United States 

Department of 

Agriculture 

Forest 

Service 

January 2009 

Environmental Impact 

Statement 

BLT Project 

Crescent Ranger District, Deschutes National Forest 

Klamath County, Oregon 

Townships 24, 25, 26 South and Ranges 6 1⁄2, 7, 8, East, Willamette Meridian 
 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its 

programs and activities on the basis of race, color, national origin, gender, 

religion, age, disability, political beliefs, sexual orientation, or marital or family 

status. (Not all prohibited bases apply to all programs.) Persons with 

disabilities who require alternative means for communication of program 

information (Braille, large print, audiotape, etc.) should contact USDA’s 

TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of 

discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, 

Whitten Building, 14th and Independence Avenue, SW, Washington, DC 

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

opportunity provider and employer. 
Environmental Impact Statement BLT Project 

i

BLT Project 

 Environmental Impact Statement 

Deschutes County, Oregon 

Lead Agency: USDA Forest Service 

Responsible Official: John P. Allen 

Deschutes National Forest Supervisor 

1001 SW Emkay Drive 

Bend, OR 97702 

For Information Contact: Chris Mickle 

Interdisciplinary Team Leader 

 (541) 433-3200 

Abstract: The Forest Service has analyzed vegetation management activities in the 80,000-acre BLT 

Project area on the Crescent Ranger District of the Deschutes National Forest. The purpose of the 

proposed actions included reducing the risk that natural disturbance processes such as insects, disease 

and wildfire, will lead to large-scale loss of forest resources and contributing to local and regional 

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

involves commercial and small-tree thinning of forested stands, prescribed burning, piling and disposal 

of activity-generated slash, and construction of 9.8 miles of temporary roads. Activities in the proposed 

action would take place over 7,499 acres. It would make available to the local economy approximately 

12.1 Million Board Feet of timber. Two action alternatives to the proposed action (Alternatives C and 

D) were developed. Alternative C was developed to respond to the needs of selected Management 

Indicator Species. It would reduce the amount of commercial harvest by about 1,728 acres with about 

9.8 Million Board Feet of timber and 8.7 miles of temporary roads. Alternative D responds to shortterm mushroom production by virtually eliminating most timber harvest west of Highway 58 over 

approximately 2,616 acres. It would provide 5.2 Million Board Feet and require 4.7 miles of temporary 

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

alternatives considered in this environmental impact statement are consistent with applicable local, 

state, and national laws and regulations and with all land management plans. Alternative B is the 

selected alternative.

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

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

with the Reviewing Officer at: 

 Appeal Deciding Officer 

 Pacific Northwest Region, USDA Forest Service 

 Attn: 1570 Appeals 

 333 S.W. First Avenue 

 PO Box 3623 

 Portland, OR 97208-3623 

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

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

this decision appears in the Bend Bulletin newspaper. The publication date of the legal notice in the 
BLT Project Environmental Impact Statement 

ii

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

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

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

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

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

containing viruses will be rejected. 

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

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

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

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

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

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

mail may be filed with the appeal); 

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

verification of the identity of the lead appellant upon request; 

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

Responsible Official, and the date of the decision; 

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

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

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

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

disagreement; 

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

and; 

9. How the appellant believes the decision specifically violates law, regulation, or policy. 

Contact Persons 

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

contact: 

Chris Mickle 

IDT leader 

Crescent Ranger District 

P.O. Box 208 

Crescent, OR 97733 

(541) 433-3200 

Holly Jewkes 

District Ranger 

Crescent Ranger District 

P.O. Box 208 

Crescent, OR 97733 

(541) 433-3200 
Environmental Impact Statement BLT Project 

 Summary 

iii

Summary ________________________________________ 

The Deschutes National Forest proposes to conduct vegetation management activities within the 

Upper Little Deschutes 5th field watershed, which totals about 80,072 acres and includes the 

upper reaches of the Little Deschutes River. Approximately 53,542 acres are National Forest 

System lands within the Deschutes National Forest, and the remaining acres are privately owned. 

The analysis area and the 5th field watershed are the same; and it is located about 50 miles south 

of Bend, Oregon, in Township 25-26 South, Range 6 1⁄2 East; T25-26 South, Range 7 East; 

Township 24 South, Range 8 East, Willamette Meridian. The entire analysis area lies within 

Klamath County. Approximately one-third of the analysis area (26,487 acres) is within the 

boundary of the Northwest Forest Plan, with about 10,190 acres in the Matrix allocation. The 

remaining two-thirds lie within the direction that is provided by the Interim Management 

Direction Establishing Riparian, Ecosystem and Wildlife Standards for Timber Sales (Eastside 

Screens). 

The Major Plant Association Groups within the BLT analysis area lodgepole pine (49 percent), 

ponderosa pine (16 percent), and mixed conifer (15 percent). The lodgepole pine is mostly 

“pure” in the lower elevations, but then interspersed with other plant associations, most often 

mixed conifer, usually in relatively abrupt transitions associated with topographic change. 

In general, the mixed conifer stands have dense understories that can contribute to overstressed 

growing conditions for the larger trees as well as increased risk of wildfire. Lodgepole pine and 

mixed conifer stands in the BLT area provide habitat for growing and harvesting matsutake 

mushrooms. 

Matsutake mushrooms are an economically important forest product. Every September, hundreds 

of harvesters come to Chemult and Crescent Lake to participate in the matsutake harvest. Harvest 

levels for mushrooms are highly variable each year due to factors such as weather and moisture 

regimes, stand progression, fungi harvesting techniques, and some types of active forest 

management that change canopy levels from “closed” to “open” and disturb soil. 

Lodgepole pine stands in the BLT area may require activities to reduce or modify fuel loads. As 

noted from the Davis Fire of 2003, the considerable loading of fuels that often dominates 

lodgepole pine stands is a very real threat to adjacent areas in the event of wildfire. Lodgepole 

pine stands in the analysis area often are heavily traversed by people, especially for recreation and 

access to mushroom harvest areas, which increases the chance of human-caused fire ignitions. 

In 1998, the Crescent Ranger District completed a Landscape Analysis Process (LAP), which 

looked at key issues regarding vegetation, terrestrial, aquatics, natural disturbance regimes and 

human uses. The intent of the LAP was to contribute to a more accurate, long-term, sustainable 

plan for the District. The LAP identified approximately 30-50 percent of the plant association 

groups found within the BLT Vegetation Management analysis area as imminently susceptible to 

a large-scale disturbance event, such as insects, disease, or wildfire. Furthermore, the LAP 

determined that a large-scale disturbance event in the BLT analysis area can impact the security 

of local communities (especially in a wildfire event), wildlife habitat, special forest products, and 

socially desirable large trees. 

Although some work to reduce risk has been accomplished in the vicinity of the BLT analysis 

area since the completion of the LAP, there is an immediate need to reduce stand density and fuel 

loadings to reduce the risk of large-scale loss of late- and old-structured stands and other forest 

resources on the landscape. 
BLT Project Environmental Impact Statement 

Summary 

iv

Key issues identified during project scoping were: 

 The potential effects of active management on selected Deschutes National Forest 

Wildlife Management Indicator Species and their habitat could alter effectiveness of 

habitat; and 

 The potential effects of active management could reduce mushroom production in the 

short-term 

These issues led the agency to develop three alternatives to the proposed action, for a total of four 

alternatives. The following is a summary of the alternatives: 

Alternative A: No Action 

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

of this analysis. Management actions otherwise authorized would not be affected. For a detailed 

description of these management actions, reference Chapter 3. 

Alternative B: The Selected Alternative 

The Proposed Action includes a variety of vegetation management activities across 

approximately 7,499 acres, and would harvest approximately 12.1 million board feet of timber. 

Refer to Figure 2-1 for locations of Alternative B units. Activities to improve forest health and 

reduce risk on the landscape include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition 

and health (HIM, 3,614 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 3,550 acres); 

• Small diameter thinning and fuels reduction on 312 acres; 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 2,312 

acres; and 

• Opportunity for utilization of forest products such as posts and poles and firewood on 

3,093 acres. 

Connected Actions

In order for Alternative B to be implemented, the following are connected actions1

: 

• About 22 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 160 

miles of Maintenance Level 1 and 2 roads. 

• About 9.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. 

Alternative C: 

Alternative C includes a variety of vegetation management activities across approximately 5,771 

acres, and would harvest approximately 9.8 million board feet of timber. This alternative was 

developed to address the needs of wildlife species that favor dense canopies and decadent 

conditions for some of their life requirements. To respond, in the development of this alternative, 

stands of late and old-structured lodgepole pine were dropped in comparison with Alternative B 

(Proposed Action) to provide for additional goshawk nesting and three-toed/black-backed 

 

1

 Please refer to the Transportation System section in Chapter 3 of this document for descriptions and 

definitions of these activities. 
Environmental Impact Statement BLT Project 

 Summary 

v

woodpecker nesting and roosting habitat. Refer to Figure 2-2 for locations of Alternative C units. 

Management activities would include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition 

and health (HIM, 2,672 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 2,765 acres); 

• Small diameter thinning and fuels reduction on 334 acres; 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 1,764 

acres; and 

• Opportunity for utilization of forest products such as posts and poles and firewood on 

2,304 acres. 

Connected Actions

In order for Alternative C to be implemented, the following are connected actions: 

• About 17 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 126 

miles of Maintenance Level 1 and 2 roads. 

• About 8.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. 

Alternative D: 

Alternative D includes a variety of vegetation management activities across approximately 2,616 

acres, and would harvest approximately 5.2 million board feet of timber. This alternative focuses 

on the short term production and harvest of matsutake mushrooms by excluding active 

management in the most productive matsutake areas. Refer to Figure 2-3 for locations of 

Alternative D units. Management activities would take place on approximately 2,616 acres, and 

would include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition 

and health (HIM, 1,323 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 981 acres); 

• Small diameter thinning and fuels reduction on 312 acres; and 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 824 

acres; and 

• Opportunity for forest products such as post and poles and firewood on 1,064 acres. 

Connected Actions

In order for Alternative D to be implemented, the following are connected actions: 

• About 11 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 76 

miles of Maintenance Level 1 and 2 roads. 

• About 4.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. 

Major conclusions include: 

Soils 

All activities have been designed to meet Forest Plan and Regional Standards. All areas where 

active management is to occur would continue to function as productive sites. 
BLT Project Environmental Impact Statement 

Summary 

vi

Forested Vegetation 

Active management in the BLT analysis area is developed to modify the effects that disturbance 

events will have on this landscape. Analysis has shown that much of the vegetative structure is 

imminently susceptible to change and cannot be sustained in any one place on the landscape for 

the long-term. Neither action alternative would eliminate risk of disturbance processes; however, 

both would take steps necessary to limit the extent of wide-scale stand replacement events, help 

provide for a mix of vegetative conditions to be present at any time, and increase the resiliency of 

forested stands. 

Fire and Fuels 

The entire BLT analysis area is within the Walker Range Community Wildfire Protection Plan 

and several small communities are embedded. A great deal of work has been completed 

surrounding these communities; however, this project focuses on identifying and maintaining 

Strategic Placement of Treatments (SPOTS). The potential effectiveness of fuels treatments was 

evaluated using risk modeling procedures using measures for the amount of overlap onto SPOTS. 

Alternative B overlaps active management into these areas the most, followed by Alternatives C 

and D. 

 

Wildlife 

After extensive analysis, it was determined that the alternatives are very similar in their effects (in 

the short term) on selected Management Indicator Species. In the longer term, Alternatives A and 

D carry the highest risk of a stand replacement event that has potential to alter habitat on a 

landscape scale. Alternatives A, B, C, and D would have “No Effect” on the northern spotted 

owl and Oregon spotted frog. Alternatives B, C, or D would result in a determination of “May 

Impact Individuals or Habitat, But Will Not Contribute To a Trend Toward Federal 

Listing or Loss of Viability To The Population or Species” for the Pacific fisher and Lewis’ 

woodpecker. 

Fisheries and Water Quality 

The determination in the Biological Assessment was that implementation of this project would 

have No Effect to bull trout or their habitat. The project will have No Impact on redband trout. 

Harvest activities and temporary road construction would occur outside of riparian resources and 

only one non-mechanical activity would occur within. It is categorized as a meadow restoration 

project and would remove encroaching lodgepole pine 3 inches and smaller and prescribe burn 

decadent willows. All activities have been designed to comply with the Riparian Reserve and 

Riparian Habitat Conservation Areas as specified in the Northwest Forest Plan and Inland Native 

Fish. 

The analysis area contains two streams (Little Deschutes and Hemlock Creek) that are listed on 

the EPA’s 303(d) list of water quality impaired water bodies. Activities would be avoided in all 

Riparian Reserves and only one small restoration activity would occur within Riparian Habitat 

Conservation Areas. No actions associated with this project would change the condition of any 

waterway or water body within the analysis area. 

Invasive Plants 

Based on the vectors and proposed activity, Alternative B was determined to have the greatest 

risk rating for introduction and spread of existing populations of invasive plants. The risk rating is 

mostly based on the amount of ground disturbance. Since Alternative B has the greatest amount 

of activity, the potential is the greatest. 

This project will use prevention as the main strategy to manage invasive plant species (R6 

Invasive Plant EIS Standard #7). Actions conducted or authorized by written permit (contracts) 
Environmental Impact Statement BLT Project 

 Summary 

vii

that operate outside the limits of the road prism, require clean equipment prior to entering 

National Forest System Lands. All active gravel, fill, sand stockpiles, quarry sites, and borrow 

material will be inspected for invasive plants before use and transport. Only weed-free gravel, 

fill, sand, and rock would be used. 

Economic and Social 

Investments in forest stands are not to be based solely on net primary aboveground productivity. 

Both forest incomes and forest structure are maintained. Although matsutake production 

recovery might occur as soon as 2 years or as many as 6 years or more following treatment 

depending on Plant Association Group and original quality of habitat, worst case scenario in 

Alternative B would retain over 91 percent of picking areas categorized as “good habitat” in the 

Upper Little Deschutes Watershed/BLT analysis area. This does not include the picking area 

surrounding the Crescent Lake/Windigo Pass area. 

None of the alternatives generates revenues that exceed all costs associated with the project. In 

regard to timber outputs, Alternative B has the greatest economic efficiency of the action 

alternatives and would harvest 12.1 million board feet (MBF), followed by Alternative C (9.8 

MBF) and Alternative D (5.2 MBF). 

Unroaded, Inventoried Roadless Area Resources 

Oregon Wild provided a map of unroaded areas that overlaps the Oregon Cascades Recreation 

Area. They requested that the Forest Service avoid timber harvest, roads, mining, development, 

and motorized recreation in roadless areas greater than or equal to 1000 acres or any roadless area 

adjacent to existing wilderness or parks and all inventoried roadless areas. Refer to the 

Unroaded/Oregon Cascades Recreation Area section in the Environmental Impact Statement for 

disclosure and a figure (Figure 3-31) overlaid by BLT activity units. 

Wild and Scenic River 

Much of the corridor has been impacted by the 1980s beetle infestation. All activities have been 

found to be consistent with the Little Deschutes Wild and Scenic Management Plan by 

maintaining the Outstandingly Remarkable Values. All activities are subordinate to the landscape 

and reduce risk of a wide-scale disturbance event. 

The BLT project includes up to 11 proposed units within the Wild and Scenic River corridor of 

the Little Deschutes River. These units have been identified for treatment to improve forest 

health conditions and promote the development of large trees by thinning small trees. This 

process would help to improve stand condition and appearance as the result of insect infestation. 

Issues to Resolve and the Decision to be Made 

Based upon the effects of the alternatives, the responsible official will decide to: 

• Select the proposed action, an action alternative that has been considered in detail, 

modify an action alternative, or select the no-action alternative. 

• Identify what mitigation measures will apply. 

• Determine what monitoring will be necessary and where it will be completed. 

The Forest Supervisor will evaluate the alternatives by: 

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

• Consider their responsiveness to the issues and concerns raised by the public and other 

agencies; and 

• Review their likely environmental effects, and in particular, their short- and long-term 

impacts and benefits to the habitat of Federally-listed threatened and endangered species. 
BLT Project Environmental Impact Statement 

Acronyms 

viii

List of Acronyms__________________________________ 

ACS - Aquatic Conservation Strategy 

BA - Biological Assessment 

BBS - Breeding Bird Surveys 

BCC - Birds of Conservation Concern 

BCR - Bird Conservation Region 

BE - Biological Evaluation 

BEMA - Bald Eagle Management Area 

BMP - Best Management Practices 

BO - Biological Opinion 

BOR - Bureau of Reclamation 

CSA - Conservation Support Areas 

CWPP - Community Wildfire Protection Plan 

DEQ - Oregon Department of Environmental Quality 

EA - Environmental Assessment 

EIS - Environmental Impact Statement 

EPA - Environmental Protection Agency 

ESA - Endangered Species Act of 1973 

FS - Forest Service 

FSH - Forest Service Handbook 

FSM - Forest Service Manual 

GNN - Gradient Nearest Neighbor 

HIM - Harvest Improvement Cut 

HTH - Harvest Thinning Cut 

HUC - Hydrologic Unit Code 

INFISH - Inland Native Fish Strategy 

LAP - Land Analysis Process 

LRMP - Deschutes National Forest Land and Resource Management 

Plan (1990) 

LSR - Late Successional Reserve 

MIIH - May Impact Individuals or Habitat but Will Not Likely 

Contribute to a Trend Towards Federal Listing or Cause a 

Loss of Viability to the Population or Species 

MOCA - Managed Owl Conservation Area 

MOU - Memorandum of Understanding 

MSA - Magnuson-Stevens Fishery Conservation Act 

MSL - Mean Sea Level 

NEPA - National Environmental Policy Act 

NFMA - National Forest Management Act 

NLAA - May Affect, but Not Likely to Adversely Affect 

NMFS - National Marine Fisheries Service 

NWFP - Northwest Forest Plan 

OCRA - Oregon Cascade Recreation Area 

ODFW - Oregon Department of Fish and Wildlife 

ORV - Outstanding Remarkable Value 

OSHA - Occupational Safety and Health Association 

PAG - Plant Association Group 

PDC - Project Design Criteria from the 2006-2009 Programmatic 
Environmental Impact Statement BLT Project 

 Acronyms 

ix

Biological Assessment 

PFA - Post-Fledgling Area 

RHCA - Riparian Habitat Conservation Area 

RR - Riparian Reserve 

TMDL - Total Maximum Daily Load 

USDA - United States Department of Agriculture 

USDI - United States Department of the Interior 

USFS - United States Forest Service 

USFWS - United States Fish and Wildlife Service 

VQO - Visual Quality Objective 

WQMP - Water Quality Management Plan 

WUI - Wildland-Urban Interface 
BLT Project Environmental Impact Statement 

Table of Contents 

x

Table of Contents ____________________________________ 

Summary ..............................................................................................................................................iii

List of Acronyms ............................................................................................................................... viii

Table of Contents.................................................................................................................................. x

List of Tables ...................................................................................................................................... xii

List of Figures ..................................................................................................................................... xv

Chapter 1. Purpose of and Need for Action ................................................................................. 1

Document Structure .............................................................................................................................. 1

Background and Existing Conditions.................................................................................................... 1

Purpose and Need for Action ................................................................................................................ 2

Proposed Action.................................................................................................................................... 3

Decision Framework............................................................................................................................. 3

Chapter 2. Alternatives, Including the proposed action .............................................................. 8

Introduction........................................................................................................................................... 8

Public Involvement ............................................................................................................................... 8

Issues................................................................................................................................................... 13

Alternatives Considered in Detail ....................................................................................................... 16

Alternative A................................................................................................................................... 17

Alternative B................................................................................................................................... 17

Alternative C................................................................................................................................... 22

Alternative D................................................................................................................................... 26

Resource Protection Measures ............................................................................................................ 28

Project Design Features Common to All Action Alternatives........................................................ 29

Mitigations Common to All Action Alternatives............................................................................ 36

Alternatives Considered but Eliminated from Detailed Study............................................................ 41

Sale Area Improvement Projects......................................................................................................... 43

Comparison of Alternatives ................................................................................................................ 44

Chapter 3. Affected Environment and Environmental Consequences ....................................... 46

Introduction......................................................................................................................................... 46

Changes Between Draft and Final EIS................................................................................................ 46

Cumulative Effects of Past, Present and Reasonably Foreseeable Future Actions............................. 47

Soil Quality ......................................................................................................................................... 51

Forested Vegetation ............................................................................................................................ 85

Long-term Climate Changes ............................................................................................................. 100

Fire and Fuels Management.............................................................................................................. 102

Wildlife ............................................................................................................................................. 129

Dead Wood Historical Range of Variation (HRV)....................................................................... 134

Management Indicator Species (MIS) .......................................................................................... 141

Threatened, Endangered, and Sensitive Species........................................................................... 180

Regional Forester’s Sensitive Species .......................................................................................... 195

Rare and Uncommon Species ....................................................................................................... 219

Birds of Conservation Concern..................................................................................................... 225

Big Game - Deer and Elk.............................................................................................................. 240

Old Growth Management.................................................................................................................. 255

Fisheries and Aquatic Resources ...................................................................................................... 261

Aquatic Conservation Strategy (ACS).......................................................................................... 274

Wild and Scenic River ...................................................................................................................... 280

Botany............................................................................................................................................... 286

Invasive Plants .................................................................................................................................. 295
Environmental Impact Statement BLT Project 

 Table of Contents 

xi

Special Concern Plants ......................................................................................................................305

Matsutake (Tricholoma magnivelare) mushrooms and Allotropa virgata (candy stick). .............305

Cultural Resources.............................................................................................................................318

Recreation..........................................................................................................................................321

Transportation System.......................................................................................................................323

Inventoried Roadless Areas ...............................................................................................................332

Unroaded Characteristics/Oregon Cascades Recreation Area...........................................................332

Scenery Resources.............................................................................................................................335

Public Health and Safety ...................................................................................................................339

Economic and Social Analysis ..........................................................................................................341

Environmental Justice and Civil Rights Impact Analysis .................................................................349

Air Quality and the Clean Air Act.....................................................................................................352

Other Disclosures ..............................................................................................................................354

Short-term Uses and Long-term Productivity ...............................................................................354

Unavoidable Adverse Effects........................................................................................................354

Irreversible and Irretrievable Commitments of Resources............................................................355

Incomplete and Unavailable Information......................................................................................356

Effects on Wetlands and Floodplains............................................................................................356

Effects on Prime Farmland, Rangeland and Forest Land..............................................................356

Energy Requirements of Alternatives ...........................................................................................357

Chapter 4. Consultation and Coordination..............................................................................358

Preparers and Contributors ................................................................................................................358

Preparers........................................................................................................................................358

Distribution of the Environmental Impact Statement........................................................................361

Literature Cited..................................................................................................................................362

Glossary.............................................................................................................................................385

Index..................................................................................................................................................389

Appendix A – Consistency With Current Laws And Management Direction............................390

Current Laws and Management Direction.........................................................................................390

Deschutes National Forest Land and Resource Management Plan ...............................................394

Wildlife Standards and Guidelines................................................................................................396

Northwest Forest Plan ...................................................................................................................397

Standards and Guidelines ..............................................................................................................399

National Fire Plan..........................................................................................................................400

Standards and Guidelines and Best Management Practices for Protection of Soil and Water 

Quality...........................................................................................................................................401

Additional Consistency......................................................................................................................404

State and Local Laws ....................................................................................................................404

National Historic Preservation Act................................................................................................404

FEIS for Managing Competing and Unwanted Vegetation and the Mediated Agreement ...........404

Appendix B – Historical Range of Variation (HRV) for Snags and Down Wood ......................405

Appendix C – Response to Comments .....................................................................................413
BLT Project Environmental Impact Statement 

List of Tables 

xii

List of Tables ____________________________________ 

Table 2-1. Public Involvement in the BLT Project Planning Process...........................................................8

Table 2-2. Alternative B Active Management Units...................................................................................18

Table 2-3. Alternative C Management Units .............................................................................................22

Table 2-4. Alternative D Management Units .............................................................................................26

Table 2-5. Seasonal Restrictions on Disturbing Activities near Active Nest Sites, Wolverine Dens, and Big 

Game Calving/Fawning Habitat ...................................................................................................32

Table 2-6. Minimum Snag Levels to Determine Snag Creation ................................................................33

Table 2-7. Minimum Down Wood Levels Regardless of Location.............................................................35

Table 2-8. Connectivity Corridor Acres by Alternative...............................................................................37

Table 2-9. Comparison of the Activities by Alternative..............................................................................44

Table 2-10. Comparison of How Each Alternative Responds to the Purpose and Need...........................44

Table 2-11. Comparison of How Each Alternative Responds to the Key Issues.......................................45

Table 3-1. Past, Present, and Reasonably Foreseeable Future Actions...................................................48

Table 3-2. Sample of Projects and Rationale why they will not be discussed in Cumulative Effects 

Analysis .......................................................................................................................................49

Table 3-3. SRI Mapping Unit Interpretations and Amounts of Each Soil Type in the BLT Analysis Area..55

Table 3-4. Minimum Ground Cover Objectives to Minimize Soil Erosion by Water and Wind...................57

Table 3-5. Land type acres that contain localized areas of sensitive soils within the BLT Analysis Area 

(Soil Resource Inventory, Deschutes National Forest, 1976) ......................................................58

Table 3-6. Road Categories and Determination of Respective Detrimental Soil Condition.......................60

Table 3-7. Alternative B Summary ............................................................................................................67

Table 3-8. Mechanical Vegetation Activity on Landtypes that Contain Sensitive Soils in Alternative B ....69

Table 3-9. Alternative B Units with Slopes Greater Than 30 Percent Prescribed for Advanced................69

Table 3-10. Estimated Effects to Soil Productivity for Alternative B ..........................................................71

Table 3-11. Alternative C Summary ..........................................................................................................75

Table 3-12. Mechanical Vegetation Activities on Landtypes that Contain Sensitive Soils in Alternative C76

Table 3-13. Alternative C Units with Slopes Greater Than 30 Percent Prescribed for Advanced Logging 

Systems.......................................................................................................................................76

Table 3-14. Estimated Effects to Soil Productivity for Alternative C..........................................................77

Table 3-15. Alternative D Summary ..........................................................................................................79

Table 3-16. Mechanical Vegetation Activities on Landtypes that Contain Sensitive Soils in Alternative D81

Table 3-17. Alternative D Units with Slopes Greater Than 30 Percent Prescribed for Advanced Logging 

Systems.......................................................................................................................................81

Table 3-18. Estimated Effects to Soil Productivity for Alternative D..........................................................81

Table 3-19. Summary of the Action Alternatives.......................................................................................84

Table 3-20. Seral/Structural Matrix and Definitions (Seral Structural Stages)...........................................86

Table 3-21. Mushroom Production............................................................................................................93

Table 3-22. Acres Changed to a More Sustainable Condition ..................................................................97

Table 3-23. Volume by Alternative in Million Board Feet ..........................................................................97

Table 3-24. Historic Range of Variability (HRV) for Medium and Large Trees by Plant Association Group 

and Seral Stage within the Upper Little Deschutes 5th Field Watershed......................................99

Table 3-25. Communities at Risk in the BLT Analysis Area....................................................................105

Table 3-26. Fire Regime Condition Classes............................................................................................108

Table 3-27. Fuel Models in the BLT Analysis Area .................................................................................109

Table 3-28. Summary of Existing Forest Structure within the BLT Analysis Area...................................114

Table 3-29. Percent of a Wildfire Area Resulting in Stand Replacement; Comparison of Historical 

Conditions and Problem Fire Conditions (represented by Davis Fire, 2003) .............................114

Table 3-30. Existing Stand Characteristic by Plant Association Groups Proposed for Activity within the 

BLT............................................................................................................................................114

Table 3-31. National Fire Danger Rating for the BLT Area .....................................................................115

Table 3-32. Size and Number of Fires within the Analysis Area .............................................................115

Table 3-33. Predicted Fire Behavior Associated with Fuel Models and Weather Typical of the BLT 

Analysis Area.............................................................................................................................116

Table 3-34. Alternative A Fire Behavior by Weather and Fuel Model .....................................................117

Table 3-35. Alternative B Fire Behavior within Activity Units Compared to Alternative A........................121

Table 3-36. Alternative C Fire Behavior within Activity Units Compared to Alternative A........................124

Table 3-37. Alternative D Fire Behavior within Activity Units Compared to Alternative A........................126

Table 3-38. Example Table from DecAID ...............................................................................................130

Table 3-39. Habitat Types by Acreage within the Planning Area ............................................................131

Table 3-40. HRV Developed for Each Habitat Type................................................................................133

Table 3-41. Deschutes National Forest Plan Standards for Snags.........................................................135
Environmental Impact Statement BLT Project 

 List of Tables 

xiii

Table 3-42. Deschutes National Forest Plan Standards for Down Wood. ...............................................135

Table 3-43. Structural Condition by Habitat Type in BLT ........................................................................136

Table 3-44. Comparison of Existing Snag Densities with HRV................................................................137

Table 3-45. Comparison of Existing Down Wood Densities with HRV ....................................................137

Table 3-46. Alternative B Acres of Activity by Habitat Type.....................................................................138

Table 3-47. Deschutes National Forest Management Indicator Species.................................................141

Table 3-48. Acres of Potential Goshawk Nesting Habitat within the BLT Analysis Area .........................144

Table 3-49. Viable Ecosystem Modeling Projections of Goshawk Nesting Habitat over Time.................144

Table 3-50. Projected Changes to Black-Backed and Three-Toed Woodpecker Nesting Habitat...........151

Table 3-51. Tolerance Intervals for Black-Backed Woodpeckers and Snag Use ....................................152

Table 3-52. Tolerance Intervals for Black-Backed Woodpecker and Down Wood Use ...........................152

Table 3-53. Tolerance Intervals for Three-Toed Woodpecker and Down Wood Use ..............................153

Table 3-54. Viable Ecosystem Modeling Projections of Black-Backed and Three-Toed Woodpecker 

Nesting Habitat over Time..........................................................................................................154

Table 3-55. American Marten Tolerance Intervals and Snag Use...........................................................162

Table 3-56. American Marten Tolerance Intervals and Down Wood Use................................................162

Table 3-57. Pileated Woodpecker Tolerance Intervals and Snag Use ....................................................166

Table 3-58. Pileated Woodpecker Tolerance Intervals and Down Wood Use .........................................166

Table 3-59. Williamson Sapsucker Tolerance Intervals and Snag Use. ..................................................167

Table 3-60. Acres of Potential Great Gray Owl Nesting Habitat Affected By the BLT Project .................172

Table 3-61. Acres of Potential Sharp-shinned and Cooper’s Hawks Nesting Habitat..............................177

Table 3-62. Threatened, Endangered, and Federal Candidate Wildlife Species Documented to Occur or 

may Potentially Occur within the BLT Analysis Area..................................................................180

Table 3-63. Summary of Conclusion of Effects for Threatened, Endangered, and Federal Candidate 

Wildlife Species, BLT Project .....................................................................................................180

Table 3-64. Dispersal Habitat Definition Developed by the Deschutes National Forest ..........................184

Table 3-65. Tolerance Intervals for the Pacific Fisher and Snag Use......................................................191

Table 3-66. Tolerance Intervals for the Pacific Fisher and Down Wood Use...........................................192

Table 3-67. Regional Forester Listed Sensitive Animal Species for the Deschutes National Forest .......195

Table 3-68. Summary of Conclusion of Effects to Region 6 Sensitive Animal Species ...........................197

Table 3-69. Bald Eagle Nest Territories and Historical Nesting Status (1998-2007) for Territories on the 

Crescent Ranger District ............................................................................................................199

Table 3-70. Tolerance Intervals for White-headed Woodpeckers............................................................207

Table 3-71. Tolerance Interval Projections for the Pygmy Nuthatch........................................................220

Table 3-72. Bat Species Known or Suspected to Occur and Habitat Requirements ...............................223

Table 3-73. Bird Conservation Region 9 (Great Basin) ...........................................................................226

Table 3-74. Landbird Focal Species for Central Oregon .........................................................................228

Table 3-75. BLT Road Densities by Subwatershed Expressed in Miles per Square Mile........................242

Table 3-76. Open Road Densities within the Hemlock Key Elk Area.......................................................242

Table 3-77. Current Forage and Cover Conditions within the Hemlock Key Elk Area .............................243

Table 3-78. Change in Cover Condition by Subwatershed by Alternative on National Forest lands .......244

Table 3-79. Change in Cover Condition for Hemlock Key Elk Area.........................................................245

Table 3-80. Threatened, Endangered, and Sensitive Fish Species.........................................................261

Table 3-81. Subwatersheds within the BLT Analysis Area ......................................................................263

Table 3-82. Perennial Streams within the BLT Analysis Area .................................................................263

Table 3-83. Streams in BLT Planning Area and Fish Found Within ........................................................263

Table 3-84. Stream Crossings in the BLT Analysis Area.........................................................................271

Table 3-85. Units and Acres within the Wild and Scenic River Corridor by Alternative ...........................282

Table 3-86. Prefield Review Summary (2008 Sensitive Plant List)..........................................................287

Table 3-87. Rare or Uncommon Fungal and Plant Species with Known Sites on the Deschutes National 

Forest as of March 21, 2004 ......................................................................................................292

Table 3-88. Rare or uncommon plant taxa surveyed for in 2003.............................................................294

Table 3-89. Risk Rating for Invasive Plants by Alternative ......................................................................304

Table 3-90. BLT Analysis Area Matsutake Potential Habitat by Plant Association Group .......................310

Table 3-91. Alternative B Potential Matsutake Habitat by Plant Association Group ................................313

Table 3-92. Alternative C Potential Matsutake Habitat by Plant Association Group ................................313

Table 3-93. Alternative D Potential Matsutake Habitat by Plant Association Group ................................314

Table 3-94. Miles of Road by Maintenance Level....................................................................................325

Table 3-95. Road Density on a Subwatershed Basis (Mile/Square Mile) ................................................326

Table 3-96. Road Density on a Key Elk Area Basis ................................................................................326

Table 3-97. Alternative B Road Miles (Forest Service Jurisdiction) by Maintenance Level .....................327

Table 3-98. Alternative C Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level.............328

Table 3-99. Alternative D Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level.............328

Table 3-100. Temporary Road Estimate, By Alternative .........................................................................328
BLT Project Environmental Impact Statement 

List of Tables 

xiv

Table 3-101. Acres of Scenic Views Management Area by Visual Quality Objective in the BLT Analysis 

Area...........................................................................................................................................335

Table 3-102. Active management in Scenic Views by Acres ..................................................................336

Table 3-103. Prescriptions in Foreground Retention by Acres................................................................337

Table 3-104. Klamath County Employment.............................................................................................342

Table 3-105. Volume Removed in 1,000s of Board Feed (Scribner Log Scale)......................................344

Table 3-106. Potential Jobs in the Timber Industry Created by the BLT.................................................346

Table 3-107. Klamath County Employment in the Timber industry .........................................................346

Table 3-108. Cash Flow Analysis by Alternative.....................................................................................347

Table 3-109. Volume of Wood in Thousand Board Feet .........................................................................347

Table 3-110. Potential Emission from a “Problem Fire” Scenario ...........................................................353

Table 3-111. Alternative B Prescribed Fire Emissions (7,499 acres)......................................................353

Table 3-112. Alternative C Prescribed Fire Emissions (5,771 acres)......................................................353

Table 3-113. Alternative D Prescribed Fire Emissions (2,616 acres)......................................................353
Environmental Impact Statement BLT Project 

 List of Figures 

xv

List of Figures ____________________________________ 

Figure 1-1. Location of the BLT Project ...................................................................................................... 5

Figure 1-2. Deschutes LRMP Management Areas in the BLT Analysis Area ............................................. 6

Figure 1-3. Northwest Forest Plan Allocations in the BLT Analysis Area.................................................... 7

Figure 2-1. BLT Project Alternative B........................................................................................................ 21

Figure 2-2. BLT Project Alternative C ....................................................................................................... 25

Figure 2-3. BLT Project Alternative D ....................................................................................................... 28

Figure 2-4. Comparison of anticipated effects of small-tree thinning on basal area.................................. 43

Figure 3-1. Sensitive Soil Areas Overlaid with Activity Units..................................................................... 83

Figure 3-2. Lodgepole Pine Departure from Historical Range of Variability.............................................. 89

Figure 3-3. Ponderosa Pine Dry Departure from Historical Range of Variation ........................................ 90

Figure 3-4. Ponderosa Pine Moist Departure from Historical Range of Variation ..................................... 90

Figure 3-5. Mixed Conifer Dry Departure from Historical Range of Variation............................................ 91

Figure 3-6. Mixed Conifer Moist Departure from Historical Range of Variation......................................... 92

Figure 3-7. Illustration of a Stand Before Thinning (HTH)......................................................................... 95

Figure 3-8. Illustration of a Stand After Thinning (HTH)............................................................................ 96

Figure 3-9. Illustration of Before Improvement Cut ................................................................................... 96

Figure 3-10. Illustration of After Improvement Cut .................................................................................... 97

Figure 3-11. Walker Range Community Wildfire Protection Plan............................................................ 105

Figure 3-12. Fire by Statistical Cause in the BLT Area ........................................................................... 116

Figure 3-13. Alternative A Minimum Travel Time 25 Years..................................................................... 119

Figure 3-14. Alternative B Minimum Travel Time 25 years ..................................................................... 123

Figure 3-15. Alternative C Minimum Travel Time 25 years..................................................................... 125

Figure 3-16. Alternative D Minimum Travel Time 25 years..................................................................... 127

Figure 3-17. Changes in Distribution of Snag Densities for Lodgepole Pine Habitat over Time ............. 139

Figure 3-18. Changes in Distribution of Down Wood over Time in LP Habitat........................................ 139

Figure 3-19. Changes in Distribution of Snag Densities in Ponderosa Pine Habitat over Time .............. 140

Figure 3-20. Changes in Distribution of Snag Densities in Mixed Conifer Habitat over Time.................. 140

Figure 3-21. Potential Northern Goshawk Nesting Habitat Based on the Viable Ecosystem Model ....... 143

Figure 3-22. Black-Backed and Three-Toed Woodpeckers Nesting Habitat, Down Wood, and Snag 

Densities.................................................................................................................................... 150

Figure 3-23. Potential American Marten Habitat Modeled by Viable Ecosystem Model ......................... 159

Figure 3-24. Pacific Fisher Habitat.......................................................................................................... 190

Figure 3-25. Connectivity Corridors ........................................................................................................ 250

Figure 3-26. Old Growth Management Areas within the BLT Analysis Area........................................... 256

Figure 3-27. Wild and Scenic River Corridor........................................................................................... 280

Figure 3-28. BLT Invasive Species Sites ................................................................................................ 296

Figure 3-29. Action Alternative Temporary Road Construction West of Highway 58 .............................. 329

Figure 3-30. Action Alternative Temporary Road Construction East of Highway 58 ............................... 330

Figure 3-31. Oregon Wild Roadless Data and BLT Activity Units ........................................................... 334

Figure 3-32. Annual Average Unemployment Rate Compared to the State and the Nation ................... 343

Environmental Impact Statement BLT Project 

 Chapter 1 

1

CHAPTER 1. PURPOSE OF AND NEED FOR ACTION 

Document Structure _________________________________ 

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

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

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

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

chapters: 

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

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

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

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

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

achieving the stated purpose. These alternatives were developed based on significant issues 

raised by the public and other agencies. This discussion also includes mitigation measures. 

Finally, this section provides a summary table of the environmental consequences associated 

with each alternative. 

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

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

analysis is organized by resource area. 

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

agencies consulted during the development of the environmental impact statement. 

• Index: The index provides page numbers by subject. 

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

presented in the environmental impact statement. Appendix A describes the management areas 

and consistency with current laws and management direction. 

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

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

Background and Existing Conditions___________________ 

The Deschutes National Forest proposes to conduct vegetation management activities within the 

Upper Little Deschutes 5th field watershed, which totals about 80,072 acres and includes the upper 

reaches of the Little Deschutes River. Approximately 53,542 acres are National Forest System lands 

within the Deschutes National Forest, and the remaining acres are privately owned. The analysis area 

and the 5th field watershed are the same; and it is located about 50 miles south of Bend, Oregon, in 

Township 25-26 South, Range 6 1⁄2 East; Township 25-26 South, Range 7 East; Township 24 South, 

Range 8 East, Willamette Meridian. The entire analysis area lies within Klamath County. 

Approximately one-third of the analysis area (26,487 acres) is within the boundary of the Northwest 

Forest Plan, with about 10,190 acres in the Matrix allocation. The remaining two-thirds lie within the 

direction that is provided by the Interim Management Direction Establishing Riparian, Ecosystem and 

Wildlife Standards for Timber Sales (Eastside Screens). 

The Major Plant Association Groups within the BLT analysis area lodgepole pine (49 percent), 

ponderosa pine (16 percent), and mixed conifer (15 percent). The lodgepole pine is mostly “pure” in 
BLT Project Environmental Impact Statement 

Chapter 1 

2

the lower elevations, but then interspersed with other plant associations, most often mixed conifer, 

usually in relatively abrupt transitions associated with topographic change. 

In general, the mixed conifer stands have dense understories that can contribute to overstressed growing 

conditions for the larger trees as well as increased risk of wildfire. Lodgepole pine and mixed conifer 

stands in the BLT area provide habitat for growing and harvesting matsutake mushrooms. 

Matsutake mushrooms are an economically important forest product. Every September, hundreds of 

harvesters come to the Chemult and Crescent Ranger Districts to participate in the matsutake harvest. 

Harvest levels for mushrooms are highly variable each year due to factors such as weather and moisture 

regimes, stand progression, fungi harvesting techniques, and some types of active forest management 

that change canopy levels from “closed” to “open” and disturb soil. These physical and biological 

conditions are discussed in detail in Chapter 3, Special Concern Plants. 

Older and denser lodgepole pine stands in the BLT area may require activities to reduce or modify fuel 

loads. As noted from the Davis Fire of 2003, the considerable loading of fuels that often dominates 

lodgepole pine stands is a very real threat to adjacent areas in the event of wildfire. Lodgepole pine 

stands in the analysis area often are heavily traversed by people, especially for recreation and access to 

mushroom harvest areas, which increases the chance of human-caused fire ignitions. 

In 1998, the Crescent Ranger District completed a Landscape Analysis Process (LAP) which looked at 

key issues regarding vegetation, terrestrial, aquatics, natural disturbance regimes and human uses. The 

intent of the LAP was to contribute to a more accurate, long-term, sustainable plan for the District. The 

LAP identified approximately 30-50 percent of the plant association groups found within the BLT 

Project analysis area as imminently susceptible to a large-scale disturbance event, such as insects, 

disease, or wildfire. Furthermore, the LAP determined that a large-scale disturbance event in the BLT 

analysis area can impact the security of local communities (especially in a wildfire event), wildlife 

habitat, special forest products, and socially desirable large trees. 

Although some work toward risk reduction has been accomplished in the vicinity of the BLT analysis 

area since the completion of the LAP, there is an immediate need to further reduce fuel loadings and the 

density of trees to decrease the risk of large-scale loss of late- and old-structured stands and other forest 

resources on the landscape. 

Purpose and Need for Action__________________________ 

1. There is a need to reduce forest vegetation density so as to lessen the risk that disturbance 

events such as insect, disease, and wildfire will lead to large-scale loss of forest. 

Currently, values associated with management areas such as Wild and Scenic Rivers, Old Growth 

and other special places (including lands that interface urban areas) have a common denominator - 

forest health. Whether it is the aesthetic and spiritual value of large trees, habitat for vegetative 

and wildlife communities, or risk to a populated subdivision, how much of the forest that is 

maintained in a condition that is sustainable on the landscape affects the values people associate 

with these management areas. This also includes limiting the extent of a potential wildfire within 

the Wildland Urban Interface (WUI). Appendix A summarizes these values and management 

direction, but a Landscape Analysis Process has identified too much of the landscape in a condition 

susceptible to a wide-scale disturbance. The Forest Plan (as amended) supports proactive 

maintenance and enhancing the vigor of the forest in preventing a stand replacement event, rather 

than waiting (4-36). 
Environmental Impact Statement BLT Project 

 Chapter 1 

3

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

wood fiber products. 

The Forest Plan (as amended) supports management of timber resources and recognizes the value 

in a way that is consistent with other resource objectives, environmental constraints, and economic 

efficiency (4-37). 

Proposed Action ____________________________________ 

The action proposed by the Forest Service to meet the purpose and need is to utilize silvicultural and 

fuels reduction activities to limit the extent of a wide-scale loss of forest from wide-scale disturbance 

processes across the larger landscape. Strategic Placement of Treatments (SPOT) was used to identify 

those areas where active management would be most efficient in protecting homes. By design, the 

Proposed Action would maintain late- and old-structured forest with no net loss. The goal is to bring 

appropriate stands into a condition where reintroduction of fire to fire-dependent ecosystems operates 

as a natural fuels reduction agent. These actions would maintain the forests in a more sustainable 

condition, continue long-term harvesting of fungi in the analysis area, protect communities from 

wildfire, and offer economic opportunities that result from vegetation management activities. 

The Proposed Action includes a variety of vegetation management activities across approximately 

7,499 acres, and would harvest approximately 12.1 million board feet of timber. Those activities would 

reduce risk from a large disturbance (particularly from insects and wildfire). However, it would reduce 

potential nesting habitat for some Management Indicator Species by 12 percent and potentially reduce 

short-tern mushroom production on 1,454 acres. Refer to Figure 2-1 for locations of Alternative B 

units and Table 2-2 for site-specific prescriptions. Activities to improve forest health and reduce risk 

on the landscape include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition and 

health (HIM, 3,614 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 3,550 acres); 

• Small diameter thinning and fuels reduction outside timber harvest units on 312 acres; 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 2,312 

acres; and 

• Opportunity for utilization of forest products such as posts and poles and firewood on 3,093 

acres. 

A detailed description of the proposed action, including maps showing the locations of all activities, can 

be found in Chapter 2 of this document. All unit boundaries are approximate and would be identified to 

match site-specific conditions as described in this document. 

Decision Framework__________________________________ 

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

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

Responsible Official can decide to: 

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

action alternative, or select the no-action alternative. 

• Identify what Project Design Features and mitigation measures will apply. 

• Determine what monitoring will be necessary and where it will be completed. 
BLT Project Environmental Impact Statement 

Chapter 1 

4

The Forest Supervisor will evaluate the alternatives by: 

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

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

agencies; and 

• Reviewing their likely environmental effects. 
Environmental Impact Statement BLT Project 

 Chapter 1 

5

R. 09 E. R. 10 E.

T. 24 S.

T. 25 S.

58

61

US-97

94

60

46

62

60

60

60

Crescent Lake

Fawn Lake

Maidu Lake

Oldenberg Lake

Bingham Lakes

State Of Oregon

Deschutes

National

Forest

Crescent

Ranger

District

BLT Project

Area

0 1 2 3 4 Miles

Figure 1-1. Location of the BLT Project 
BLT Project Environmental Impact Statement 

Chapter 1 

6

Figure 1-2. Deschutes LRMP Management Areas in the BLT Analysis Area 

58

SU 9- 7

61

Deschutes Forest Plan

General ForestOld GrowthOregon Cascade Rec. AreaScenic View Partial Retention ForegroundScenic View Partial Retention MiddlegroundWildernessWild and Scenic River /Administratively WithdrawnOther Ownership

0123 0.5

Miles

The USDA is an equal opportunity provider and employer

jm 1/6/09T:\r06\des\cre\project\eis\eis_blt\gis\map_product

Key Ellk Range

Potential Management Activity Units

 State-BLM-County Roads

 BLT Boundary
Environmental Impact Statement BLT Project 

 Chapter 1 

7

Figure 1-3. Northwest Forest Plan Allocations in the BLT Analysis Area T. 24 S. T. 25 S. R. 09 E. R. 10 E. Crescent Lake Fawn Lake

Maidu Lake

Oldenberg Lake

Bingham Lakes

58

61

US 9- 7

64

62

60

62

60

60

60

2

62

NW Forest PlanALLOCATION

Administrative WithdrawalCongressional WithdrawalLate Successional ReserveMatrixOther Ownership

0123 0.5

Miles

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BLT BoundaryState-BLM-County RoadsArterial Roads
BLT Project Environmental Impact Statement 

Chapter 2 

8

CHAPTER 2. ALTERNATIVES, INCLUDING THE 

PROPOSED ACTION 

Introduction ________________________________________ 

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

compares the alternatives considered for the BLT Project. It includes a description and map of each 

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

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

Some of the information used to compare the alternatives is based upon the design of the alternative and 

some of the information is based upon the environmental, social and economic effects of implementing 

each alternative. 

Public Involvement __________________________________ 

The BLT project has truly been an effort to reach out to the stakeholders and modify activities to 

address their concerns. On November 3, 2003, scoping began on the BLT project for an environmental 

assessment. At that time, approximately 14,000 acres were proposed for active management. A 

decision was made to prepare and Environmental Impact Study and a Notice of Intent (NOI) was 

published in the Federal Register on April 1, 2005. The NOI asked for public comment on the proposal 

from April 1 - May 1, 2005. A scoping letter was again sent to interested citizens on April 22, 2005, 

with a 12,800-acre proposed action. Accounting for economics to allow for an economical timber sale 

and actual on-the-ground layout resulted in a proposed action of 7,499 acres. Another opportunity to 

comment on the 7,499-acre Proposed Action and the alternatives was provided March 28, 2008. 

Interested parties were updated on the analysis and asked to comment on the draft alternatives. The 

following table displays the public involvement and collaboration that has occurred. The entire process 

was open to the public and many of the stakeholders that weighed in were matsutake harvesters and 

those that advocate on their behalf. Much of the concern raised involved the effect to matsutake 

production and the short-term effect from opening the tree canopy and disturbance to the soil. This 

became the basis for a key issue and resulted in an alternative that responded. 

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

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

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

3, 2008. The public comment period ended November 17, 2008. During this period, the Forest Service 

received comments from different sectors of the public, with a range of concerns and questions. Some 

comments resulted in a clarification of discussions within the DEIS. All comments were reviewed and 

substantive comments received the focus during this comment analysis. The complete comment record 

is kept within the BLT Project public record and is available for review at the Crescent Ranger District, 

Crescent, Oregon. 

Table 2-1. Public Involvement in the BLT Project Planning Process 

Date Stakeholder Format/Information 

September 3, 

2002 

Harvesters and 

interested parties 

Matsutake camp meeting. In addition to discussions on 

the harvest season, a field trip was organized in response 

to a petition received by the Forest Service expressing 

concerns over vegetation management in the Crescent 

Lake area. Baja timber sale (in progress at the time) was 

the focus with input regarding future vegetation 

management in the area. 
Environmental Impact Statement BLT Project 

 Chapter 2 

9

Date Stakeholder Format/Information 

October 1, 

2002 

Mushroom 

harvesters and 

community 

volunteers 

Matsutake camp meeting. Topics for discussion 

included the upcoming harvest season; the petition 

referenced from September 3, 2002, the Baja Timber 

Sale, organization for the October 16, 2002 field trip to 

the harvest area and future vegetation management 

projects. 

October 8, 

2002 

Mushroom 

harvesters and 

community 

volunteers 

Matsutake camp meeting. Topics for discussion 

included the upcoming harvest season; the petition 

referenced from September 3, 2002, the Baja Timber 

Sale, organization for the October 16, 2002 field trip to 

the harvest area and future vegetation management 

projects. 

October 15, 

2002 

Mushroom 

harvesters 

Matsutake camp meeting. Topics for discussion 

included the upcoming harvest season; the petition 

referenced from September 3, 2002, the Baja Timber 

Sale, organization for the October 16, 2002 field trip to 

the harvest area and future vegetation management 

projects. 

October 16, 

2002 

Mushroom 

harvesters 

A field trip to the Baja and BLT (before a specific 

proposal was initiated) project areas were attended to 

discuss concerns over vegetation management and 

matsutake harvest in the area. 

October 18, 

2002 

Mushroom 

harvesters 

Matsutake camp meeting to discuss the harvest season, 

the petition referenced from October 15, 2002, and the 

Baja and future vegetation management projects. 

October 22, 

2002 

Mushroom 

harvesters 

Matsutake camp meeting to discuss the harvest season, 

the petition referenced from October 15, 2002, and the 

Baja and future vegetation management projects. 

November 

21, 2002 

Pacific West 

Community 

Center/mushroom 

harvesters 

Letter documenting collaboration and agreed-to actions 

with stakeholders for the Wood Fiber Timber sale and a 

process for subsequent vegetation management within 

the Crescent Lake area. 

April 16, 

2003 

Alliance of Forest 

Workers and 

Harvesters 

Letter documenting efforts on the Crescent Lake 

Monitoring project, logistical matters regarding 

mushroom permits, camping, and enforcement, and 

harvesters appreciation for the willingness of the Forest 

Service in addressing concerns over the Woody Fiber 

Timber Sale (Baja EA) in the Windigo Pass area. 

June 27, 

2003 

Alliance of Forest 

Workers and 

Harvesters 

Letter clarifying law enforcement, camping, closed 

areas, season length, permits, and harvester relations. 

August 16, 

2003 

Mushroom 

harvesters from the 

community of 

Stockton 

Meeting with members of Asian Pacific Selfdevelopment and Residential Association in Stockton, 

California to discuss the upcoming harvest season, 

potential vegetation management within the picking 

area, past timber sales (Baja), and the Davis Fire which 

started June 28, 2003. 

September 8, 

2003 

Mushroom 

harvesters 

Matsutake camp meeting to discuss harvest season, 

monitoring, past and upcoming vegetation management 

projects such as Baja and BLT, and picking 

opportunities for morels in the Davis Fire. 
BLT Project Environmental Impact Statement 

Chapter 2 

10

Date Stakeholder Format/Information 

September 

29, 2003 

Mushroom 

harvesters 

Matsutake camp meeting to discuss harvest season 

logistical matters, monitoring, past and upcoming 

vegetation management projects such as Baja and BLT, 

and picking opportunities for morels in the Davis Fire. 

November 3, 

2003 District mailing list 

First public scoping letter to all those who have 

expressed an interest on the district mailing list 

regarding vegetation management in the BLT analysis 

area. At this time, BLT was also added to the central 

Oregon website, maintained by the Deschutes national 

Forest to solicit public comment/collaboration. 

November 6, 

2003 

Susan Chapp, 

Forestry Action 

Committee 

Provided large map of the BLT analysis area proposal. 

November 6, 

2003 

Vern Odem, 

mushroom 

harvester and 

monitor 

Provided large map of the BLT analysis area proposal. 

November 

18, 2003 

Susan Chapp, 

Forestry Action 

Committee 

Provided another large map of the analysis area 

including a request for a display of secondary roads. 

November 

21, 2003 

Alliance of Forest 

Workers and 

Harvesters 

Provided large map of the BLT analysis area proposal 

and another scoping letter. 

November 

21, 2003 

Pacific West 

Community 

Forestry Center 

Provided large map of the BLT analysis area proposal. 

November 

24, 2003 

Pacific West 

Community 

Forestry Center 

Request to extend public scoping one more season due 

to the transient nature of harvesters to include comments 

from stakeholders who may not be present and able to 

provide comments this harvest season. 

February 8, 

2004 

Members of Asian 

Pacific Selfdevelopment and 

Residential 

Association in 

Stockton, CA and 

advocacy groups 

Meeting with approximately 15 harvesters and advocacy 

group members to discuss logistical matters related to 

past and upcoming harvest seasons, and to discuss and 

solicit public input on proposed BLT project. 

February 19, 

2004 

Sophat Sorn, 

harvester 

Provided large map of the BLT analysis area proposed 

action. 

June 28, 

2004 

Mushroom 

harvesters, Forest 

Community 

Research 

Field trip to BLT analysis area and follow-up letter to 

acknowledge efforts of the Forest Service on 

collaborative efforts, and to document agreements 

regarding past and future vegetation management in the 

harvesting area. 

August 29, 

2004 

Mushroom monitor 

and community 

volunteer 

Pre-season matsutake meeting with Vern Odem and 

Gloria Gibbs to discuss procedure for scoping on the 

BLT project and mushroom season logistics. 

September 1, 

2004 

Mushroom 

monitors, 

harvesters, and 

research scientists 

Field trip to matsutake mushroom research plots in 

Toketee, Oregon on the Umpqua National Forest to 

discuss harvest practices and effects of vegetation 

management on fungi populations. 
Environmental Impact Statement BLT Project 

 Chapter 2 

11

Date Stakeholder Format/Information 

September 1 

through 

November 1, 

2004 

Mushroom 

harvesters 

Site-specific comment cards from harvesters. Key areas 

were posted in the analysis area with maps in order to 

solicit comments on a site specific basis. Also, an 

information center was posted and used as a collection 

site in the industrial camping area. 

September 

23, 2004 

Mushroom 

harvesters 

Matsutake camp meeting during harvest season to 

discuss harvest practices, proposed vegetation 

management in the BLT analysis area, and other 

projects being implemented within the mushroom 

harvest area. 

September 

26, 2004 

Readers of the 

Oregonian 

newspaper 

Reporter’s reactions on the relationship between 

harvesters and the Forest Service; including proposed 

activities with the BLT project. 

October 6, 

2004 

Mushroom 

harvesters 

Matsutake camp meeting during harvest season to 

discuss harvest practices, proposed vegetation 

management in the BLT analysis area, and other 

projects being implemented within the mushroom 

harvest area. 

October 12, 

2004 Local community Community Wildfire Protection Plan meeting 

October 14, 

2004 

Pacific West 

Community 

Forestry Center 

Correspondence regarding concerns with proposed BLT 

project and to set up a field trip for October 18, 2004 to 

discuss prescriptions. 

October 16, 

2004 

Crescent Lake, 

Oregon area 

homeowners 

Community Wildfire Protection Plan meeting 

October 18, 

2004 

Harvesters in the 

Crescent Lake area 

Notes and ideas from a harvester meeting and field trip 

associated with the Crescent Lake Monitoring Project 

October 19, 

2004 

Matsutake camp 

harvesters 

Closeout matsutake camp meeting to review mushroom 

harvesting issues and proposed vegetation management 

in the BLT analysis area. 

October 21, 

2004 

Wagon Trail 

Subdivision 

homeowners, La 

Pine, Oregon 

Community Wildfire Protection Plan meeting 

October 22, 

2004 

Mushroom 

harvesters from the 

community of 

Santa Cruz, CA 

Community meeting with harvesters to work on an 

alternative for the BLT project that would be supported 

by the harvesters, harvest season issues, Davis Fire 

mushrooms, and the recent Baja vegetation management 

project. 

October 23, 

2004 

Hwy 31 and 

Gilchrist/Crescent 

area homeowners 

Community Wildfire Protection Plan meeting 
BLT Project Environmental Impact Statement 

Chapter 2 

12

Date Stakeholder Format/Information 

November 

16, 2004 

Umpqua, Winema, 

Willamette, 

Deschutes National 

Forest and 

Regional Office 

personnel 

responsible for 

administering the 

mushroom program 

Multi-forest mushroom coordination meeting to assess 

the mushroom season, and to discuss the National 

Environmental Policy Act regarding vegetation 

management and mushroom harvesting. 

December 

16, 2004 Local community 

Community Wildfire Protection Plan meeting notes, 

including recommended actions for BLT, attended by 

local private, state, and federal members. 

February 2, 

2005 

Sierra Institute for 

Community and 

Environment 

Correspondence regarding BLT and planning for 

upcoming California meetings. 

February 8, 

2005 

Sierra Institute for 

Community and 

Environment 

Correspondence regarding BLT and planning for 

upcoming California meetings. 

February 15, 

2005 

Forestry Action 

Committee 

Conversation regarding upcoming meetings in 

California 

February 15, 

2005 

Umpqua, Winema, 

Willamette, 

Deschutes National 

Forests and Regional 

Office personnel 

responsible for 

administering the 

mushroom program 

Multi-forest mushroom coordination meeting to discuss 

harvest techniques, fungi seasons, cost reimbursable 

agreements, and consultation with tribes. 

March 2, 

2005 

Forestry Action 

Committee 

Various maps of BLT analysis area were provided ahead 

of time and mailed to California in preparation for 

upcoming harvester meetings in Redding and Stockton. 

March 25, 

2005 

Harvesters who 

reside in Redding, 

CA 

Met within the community to discuss harvesters 

concerns and to share information on the upcoming 

harvest season. 

March 26, 

2005 

Harvesters who 

reside in Stockton, 

CA 

Met within the community to discuss harvesters 

concerns and to share information on the upcoming 

harvest season. 

April 1, 2005 

Readers of the Notice 

of Intent published in 

the Federal Register 

Modified proposed action. Also posted on the 

Deschutes National Forest website and mailed 

approximately 100 letters to those who have expressed 

interest in the project. 

July 14, 2005 

Alliance of Forest 

Workers and 

Harvesters – Susan 

Chapp and Denise 

Smith 

Medford, Oregon – Met to strategize for the upcoming 

season and provide material for picking units to monitor 

for biophysical monitoring by the Alliance. 

August 19, 

2005 

Sierra Institute – 

Katie Bagby 

Mt. Shasta, California – Coordination for Title III 

mushroom monitoring and to discuss current agreements 

for upcoming season. 

October 7, 

2005 

Alliance of Forest 

Harvesters 

At mushroom camp to discuss specifics on biophysical 

monitoring for the BLT project. 
Environmental Impact Statement BLT Project 

 Chapter 2 

13

Date Stakeholder Format/Information 

October 11, 

2005 

Alliance of Forest 

Harvesters, 

mushroom monitors 

and Dr. Anna Tsing 

At mushroom camp to discuss possible locations of plots 

for biophysical monitoring, feedback on BLT 

Alternative C, discussion and concern over 

implementation of timber sales that affect potential 

matsutake habitat, and mushroom harvester concerns 

over this year’s program. 

August 8, 

2006 

Alliance of Forest 

Harvesters 

Preseason meeting at Toketee, Oregon, to discuss 

upcoming season. 

August 13, 

2007 

Alliance of Forest 

Harvesters 

Winema, Umpqua, 

and Deschutes 

National Forest 

Special Use Permit 

Program 

Administrators 

Multi-forest preseason meeting with representatives of 

the Alliance of Forest Harvesters to discuss law 

enforcement policy, monitoring, and the status of the 

BLT project. 

October 9, 

2007 

Harvesters at the 

Little Odell 

mushroom camp 

Harvester meeting hosted by the Alliance of Forest 

Harvesters to listen to harvesters concerns over logging 

in matsutake habitat. 

October 10, 

2007 

Alliance of Forest 

Harvesters at the 

Crescent Ranger 

District 

In depth discussion regarding collaboration, BLT and 

the planning timelines. Provided harvesters maps that 

display how the Crescent Ranger District has responded 

to their input. 

March 29, 

2008 

Teleconference with 

harvesters that reside 

in Stockton, Ca. 

General update for upcoming season and brought 

harvesters up to date on the BLT timeline. 

Using the comments from the stakeholders, the interdisciplinary team developed a list of issues to 

address. 

Consultation with the Tribes 

During the early stages of this project, government to government contact was made with affected 

tribes (Klamath, Confederated Tribes of Warm Springs, and Burns-Paiute). 

Consultation with Government Agencies 

Informal consultation and correspondence has occurred with the US Fish and Wildlife Service and the 

Environmental Protection Agency. 

Issues______________________________________________ 

Issues are points of discussion, debate, or dispute about environmental effects or competing uses of the 

resources that may occur as a result of the proposed action. Issues provide focus and influence 

alternative development, including development of mitigation measures to address potential 

environmental effects, particularly potential negative effects. Issues are also used to display differing 

effects between the proposed action and the alternatives regarding a specific resource element. 

The project Interdisciplinary Team sorted the comments received during initial scoping into categories 

to help issue tracking and response. The issues are categorized as follows: 
BLT Project Environmental Impact Statement 

Chapter 2 

14

• Key issues: These are issues that cannot be resolved without some consideration of the tradeoffs involved and so are used to develop alternatives and design elements. Trade-offs can be 

more clearly understood by developing alternatives and displaying the relative effects of these 

alternatives. 

• Resources of Concern: Are those resource values that are thought would be affected and 

desired to be considered in the analysis and decision. If issues were not used to develop 

alternatives and design elements, they relate to environmental components that are considered 

in the analysis in Chapter 3. These are important for providing the Responsible Official with 

complete information about the effects of the project. 

Key Issues

The alternatives respond to the following key issues identified during initial project scoping. The key 

issues are specific to the proposed actions and the analysis area. Each issue contains a common 

attribute and measure of an environmental factor that can help evaluate how each of the alternatives 

address issues. Evaluations of each attribute and measure are provided later in this Chapter in the 

Comparison of Alternatives section. 

Key Issue #1: The potential effects of active management on selected Deschutes National Forest 

Wildlife Management Indicator Species and their habitat could alter effectiveness of habitat. 

The BLT project proposes to limit large scale loss of forest to uncharacteristically severe insect, 

disease, and wildfire events within the 80,072 acre planning area. The proposal would use silvicultural 

techniques and prescribed underburning to maintain and encourage the development of late- and oldforest structural stand characteristics plus improve forest health. However, the intensity of the 

treatments, their timing, and their placement on the landscape has the potential to change up to 12 

percent of nesting habitat for some species. The Deschutes Forest Plan designated a group of individual 

wildlife species and/or guilds of species as management indicator species (MIS) because their welfare 

could be used as an indicator of other species dependent upon similar habitat conditions. 

Project activities would primarily focus on understory tree thinning and result in a reduction of stem 

density and overall canopy cover within activity units. As a result, the quality, effectiveness, and 

distribution of avian wildlife habitat available to some management indicator species in the planning 

area may be altered. Because MIS species are potentially affected differently by various aspects of 

vegetation management, three species were selected to measure effects for this issue and for the 

purposes of alternative development. Reynolds (1995) stated preferred nest stands for northern 

goshawks have a minimum 40 percent canopy cover and nests sites within those stands have greater 

than 60 percent canopy cover. For the three-toed and black-backed woodpeckers, neither species 

prefers to roost in logged forests (Goggans et al. 1989). For these reasons and because active 

management to reduce risk of a wide-scale disturbance has potential to affect certain aspects of habitat 

for these species, the northern goshawk, 3-toed woodpecker and black-backed woodpecker were 

selected for this Key Issue analysis. Disclosure of effects to the remaining MIS species is discussed in 

Chapter 3 of the FEIS. 

The following attributes and measures are designed to display expected changes in habitat conditions 

for the northern goshawk, black-backed woodpecker, and the three-toed woodpecker: 

• The amount of northern goshawk nesting habitat affected by project activities and expected use 

of activity units post-harvest. 

• The amount of black-backed woodpecker nesting habitat impacted by project activities and 

expected use of activity units post-harvest. 

• The amount of three-toed woodpecker nesting habitat impacted by project activities and 

expected use of activity units post-harvest. 
Environmental Impact Statement BLT Project 

 Chapter 2 

15

Key Issue #2. The potential effects of active management could reduce mushroom production in the 

short-term. 

The analysis area includes important harvesting areas for matsutake, although many acres of canopy 

closure across the BLT landscape are not at sustainable levels and at risk to wide-scale disturbances. 

Vegetation management and fuels treatments have the potential to affect matsutake growing conditions 

in the short-term by changing micro-climates as tree canopies are reduced below optimal conditions. 

Canopies closed more than 70 percent or less than 40 percent may not be optimal for matsutake 

production because of below ground competition with other mycorrhizal species (Hosford et al., 1997; 

Luoma et al., 2004; Luoma and Eberhart, 2005). Also, soil biota important for mushroom production 

uses a complex symbiotic relationship in an environment that does not tolerate soil disturbance related 

to the use of equipment. 

Some research has shown that the optimal canopy cover may be 50-90 percent, although site-specific 

surveys in the analysis area have shown matsutake presence (or a surrogate Allotropa virgata) in 

canopies as open as 25 percent, in some plant association groups. 

The degree to which each alternative addresses Key Issue #2 will be measured using the following 

attributes: 

• Total acres of detrimental soil conditions following active management by alternative 

• Acres of change from closed to open canopy 

• Acres changed from to a more sustainable condition 

 

Analysis Issues

Other issues and concerns for various resource areas were raised during scoping that did not result in 

different alternatives or design elements, but are considered during the analysis process and discussed 

in Chapter 3. 

Soil Quality 

Wildlife 

• Threatened, Endangered, Candidate and Sensitive Species 

• Management Indicator Species 

• Resident and Migratory Landbirds 

Water Quality and Fish Habitat 

Botany 

• Threatened, Endangered, Candidate, and Sensitive plant species 

• Invasive plants 

Cultural Resources 

Old Growth management 

Recreation 

Social and Economic 

Scenery and Wild and Scenic River 

Oregon Cascades Recreation Area (OCRA) 
BLT Project Environmental Impact Statement 

Chapter 2 

16

Alternatives Considered in Detail _______________________ 

The Forest Service developed two alternatives to the Proposed Action, for a total of four alternatives, 

including the No Action. The No Action Alternative is used as a baseline to display consequences of a 

passive management scenario. Boundaries shown for active management alternatives are approximate 

and would be located to match site-specific conditions. No harvest activities would occur in Riparian 

Reserves or Riparian Habitat Conservation Areas. 

All action alternatives have only one non-mechanical activity within riparian resources (Unit #1061) 

and it would thin lodgepole pine less than 6 inches diameter and spot burn some patches of willow that 

are decadent and to rejuvenate them. No other activity, such as burning of handpiles, or prescribed 

burning within 10 meters of permanently wetted areas, would occur. 

No activities would occur within the boundary of the Oregon Cascades Recreation Area (OCRA). 

There are no harvest units within the Eastside Screen boundary that would cut trees greater than or 

equal to 21 inches. For a listing of these units, reference the Project Design Criteria in this Chapter. 

Also, for those units within the Northwest Forest Plan boundary and within the Wild and Scenic River 

corridor, the Little Deschutes Wild and Scenic River Plan has adopted visual quality guidelines and 

limits harvest of trees (24 inches in diameter) or greater unless they meet the specific criteria listed on 

page 4-123 of the Forest Plan in Retention and Partial Retention. 

The action alternatives include two basic prescriptions: Commercial Thinning (HTH) and Improvement 

Cut (HIM). For a visual description of these, reference Figures 3-8 and 3-10, in the Forested 

Vegetation Section in Chapter 3. Basically, for the prescription code of HTH, trees would be thinned to 

a density within the management zone with thought to future growth within the 20 or 30 years before 

the next likely treatment. This would primarily be achieved by thinning from below – the removal of 

trees from the lower crown classes to favor those in the upper crown classes (Helms 1998). After 

thinning, stands will average as low as 20 percent canopy cover and 50 square feet of basal area in 

lodgepole and up to 40 percent canopy cover and 180 square feet of basal area in mixed conifer plant 

associations. 

For the prescription code HIM, improvement cuts are similar to commercial thinning prescriptions, 

however the stand does not have the same level of trees to retain as in a healthier stand. It is not a 

regeneration cut. Stands prescribed for HIM are primarily lodgepole pine impacted by the mountain 

pine beetle outbreak of the 1980s. The proportion of their overstories exhibit poor crowns and/or heavy 

mistletoe infection (generally greater than 1/3 of crown volume in mistletoe brooms) would be 

removed. These trees have poor growth rates and potential for infecting the understory with mistletoe 

is high. Because of the lack of a healthy overstory, the understory would contribute considerably to 

future growth. 

All wildlife connectivity corridors have been identified and mapped for all action alternatives. 

Corridors do not necessarily meet the same description of “suitable” habitat for breeding, but allow free 

movement between suitable breeding habitats. It is important to insure that blocks of habitat maintain a 

high degree of connectivity between them and that blocks of habitat do not become fragmented in the 

short-term. Connectivity corridors are considered stands in which medium to larger trees are common, 

and canopy cover are within the top-third of site potential. Stand widths should be at least 400 feet 

wide at their narrowest point, unless it is impossible to meet the 400 feet with current vegetative 

conditions. If stands meeting these descriptions are not available, the next best available habitat would 

be identified. Site-specific field reconnaissance would be performed by a wildlife biologist, 

silviculturist, and fuels specialist to determine appropriate treatments and to maintain consistency with 
Environmental Impact Statement BLT Project 

 Chapter 2 

17

Regional Forester’s Amendment #2 Eastside Screens and Figure 3-25. For details, reference 

Connectivity and Fragmentation in the Wildlife section, Chapter 3. 

Alternative A 

No Action 

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

analysis. Management actions otherwise authorized would not be affected. For a detailed description 

of these management actions, reference Chapter 3. 

Alternative B 

The Proposed Action

The Proposed Action includes a variety of vegetation management activities across approximately 

7,499 acres, and would harvest approximately 12.1 million board feet of timber. Stands that were 

identified as too dense and competing for limited site resources, and those that need immediate or longterm reduction of hazardous fuel conditions were prioritized for active management. 

Activities would reduce risk from a large disturbance (particularly from insects and wildfire) on 7,499 

acres and change stands to a more sustainable condition. However, it would reduce potential nesting 

habitat for some Management Indicator Species by 12 percent and potentially reduce short-tern 

mushroom production on 1,454 acres. Refer to Figure 2-1 for locations of Alternative B units and 

Table 2-2 for site-specific prescriptions. Activities to improve forest health and reduce risk on the 

landscape include: 

• Improvement cutting, primarily in lodgepole pine, to enhance overall stand composition and 

health (HIM, 3,614 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 3,550 acres); 

• Small diameter thinning and fuels reduction outside timber harvest units on 413 acres; 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 2,312 

acres; and 

• Opportunity for utilization of forest products such as posts and poles and firewood on 3,093 

acres. 

Connected Actions

In order for Alternative B to be implemented, the following are connected actions2

: 

• About 22 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 160 miles of 

Maintenance Level 1 and 2 roads. Danger trees would be felled and retained on site. 

• About 9.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. Units for which 

temporary road construction would be needed: 15, 30, 115, 125, 200, 310, 350, 530, 570, 595, 

615, 625, 785, 815, 856, 865, 1085, 1130, 1135, 1200, and 1300. 

 

2

 Refer to the Transportation System section in Chapter 3 of this document for descriptions and definitions of 

these activities. 
BLT Project Environmental Impact Statement 

Chapter 2 

18

Table 2-2. Alternative B Active Management Units 

Unit Acres Silv Rx3 System4 Fuels RX5 Management6

OG/WSR 

Acres 

15 71 HIM Tractor GP GF No 

30 47 HTH Tractor GP, SFP GF No 

45 49 Fuels Fuels SDT, PR, SFP GF No 

55 43 HIM Tractor GP, SFP GF No 

65 165 HTH Tractor GP, UB, SFP GF No 

80 90 Fuels SDT, SFP, PR GF No 

90 13 HTH Tractor GP GF No 

100 32 HIM Tractor GP GF No 

115 151 Fuels SDT, PR, SFP GF No 

125 86 HIM Tractor GP GF, MAT No 

130 9 HTH Tractor GP GF No 

135 103 HIM Tractor GP, SFP GF No 

150 104 HIM Tractor GP GF No 

155 55 HTH Tractor GP, SFP GF No 

165 46 HTH Tractor GP, SFP GF No 

170 13 HTH Tractor GP, UB GF No 

175 219 HTH Tractor GP, UB, SFP GF No 

185 18 HIM Tractor GP GF No 

195 37 HTH Advanced HP GF, MAT No 

200 241 HIM Tractor GP, SFP GF, SV, MAT No 

210 36 HTH Tractor GP, UB, SFP GF, SV, MAT No 

245 28 HTH Tractor GP GF, MAT No 

260 8 HTH Tractor GP GF, SV No 

265 67 HTH Tractor GP, SFP GF, OG OG 46 ac. 

270 67 HTH Tractor GP, SFP SV No 

285 78 HTH Tractor GP GF, SV No 

290 6 HIM Tractor GP GF, MAT No 

295 13 HIM Tractor GP, SFP GF No 

300 52 HTH Tractor GP, UB, SFP GF, MAT No 

310 207 HTH Tractor GP,UB GF, OG OG 154 ac. 

311 5 HTH Tractor GP GF, OG OG 2 ac. 

312 11 HTH Tractor GP OG OG 11 ac. 

315 18 HTH Tractor GP GF, MAT No 

316 7 HTH Tractor GP GF, MAT No 

317 6 HTH Tractor GP GF, MAT No 

320 13 HTH Tractor GP GF, MAT 

335 51 HTH Tractor GP GF, SV 

340 23 HTH Advanced HP GF, OG, MAT OG 1 ac. 

 

3

 HIM = Harvest Improvement Cut, HTH = Commercial Thin, Fuels = Fuels activities without a commercial 

timber sale 

4

 Tractor = ground-based harvest system, Advanced = low impact system, typically skyline or helicopter-based 

harvest 

5

 GP = grapple pile, SFD = opportunity to utilize special forest products such as post and pole, SDT = small 

diameter thin, PR = pruning, UB = prescribed underburning 

6

 GF = General Forest, MAT = Matrix, OG = Old Growth, SV = Scenic Views, WSR = Wild and Scenic River, 

CWD = Congressionally Withdrawn areas only overlay Wild and Scenic Rivers, not Wilderness. 
Environmental Impact Statement BLT Project 

 Chapter 2 

19

Unit Acres Silv Rx3 System4 Fuels RX5 Management6

OG/WSR 

Acres 

350 138 HIM Tractor GP, SFP GF, SV No 

355 12 HIM Tractor GP GF No 

405 84 HIM Tractor GP, SFP GF No 

410 8 HTH Tractor GP, SFP GF, MAT No 

420 231 HTH Tractor GP, UB GF No 

435 79 HIM Tractor HP, PR, SFP GF, SV No 

455 6 HTH Tractor GP SV No 

460 52 HTH Tractor GP, SFP GF, MAT No 

465 24 HTH Tractor GP GF, SV No 

480 17 HTH Tractor GP GF No 

485 46 HTH Tractor GP, UB GF No 

505 43 HTH Tractor GP, UB GF No 

516 7 HIM Tractor GP SV No 

517 6 HIM Tractor GP GF No 

520 92 HIM Tractor GP GF No 

525 94 HIM Tractor GP, SFP GF, MAT No 

530 123 HTH Tractor GP, SFP GF No 

535 20 HIM Tractor GP GF No 

540 11 HTH Tractor GP GF No 

560 71 HTH Tractor GP GF No 

561 6 HTH Tractor GP GF No 

570 277 HIM Tractor GP GF No 

575 149 HIM Tractor GP, SFP GF, MAT No 

580 14 HTH Tractor GP GF No 

590 19 HIM Tractor GP GF No 

595 133 HTH Tractor GP, UB GF No 

610 46 HIM Tractor GP, SFP GF No 

615 75 HIM Tractor GP, UB GF No 

616 32 HIM Tractor GP, UB GF No 

620 18 Fuels SDT, PR GF No 

625 50 HIM Tractor GP, UB GF No 

635 189 HIM Tractor GP, SFP GF, MAT No 

640 55 HIM Tractor GP, SFP GF No 

645 6 HIM Tractor GP GF No 

646 8 HIM Tractor GP GF No 

655 39 HTH Tractor GP, UB GF No 

660 96 HTH Tractor GP, UB GF No 

670 39 HTH Tractor GP GF No 

675 30 HTH Advanced HP GF, MAT No 

690 62 HIM Tractor GP, UB, SFP GF No 

705 17 HTH Tractor GP GF No 

725 21 HTH Tractor HP GF, MAT No 

751 12 HIM Tractor GP GF, SV No 

755 134 HIM Tractor GP GF, MAT No 

770 59 HTH Tractor GP GF, OG, MAT OG 6 ac. 

775 40 HTH Tractor GP GF No 

785 188 HIM Tractor GP, UB GF No 
BLT Project Environmental Impact Statement 

Chapter 2 

20

Unit Acres Silv Rx3 System4 Fuels RX5 Management6

OG/WSR 

Acres 

790 11 HTH Tractor GP, UB, SFP GF No 

800 15 HTH Tractor GP, UB SV No 

815 124 HTH Tractor GP, UB GF No 

820 21 HTH Tractor GP, SFP GF No 

835 90 HTH Tractor GP, SFP GF, OG OG 83 ac. 

840 34 HTH Tractor GP GF No 

845 95 HTH Tractor GP, UB GF, OG OG 72 ac. 

855 30 HIM Tractor GP GF, MAT No 

856 31 HIM Tractor GP GF No 

865 50 HIM Tractor GP GF, MAT No 

870 23 HTH Tractor GP GF No 

875 31 HIM Tractor GP, SFP GF No 

900 23 HTH Tractor GP GF, OG OG 13 ac. 

915 55 HTH Tractor GP, UB GF, OG OG 50 ac. 

940 5 Fuels SDT, PR, SFP GF No 

1035 21 HIM Tractor GP GF, MAT No 

1061 22 Fuels UB GF No 

1065 45 HTH Tractor GP GF No 

1070 50 HIM Tractor GP GF No 

1085 24 HIM Tractor GP GF, MAT No 

1100 21 HTH Advanced HP GF, MAT No 

1110 26 HTH Tractor GP GF, MAT No 

1130 115 HIM Tractor GP GF No 

1135 84 HIM Tractor GP GF, MAT No 

1160 30 HTH Tractor GP, SFP GF, MAT No 

1165 11 HTH Tractor GP, SFP GF, MAT No 

1175 47 HIM Tractor GP, SFP GF, MAT No 

1180 41 HIM Tractor GP, SFP GF, MAT No 

1181 22 HIM Tractor GP GF, MAT No 

1185 108 HIM Tractor GP, UB, SFP GF, WSR, MAT WSR 107 ac.

1190 16 HIM Tractor GP, SFP GF No 

1195 39 HTH Tractor GP, SFP GF, WSR WSR 10 ac. 

1200 57 HIM Tractor GP, SFP WSR No 

1205 68 HIM Tractor GP, UB, SFP WSR No 

1210 7 HIM Tractor GP GF, MAT No 

1215 128 HIM Tractor GP, UB WSR WSR 128 ac.

1230 111 HTH Advanced HP GF, MAT No 

1235 31 HIM Tractor GP, SFP GF No 

1240 18 HIM Tractor GP, SFP WSR WSR 18 ac. 

1245 69 HTH Tractor GP GF, WSR WSR 47 ac. 

1246 17 HTH Advanced HP GF, WSR WSR 8 ac. 

1255 46 HTH Tractor GP GF, WSR, MAT, CWD WSR 14 ac. 

1260 172 HTH Advanced HP GF, MAT No 

1265 37 HTH Tractor GP WSR, CWD WSR 37 ac. 

1275 18 HTH Advanced HP GF, MAT No 

1300 48 HIM Tractor GP, SFP WSR, CWD WSR 47 ac. 

1310 11 HTH Advanced HP GF, MAT No 
Environmental Impact Statement BLT Project 

 Chapter 2 

21

Figure 2-1. BLT Project Alternative B T. 24 S. T. 25 S. R. 7 E. R. 8 E. 200 65 175 420 310

785

115

575

755

595

815

530 520

55

570

635

350

1260

80

150

135

15

1215

660

845

525

1130

835

125

1230

1185

405 435

285

615

45

560

30

270

265

1135

770

690

155

640

915

1245

1205

300

460

335

625

165

610

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505

865

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670 655

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1175

1300

210

1255

1065

840

1180

616

100

856

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675

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465

1160

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340

1110

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725

535

90

590

1085

185

315

620

1181

1061

480

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1035

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1240

1275

295 320

1100

1246

170

1190

355

751

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130

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646

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1310

516

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645

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455

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1210

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58

61

5825

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SU 9- 7

6020

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9770

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5825

16 52

I-84

5-I US Hwy 26

State Hwy 31

012 0.5

Miles

jm 6/4/08T:\r06\des\cre\project\eis\eis_blt\workspace\jmonroe\arcmap\

Alternative-B_2_28_08Project BoundaryRailroadState-BLM-County RoadsArterial RoadsCollector Roads

NW Forest PlanALLOCATION

Congressional WithdrawalMatrixOther Ownership

BLT Alternative B

Crescent Ranger District

Deschutes National Forest

This product is reproduced from information prepared bythe USDA, Forest Service or from other suppliers. The ForestService cannot assure the reliability or suitability of thisinformation for a particular purpose. The data and product accuracymay vary due to compilation from various sources, including modelingand interpretation, and may not meet National Map Accuracy Standards.This information may be updated, corrected or otherwise modifiedwithout notification. For more information contact: Deschutes National Forest Supervisors Office at 541-383-5760.The USDA is an equal opportunity provider and employer.Neither the Forest Service, nor any of its employees, makes any warrantyexpressed or implied, including the warranties of merchantability andfitness for a particular purpose, or assumes any legal liability orresponsibility for the accuracy, completeness, or usefulness of anyinformation, apparatus, product or process disclosed, or represents thatits use would not infringe privately owned rights.
BLT Project Environmental Impact Statement 

Chapter 2 

22

Alternative C 

Alternative C includes a variety of vegetation management activities across approximately 5,771 acres, 

and would harvest approximately 9.8 million board feet of timber. This alternative was developed to 

address the needs of wildlife species that favor dense canopies and decadent conditions for some of 

their life requirements. To respond, in the development of this alternative, stands of late and oldstructured lodgepole pine were dropped in comparison with Alternative B (Proposed Action) to provide 

for additional goshawk nesting and three-toed/black-backed woodpecker nesting and roosting habitat. 

All types of actions that occur in this alternative are the same as described for Alternative B. It would 

reduce potential nesting habitat for some Management Indicator Species up to 3 percent less than 

Alternative B and would reduce short-term mushroom production on 1,054 acres (450 acres less than 

Alternative B). Approximately 5,771 acres would be changed to a more sustainable condition. Refer to 

Figure 2-3 for locations of Alternative C units. Management activities would include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition and 

health (HIM, 2,672 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 2,765 acres); 

• Small diameter thinning and fuels reduction on 334 acres; 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 1,764 

acres; and 

• Opportunity for utilization of forest products such as posts and poles and firewood on 2,304 

acres. 

Connected Actions

In order for Alternative C to be implemented, the following are connected actions: 

• About 17 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 126 miles of 

Maintenance Level 1 and 2 roads. 

• About 8.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. Units where 

temporary road construction is needed: 115, 125, 200, 350, 530, 570, 615, 625, 785, 815, 856, 

865, 1100, and 1135. 

See Table 2-2 for definitions in Table 2-3. 

Table 2-3. Alternative C Management Units 

Unit Acres Silv Rx System Fuels RX Mgmt OG/WSR 

Acres 

45 49 Fuels SDT, PR, SFP GF No 

65 165 HTH Tractor GP, UB, SFP GF No 

80 90 Fuels SDT, SFP, PR GF No 

115 151 Fuels SDT, PR, SFP GF No 

125 86 HIM Tractor GP GF, MAT No 

135 103 HIM Tractor GP, SFP GF No 

150 104 HIM Tractor GP GF No 

155 55 HTH Tractor GP, SFP GF No 

165 46 HTH Tractor GP, SFP GF No 

170 13 HTH Tractor GP, UB GF No 

175 219 HTH Tractor GP, UB, SFP GF No 

185 18 HIM Tractor GP GF No 
Environmental Impact Statement BLT Project 

 Chapter 2 

23

Unit Acres Silv Rx System Fuels RX Mgmt OG/WSR 

Acres 

195 37 HTH Advanced HP GF, MAT No 

200 241 HIM Tractor GP, SFP GF, SV, MAT No 

210 36 HTH Tractor GP, UB, SFP GF, SV, MAT No 

245 28 HTH Tractor GP GF, MAT No 

260 8 HTH Tractor GP GF, SV No 

265 67 HTH Tractor GP, SFP GF, OG OG 46 ac. 

270 67 HTH Tractor GP, SFP SV No 

290 6 HIM Tractor GP GF, MAT No 

300 52 HTH Tractor GP, UB, SFP GF, MAT No 

315 18 HTH Tractor GP GF, MAT No 

316 7 HTH Tractor GP GF, MAT No 

317 6 HTH Tractor GP GF, MAT No 

320 13 HTH Tractor GP GF, MAT No 

335 51 HTH Tractor GP GF, SV No 

340 23 HTH Advanced HP GF, OG, MAT OG 1 ac. 

350 138 HIM Tractor GP, SFP GF, SV No 

355 12 HIM Tractor GP GF No 

420 231 HTH Tractor GP, UB GF No 

455 6 HTH Tractor GP SV No 

465 24 HTH Tractor GP GF, SV No 

485 46 HTH Tractor GP, UB GF No 

505 43 HTH Tractor GP, UB GF No 

520 92 HIM Tractor GP GF No 

525 94 HIM Tractor GP, SFP GF, MAT No 

530 123 HTH Tractor GP, SFP GF No 

535 20 HIM Tractor GP GF No 

560 71 HTH Tractor GP GF No 

570 277 HIM Tractor GP, SFP GF No 

580 14 HTH Tractor GP GF No 

590 19 HIM Tractor GP GF No 

610 46 HIM Tractor GP, SFP GF No 

615 75 HIM Tractor GP, UB GF No 

616 32 HIM Tractor GP, UB GF No 

620 18 Fuels Fuels SDT, PR GF No 

625 50 HIM Tractor GP, UB GF No 

635 189 HIM Tractor GP, SFP GF, MAT No 

640 55 HIM Tractor GP, SFP GF No 

645 6 HIM Tractor GP GF No 

646 8 HIM Tractor GP GF No 

660 96 HTH Tractor GP, UB GF No 

670 39 HTH Tractor GP GF No 

725 21 HTH Tractor HP GF, MAT No 

751 12 HIM Tractor GP GF, SV No 

755 134 HIM Tractor GP GF, MAT No 

775 40 HTH Tractor GP GF No 

785 188 HIM Tractor GP, UB GF No 

790 11 HTH Tractor GP, UB, SFP GF No 
BLT Project Environmental Impact Statement 

Chapter 2 

24

Unit Acres Silv Rx System Fuels RX Mgmt OG/WSR 

Acres 

800 15 HTH Tractor GP, UB SV No 

815 124 HTH Tractor GP, UB GF No 

835 90 HTH Tractor GP, SFP GF, OG OG 83 ac. 

840 34 HTH Tractor GP GF No 

845 95 HTH Tractor GP, UB GF, OG OG 72 ac. 

855 30 HIM Tractor GP GF, MAT No 

856 31 HIM Tractor GP GF No 

865 50 HIM Tractor GP GF, MAT No 

875 31 HIM Tractor GP, SFP GF No 

900 23 HTH Tractor GP GF, OG OG 13 ac. 

915 55 HTH Tractor GP, UB GF, OG OG 50 ac. 

940 5 Fuels SDT, HP, SFP, PR GF No 

1035 21 HIM Tractor GP GF, MAT No 

1061 22 Fuels UB, PR GF No 

1065 45 HTH Tractor GP GF No 

1085 24 HIM Tractor GP GF, MAT No 

1100 21 HTH Advanced HP GF, MAT No 

1110 26 HTH Tractor GP GF, MAT No 

1135 84 HIM Tractor GP GF, MAT No 

1160 30 HTH Tractor GP, SFP GF, MAT No 

1165 11 HTH Tractor GP, SFP GF, MAT No 

1175 47 HIM Tractor GP, SFP GF, MAT No 

1180 41 HIM Tractor GP, SFP GF, MAT No 

1181 22 HIM Tractor GP GF, MAT No 

1190 16 HIM Tractor GP, SFP GF No 

1195 39 HTH Tractor GP, SFP GF, WSR WSR 10 ac. 

1205 68 HIM Tractor GP, UB, SFP WSR No 

1210 7 HIM Tractor GP GF, MAT No 

1215 128 HIM Tractor GP, UB WSR No 

1230 111 HTH Advanced HP GF, MAT WSR 128 ac. 

1235 31 HIM Tractor GP, SFP GF No 

1245 69 HTH Tractor GP GF, WSR WSR 47 ac. 

1246 17 HTH Advanced HP GF, WSR WSR 8 ac. 

1255 46 HTH Tractor GP GF, WSR, 

MAT, CWD 

WSR 14 ac. 

1260 172 HTH Advanced HP GF No 

1265 37 HTH Tractor GP WSR, CWD WSR 37 ac. 

1275 18 HTH Advanced HP GF, MAT No 

1310 11 HTH Advanced HP GF, MAT No 
Environmental Impact Statement BLT Project 

 Chapter 2 

25

Figure 2-2. BLT Project Alternative C T. 24 S. R. 7 E. R. 8 E. 200 65 175 420

785

115

755

815

530 520

570

635

350

1260

80

150

135

1215

660

845

525

835

125

1230

615

45

560

270

265

1135

155

640

915

1245

1205

300

335

625

165

610

485 505

865

775

670

195

1175

210

1255

1065

840

1180

616

856

1195

855

1265

245

465

1160

1235

900

340

1110

725

535

590

1085

185

315

620

1061

1035

800

580

1275

320

1100

1246

170

875

1190

355

751

790

1165

646

260

1310

316

645

290

317

455

1210

940

58

61

5825

5834

5830

5216

SU 9- 7

6020

5828

5815

5835

9770

5820

9758

9768

5825

5216

I-84

5-I

US Hwy 26

State Hwy 31

012 0.5

Miles

jm 6/12/08T:\r06\des\cre\project\eis\eis_blt\workspace\jmonroe\arcmap\

Alternative_C_2_28_08Project BoundaryRailroadState-BLM-County RoadsArterial RoadsCollector Roads

NW Forest PlanALLOCATION

Congressional WithdrawalMatrixOther Ownership

BLT Alternative C

Crescent Ranger District

Deschutes National Forest

This product is reproduced from information prepared bythe USDA, Forest Service or from other suppliers. The ForestService cannot assure the reliability or suitability of thisinformation for a particular purpose. The data and product accuracymay vary due to compilation from various sources, including modelingand interpretation, and may not meet National Map Accuracy Standards.This information may be updated, corrected or otherwise modifiedwithout notification. For more information contact: Deschutes National Forest Supervisors Office at 541-383-5760.The USDA is an equal opportunity provider and employer.Neither the Forest Service, nor any of its employees, makes any warrantyexpressed or implied, including the warranties of merchantability andfitness for a particular purpose, or assumes any legal liability orresponsibility for the accuracy, completeness, or usefulness of anyinformation, apparatus, product or process disclosed, or represents thatits use would not infringe privately owned rights.
BLT Project Environmental Impact Statement 

Chapter 2 

26

Alternative D 

The Proposed Action includes a variety of vegetation management activities across approximately 

2,616 acres, and would harvest approximately 5.2 million board feet of timber. This alternative focuses 

on the short-term production and harvest of matsutake mushrooms by excluding active management in 

the most productive matsutake areas, primarily west of Highway 58. All types of actions that occur in 

this alternative are the same as described for Alternative B. It would potentially reduce short-term 

mushroom production on 468 acres and change up to 4 percent nesting habitat for some Management 

Indicator Species. Also, it would change 2,616 acres of forest to a more sustainable condition. Refer to 

Figure 2-3 for locations of Alternative D units. Management activities would include: 

• Improvement cutting primarily in lodgepole pine to enhance overall stand composition and 

health (HIM, 1,323 acres); 

• Thinning from below to favor the larger trees with healthy foliage (HTH, 981 acres); 

• Small diameter thinning and fuels reduction on 312 acres; and 

• Application of prescribed fire to maintain or enhance fire-dependent ecosystems on 824 acres; 

and 

• Opportunity for forest products such as post and poles and firewood on 1,064 acres. 

Connected Actions

In order for Alternative D to be implemented, the following are connected actions: 

• About 11 miles of currently closed Maintenance Level 1 roads would be opened to allow 

timber hauling and other activities. Roads would be closed following implementation. 

• Road maintenance, especially blading and brushing, would be performed on about 76 miles of 

Maintenance Level 1 and 2 roads. 

• About 4.7 miles of temporary roads would be constructed to facilitate economical timber 

harvest removal. These would be obliterated following implementation and restored to a 

condition that is hydrologically functional and able to revegetate more quickly. Units where 

temporary road construction is needed: 15, 30, 125, 135, 200, and 615. 

Table 2-4. Alternative D Management Units 

Unit Acres Veg Rx System Fuels RX Mgmt 

OG/WSR 

Acres 

15 71 HIM Tractor GP GF No 

30 47 HTH Tractor GP, SFP GF No 

45 49 Fuels SDT, PR, HP, SFP GF No 

80 90 Fuels SDT, SFP, PR GF No 

115 151 Fuels SDT, HP, SFP, PR GF No 

125 86 HIM Tractor GP GF, MAT No 

135 103 HIM Tractor GP, SFP GF No 

170 13 HTH Tractor GP, UB GF No 

195 37 HTH Advanced HP GF, MAT No 

200 241 HIM Tractor GP, SFP GF, SV, MAT No 

260 8 HTH Tractor GP GF, SV No 

265 67 HTH Tractor GP, SFP GF, OG OG 46 ac. 

270 67 HTH Tractor GP, SFP SV No 

295 13 HIM Tractor GP, SFP GF No 

300 52 HTH Tractor GP, UB, SFP GF, MAT No 

315 18 HTH Tractor GP GF, MAT No 

316 7 HTH Tractor GP GF, MAT No 

317 6 HTH Tractor GP GF, MAT No 

335 51 HTH Tractor GP GF, SV No 
Environmental Impact Statement BLT Project 

 Chapter 2 

27

Unit Acres Veg Rx System Fuels RX Mgmt 

OG/WSR 

Acres 

340 23 HTH Advanced HP GF, OG, MAT OG 1 ac. 

355 12 HIM Tractor GP GF No 

410 8 HTH Tractor GP, SFP GF, MAT No 

455 6 HTH Tractor GP SV No 

480 17 HTH Tractor GP GF No 

520 92 HIM Tractor GP GF No 

525 94 HIM Tractor GP, SFP GF, MAT No 

540 11 HTH Tractor GP GF No 

580 14 HTH Tractor GP GF No 

610 46 HIM Tractor GP, SFP GF No 

615 75 HIM Tractor GP, UB GF No 

616 32 HIM Tractor GP, UB GF No 

645 6 HIM Tractor GP GF No 

646 8 HIM Tractor GP GF No 

725 21 HTH Tractor HP GF, MAT No 

751 12 HIM Tractor GP GF, SV No 

785 188 HIM Tractor GP, UB GF No 

790 11 HTH Tractor GP, UB, SFP GF No 

800 15 HTH Tractor GP, UB SV No 

815 124 HTH Tractor GP, UB GF No 

820 21 HTH Tractor GP, SFP GF No 

840 34 HTH Tractor GP GF No 

845 95 HTH Tractor GP, UB GF, OG OG 72 ac. 

1061 22 Fuels UB, PR GF No 

1195 39 HTH Tractor GP, SFP GF, WSR WSR 107 ac. 

1205 68 HIM Tractor GP, UB, SFP WSR WSR 10 ac. 

1215 128 HIM Tractor GP, UB WSR WSR 128 ac. 

1245 69 HTH Tractor GP GF, WSR WSR 47 ac. 

1246 17 HTH Advanced HP GF, WSR WSR 8 ac. 

1255 46 HTH Tractor GP GF, WSR, 

MAT, CWD 

No 

1265 37 HTH Tractor GP WSR, CWD WSR 37 ac. 

1300 48 HIM Tractor GP, SFP WSR, CWD WSR 47 ac. 
BLT Project Environmental Impact Statement 

Chapter 2 

28

T. 24 S.

T. 25 S.

R. 7 E. R. 8 E.

58

61

5825

5834

5830

5216

SU 9- 7

6020

5828

5815

5385

9770

5820

9758

9768

16 52

5825

200

785

115

520

80

815

135

15

845

525

1215

125

45

30

265

270

615

1245

300

1205

335

610

195

1300

1255

840

616

1195

1265

340

820

725

315

480

1061

800

580

295

170

355

751

540

790

410

646

260

316

645

1246

455

317

I-84

5-I US Hwy 26

State Hwy 31

012 0.5

Miles

jm 6/12/08T:\r06\des\cre\project\eis\eis_blt\workspace\jmonroe\arcmap\

Alternative_D_2_28_08Project BoundaryRailroadState-BLM-County RoadsArterial RoadsCollector Roads

NW Forest PlanALLOCATION

Congressional WithdrawalMatrixOther Ownership

BLT Alternative D

Crescent Ranger District

Deschutes National Forest

This product is reproduced from information prepared bythe USDA, Forest Service or from other suppliers. The ForestService cannot assure the reliability or suitability of thisinformation for a particular purpose. The data and product accuracymay vary due to compilation from various sources, including modelingand interpretation, and may not meet National Map Accuracy Standards.This information may be updated, corrected or otherwise modifiedwithout notification. For more information contact: Deschutes National Forest Supervisors Office at 541-383-5760.The USDA is an equal opportunity provider and employer.Neither the Forest Service, nor any of its employees, makes any warrantyexpressed or implied, including the warranties of merchantability andfitness for a particular purpose, or assumes any legal liability orresponsibility for the accuracy, completeness, or usefulness of anyinformation, apparatus, product or process disclosed, or represents thatits use would not infringe privately owned rights.

Figure 2-3. BLT Project Alternative D 

Resource Protection Measures _________________________ 
Environmental Impact Statement BLT Project 

 Chapter 2 

29

Project Design Features Common to All Action Alternatives 

The following features are incorporated into the design of all activities included in the BLT project. 

The difference between these design features and mitigation measures is that these are considered 

routine, have been used on numerous similar projects, and are either incorporated into contract 

provisions or accomplished between appropriate resource specialists, and have proven to be effective. 

Mitigation measures are site-specific, usually have a specific unit(s) assigned to them, and are used to 

avoid, minimize, rectify, reduce, or compensate an impact (40 CFR 1508.20). For example, a Project 

Design Feature may include a seasonal closure for an unknown nest site (if discovered); a mitigation 

measure would place a seasonal closure on a known nest site specific to a unit. Project Design Features 

and mitigation measures are used as a basis for determining and disclosing effects in the Environmental 

Consequences discussions. 

Vegetation Management 

Commercial Harvest and Improvement Cuts: Commercial material would be thinned and removed 

using harvest methods that ensure soil productivity and minimal damage to residual trees. Since the 

commercial market fluctuates widely, a precise division between small tree and commercial 

products is not defined within this document. Implementation of this project would utilize the 

smallest materials the commercial market will bear at the time of implementation. For removal of 

these special forest products, a conservative estimate for additional soil disturbance was factored in; 

however existing skid trails and disturbed areas would be utilized where feasible. No additional 

temporary roads would be created. Commercial thinning prescriptions of all sized conifer trees is 

to be done in such a way that: 

• The diversity of species on the site is retained, though the proportion of one species over 

another may change considerably. Generally, the preference for conifer species to retain is 

(from highest to lowest): Douglas-fir, sugar pine, western white pine, Shasta red fir, mountain 

hemlock, ponderosa pine, white fir/grand fir, and lodgepole pine. These preferences may vary 

on specific sites depending on the abundance of a given species, presence of pathogens, 

vegetative potential, and/or site-specific objectives. 

• In all management areas, the intent is to retain the largest of the large trees across the 

landscape. 

• Structural diversity will be clearly maintained on the landscape, but may not be very diverse in 

a given activity unit. This means some individual areas may be single-storied, others twostoried, and still others with more canopy layers. 

• Areas within the Northwest Forest Plan boundary and with an excess of basal area in large trees 

(generally over 21 inches in diameter) may need to have some of those trees removed to meet 

biological objectives. If so, trees to remove should be selected in such a way that: 

• They do not have the crown or the physiological characteristics to be able to respond to 

thinning. 

• They have numerous other larger suitable trees nearby that can remain to meet longterm objectives. 

• They do not appear on the verge of imminent mortality so as to contribute to snag 

densities, if needed as indicated by the marking guide/prescription. 

• Trees of high value to wildlife should remain on site. Examples include, but are not 

limited to, true fir with conks that would indicate a future hollow log, non-lodgepole 

trees with multiple tops, trees with very large limbs, etc. 
BLT Project Environmental Impact Statement 

Chapter 2 

30

Maintain all remnant late and old seral and/or structural live trees greater than or equal to 21 inches 

in diameter (Eastside Screens, Scenario A, 2(a)) in the following units: 

Alternative B: 15, 30, 45, 55, 65, 80, 90, 100, 115, 130, 150, 155, 165, 170, 175, 185, 260, 

265, 270, 285, 290, 295, 310, 311, 312, 335, 350, 355, 405, 420, 435, 455, 465, 480, 485, 505, 

516, 517, 520, 530, 535, 540, 560, 561, 570, 580, 590, 595, 610, 615, 616, 620, 625, 640, 645, 

646, 655, 660, 670, 690, 705, 751, 775, 785, 790, 800, 815, 820, 835, 840, 845, 856, 870, 875, 

915, 940, 1061, 1065, 1070, 1130, 1185, 1190, 1195, 1200, 1205, 1215, 1240, 1245 and 1246. 

Alternative C: 45, 65, 80, 115, 150, 155, 165, 170, 175, 185, 260, 265, 270, 290, 335, 350, 

355, 420, 455, 465, 485, 505, 520, 530, 535, 560, 570, 580, 590, 610, 615, 616, 620, 625, 640, 

645, 646, 655, 660, 670, 690, 705, 751, 775, 785, 790, 800, 815, 820, 835, 840, 845, 856, 875, 

915, 940, 1061, 1065, 1190, 1195, 1205, 1215, 1245, 1246. 

Alternative D: 15, 30, 45, 80, 115, 170, 260, 265, 270, 295, 335, 355, 455, 480, 520, 540, 580, 

610, 615, 616, 645, 646, 751, 785, 790, 800, 815, 820, 840, 845, 1061, 1195, 1205, 1215, 1245, 

1246. 

Soil and Water Quality 

• All fish bearing streams would have no-harvest buffers of two standard tree heights site 

potential (minimum of 300 feet). Non-fish bearing streams and ephemeral streams would have 

one standard tree height or 150 feet no-harvest buffer placed on either side of the stream. 

Seasonal and ephemeral drainages would be maintained with a 50 foot buffer on both sides. 

Riparian reserve buffers would be maintained at the greater of the distance from stream channel 

or from riparian vegetation. 

• Best Management Practices (BMPs) (USDA 1988) apply. Specific BMPs are for Timber 

Management (pp. 1-21), Road Systems (pp. 22-42), Fire suppression and Fuels Management 

(pp.43-47), Watershed Management (pp. 48-55), and Vegetative Manipulation (pp. 71-73). 

These practices maintain the physical integrity of the aquatic system and in cooperation with 

the State of Oregon, are required to be followed in accordance with the Clean Water Act. For a 

complete list, see Appendix A, Management Direction. 

• Use old landings and skidding networks whenever possible. Assure that water control structures 

are installed and maintained on skid trails that have gradients of 10 percent or more. Ensure 

that erosion control structures are stabilized and working effectively (LRMP SL-1; Timber 

Management BMP T-16, T-18). 

• In all proposed activity areas, locations for new yarding and transportation systems would be 

designated prior to the logging operations. This includes temporary roads, spur roads, log 

landings, and primary (main) skid trail networks. (LRMP SL-1 & SL-3; Timber Management 

BMP T-11, T-14 & T-16). 

• Minimize potential erosive effects of concentrated water through the proper design and 

construction of temporary roads (Road BMP R-7). 

• Conduct regular preventive maintenance to avoid deterioration of the road surface and 

minimize the effects of erosion (Road BMP R-18, R-19). 

• Retain adequate supplies of large woody debris (greater than 3-inches in diameter) to provide 

organic matter reservoirs for nutrient cycling following completion of all project activities 

(LRMP SL-1). It is recommended that a minimum of 5 to 10 tons per acre of woody debris be 

retained on dry, ponderosa pine sites to help maintain long-term site productivity. 
Environmental Impact Statement BLT Project 

 Chapter 2 

31

• Strive to maintain existing sources of unburned or partially consumed, fine organic matter 

(organic materials less than 3-inches in diameter; commonly referred to as the duff layer), 

wherever possible, within planned activity areas. (LRMP SL-6; Fuels Management BMP F-2; 

Timber Management BMP T-13). 

• Maintain spacing of 100 to 150 feet for all primary (main) skid trail routes, except where they 

converge at landings. If closer spacing is necessary due to complex terrain, the Timber Sale 

Administrator must provide advance approval. Main skid trails spaced 100 feet apart will 

maintain soil quality on 89 percent of the unit area. For larger activity areas (greater than 40 

acres) that can accommodate wider spacing distances, it is recommended that distance between 

main skid trials be increased to 150 feet to maintain soil quality on 93 percent of the unit area 

(Froehlich, 1981; Garland, 1983). This would reduce the amount of surface area where 

restoration treatments, such as subsoiling, would be required to mitigate impacts and to achieve 

soil management objectives. 

• Restrict grapple skidders to designated areas (i.e., roads, landings, designated skid trails) at all 

times, and limit the amount of traffic from other specialized equipment off designated areas. 

The use of harvester machines will be authorized to make no more than two equipment passes 

on any site-specific area to accumulate materials. 

• Avoid equipment operations during times of the year when soils are extremely dry and subject 

to excessive soil displacement. 

• Avoid equipment operations during periods of high soil moisture, as evidenced by equipment 

tracks that sink deeper than during dry or frozen conditions. An indication of potential 

detrimental disturbance would be identifiable when ruts, or indentations in the ground after 

equipment travel appears 6 inches in depth or greater. 

• When possible, operate equipment over frozen ground or a sufficient amount of compacted 

snow to protect mineral soil. Equipment operations should be discontinued when frozen 

ground begins to thaw or when there is too little compacted snow and equipment begins to 

cause soil-puddling damage (rutting). 

• Prevent additional soil impacts in random locations of activity areas, between skid trails and 

away from landings, by machine piling and burning logging slash on existing log landings and 

skid trails that already have detrimental soil conditions. Machine piling equipment must stay 

on existing skid trails and landings. 

• On steep pitches (slopes of 30 percent or steeper) less than 100 feet long, equipment will be 

permitted to make one pass out and one pass back to harvest trees. In other areas, directional 

felling of trees to skid trails and /or line pulling should be utilized to harvest trees. This method 

applies to the following units that have a small amount of slopes over 30 percent in less than 10 

percent of the unit area: 175 (1 percent), 300 (8 percent) 751 (2 percent), 755 (1 percent), 1035 

(1 percent), 1065 (3 percent), 1070 (7 percent), 1110 (6 percent), and 1135 (1 percent). Unit 

725 has approximately 4 acres (20 percent) with slopes over 30 percent. A mitigation measure 

was included that retains these 4 acres in a retention area, allowing ground-based systems to 

operate in the remaining portion. 

• On existing exposed soil adjacent to stream crossings and haul routes (roads) within riparian 

reserves, use native grass seed to accelerate revegetation. This also would be applied to restore 

vegetation on temporary roads, where it is feasible. 
BLT Project Environmental Impact Statement 

Chapter 2 

32

• Reclaim all temporary roads by applying appropriate soil restoration treatments. 

Wildlife 

• Fifteen (15) percent of each treatment unit regardless of management allocation will be retained 

in an unmanaged condition. These “leave” areas would be strategically located to retain 

desired wildlife habitat (such as dense multi-storied pockets, accumulations of snags and down 

logs, and the largest available green trees), unique habitats (such as rock outcrops and mixed 

conifer/hardwood stands), and other resources, such as cultural heritage sites, developed water 

sources (guzzlers) or wildlife connectivity corridors, Figure 3-25. 

• If previously unknown nest sites of threatened, endangered, sensitive, or management indicator 

avian species are discovered during contract operations, project activities would not take place 

within an established distance from the occupied nest during periods of sensitivity, as described 

in Table 2-5. Activities that may disturb each species would be determined by a qualified 

wildlife biologist, but generally include timber hauling, timber harvest, temporary road 

construction, small tree thinning, prescribed slash burning and underburning operations. 

Seasonal restrictions may be waived in a given year if a qualified biologist determines the 

species is in a non-nesting status, had a nest failure, or that the habitat is not occupied; waivers 

are only valid until the beginning of the next breeding season. 

• Seasonal restrictions on all occupied wildlife habitat sites identified in this EIS would be placed 

as described in Table 2-5. Some species, like the northern spotted owl and bald eagle, have no 

known nest sites within the analysis area. However, if new occupied habitats are discovered 

during sale layout or implementation of the BLT project, contract provisions are in place to halt 

operations for Threatened and Endangered species. For all other species, the Forest Service 

would negotiate with the purchaser or amend the timber sale contract in order to follow related 

Forest Plan Standards and Guidelines. 

Table 2-5. Seasonal Restrictions on Disturbing Activities near Active Nest Sites, Wolverine Dens, 

and Big Game Calving/Fawning Habitat 

Species Buffer Distance Restricted Season 

Northern spotted owl (nest) 1⁄4 mile (most activities) or 1⁄2 mile 

(helicopter operations) March 1 –August 31 

Northern bald eagle (nest) 1⁄2 mile (line-of-sight) or 1⁄4 (non line-ofsight) 

January 1 – August 

31 

Bald eagle (winter roost) To be determined by a district wildlife 

biologist 

November 1 – April 

30 

Goshawk (nest) 1⁄4 mile March 1- August 31 

Osprey (nest) 1⁄4 mile April 1 – August 31 

Red-tailed hawk (nest) 1⁄4 mile March 1 – August 31 

Sharp-shinned hawk (nest) 1⁄4 mile April 15 – August 31 

Cooper’s hawk (nest) 1⁄4 mile April 1 – August 31 

Great gray owl (nest) 1⁄4 mile March 1 – June 30 

Great blue heron (nest) 1⁄4 mile March 1 – August 31 

Wolverine (den) 2 miles February 1 – May 30 

Deer and Elk 

(fawning/calving habitat) To be determined by qualified biologist May 1 – June 30 

 

• If sharp-shinned, Cooper’s hawk or goshawk nests are discovered during layout of the BLT 

project, temporary road construction will be located outside of nest stands (LRMP WL-27, 18, 

and 10). 
Environmental Impact Statement BLT Project 

 Chapter 2 

33

• If a sharp-shinned, Cooper’s hawk, or goshawk nest is discovered during project layout, a 

forested stand of at least l0 acres will be left for sharp-shins (LRMP WL-25), 15 acres for 

Cooper’s (LRMP WL-17), and 25 acres for goshawks (LRMP WL-9). If a goshawk nest is 

discovered within an area covered by the Eastside Screens, seasonal restrictions on activities 

near the nest will be required for activities that may disturb or harass the pair while bonding or 

nesting. Thirty (30) acres of the most suitable nesting habitat surrounding the nest will be 

deferred from harvest. A 400-acre post fledgling area (PFA) will be established. While 

harvest activities can occur within this area, the prescription will retain LOS stands and 

enhance younger stands towards LOS conditions, if possible (Interim Wildlife Standard 

Scenario A, 5). 

• If a great gray owl nest is discovered during BLT layout, a forested stand of at least 30 acres 

will be maintained around the nest site (LRMP WL-31). If a great gray owl is discovered 

within the boundary of the Northwest Forest Plan. 

• Active red-tailed hawk nests will be protected by maintaining the forested character of the area 

at least 300 feet in radius around the nest. Timber management may occur within this area, but 

must maintain an average of four dominant overstory trees per acre suitable for nest and perch 

trees. Ponderosa pine will be favored where available (LRMP WL-2). 

• To protect potential bat habitat, restrict all project activities on lava pressure ridges greater than 

or equal to 100 square feet in size. 

Wildlife/Snags 

• All existing snags would remain except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety. Timber Sale Administrators 

would design harvest operations to avoid snags by locating skid trails and landings away from 

them, where possible. If snags need to be felled, they are to be retained for down wood. 

Felled snags may be moved off roads and landings, but not removed from the site. 

• In stands currently below desired snag levels (Table 2-6) as determined by pre-sale tally, 

sufficient green trees would be retained to create snags. Snag creation to increase snag 

densities would take place as funding is available. Note: These levels exceed minimum 

requirements specified in the Eastside Screens. 

Table 2-6. Minimum Snag Levels to Determine Snag Creation 

Location PAG7 Snag Densities and Diameters 

MH 2.85 snags/acre > 10” dbh with 0.6 snags/acre > 20” dbh 

PP 3.87 snags/acre > 10” dbh with 0.6 snags/acre >20” dbh 

MC 3.93 snags/acre > 10” dbh with 0.6 snags/acre > 20” dbh Matrix 

LP 2.85 snags/acre > 10” dbh with 0.66 snags/acre > 12” dbh 

PP 2.25 snags/acre > 15” dbh with 0.14 snags/acre > 20” dbh 

MC 2.25 snags/acre > 15” dbh with 0.14 snags/acre > 20” dbh 

East of 

the NSO 

Line LP 1.80 snags/acre > 10” dbh with 0.59 snags/acre > 20” dbh 

Wildlife/Down Wood 

• Down wood requirements in all units except areas where fire behavior is maintained 

through time (Strategic Placement of Treatments, SPOTS) and areas of potential 

firewood: The intent is to retain all existing levels of down wood 7 inches and greater in 

 

7

 MH= mountain hemlock, PP= ponderosa pine, LP = lodgepole pine, MC = mixed conifer 
BLT Project Environmental Impact Statement 

Chapter 2 

34

lodgepole pine and 9 inches and greater in all other Plant Association Groups8. Only activitycreated slash below these diameters would be piled and utilized or disposed. Retain 2-3 piles 

per acre. Minimum pile size is 15 feet X 15 feet X 10 feet in grapple pile units. The minimum 

pile size is 6 feet X 6 feet X 4 feet in handpile units. This requirement can be waived if sitespecific monitoring determines adequate levels of down wood are met in all units regardless of 

location (Table 2-7). While retaining down wood in place is preferred, it is recognized that 

some manipulation may be needed to meet stand prescription objectives. In all units, down 

wood may be manipulated (shifted, clumped, grouped, driven over, etc.) only as necessary to 

meet objectives. In all units, if sufficient size classes are not present, then the largest available 

down logs would be substituted. 

• Requirements in areas where fire behavior is maintained through time (Strategic 

Placement of Treatments, SPOTS) and areas of potential firewood: Meet or exceed 

minimum levels specified in Tables 2-6 and 2-7. 

Spot Units 

Alternative B: 80, 135, 155, 270, 350, 435, 520, 530, 575, 595, 610, 620, 625, 640, 655, 660, 

775, 815, 835, 1065, 1070, 1185, 1190, 1195, 1205 and 1215. 

Alternative C: 80, 135, 155, 270, 350, 520, 530, 610, 640, 660, 775, 815, 835, 1065, 1190, 

1195, and 1205. 

Alternative D: 80, 135, 270, 520, 610, 815, 1195, and 1205. 

Potential Firewood Units 

Alternative B: 80, 270, 295, 435, 575, 690, 940, 1190, 1200, 1205, 1235, and 1300. 

Alternative C: 80, 270, 940, 1190, 1205, and 1235. 

Alternative D: 80, 270, 295, 1205, and 1300 

• Wherever possible, cull material greater than or equal to 9 inches in diameter would be retained 

in the unit and not moved to landings. 

• Live trees not intended for removal but damaged during vegetation management activities 

would remain standing if they do not pose a safety risk to forest workers. If they are felled, 

they would remain on site and retained for down wood. 

• Personal use and/or commercial firewood removal would not be permitted within designated 

Old Growth Management Areas that overlap units: 265, 310, 311, 312, 340, 770, 835, 845, 900 

and 915. 

 

8

 Minimum down wood requirements are Plant Association Group specific for dependent wildlife species. 
Environmental Impact Statement BLT Project 

 Chapter 2 

35

Table 2-7. Minimum Down Wood Levels Regardless of Location 

Species Tons 

 per Acre 

Diameter 

Small end 

Whole Tree 

Equivalent 

Percent 

Cover 

Lodgepole Pine 7-42 9 inches 17-105 Whole Trees 

8-12 inches in diameter 

2.6-15.9 

Stands Dominated by 

Ponderosa Pine 12-23 9 inches 11-16 Whole Trees 16-22 inches in diameter 

2.8-5.2 

Ponderosa Pine Stands 

Where Lodgepole Pine 

Comprises Most Down 

Wood 

Not 

specified in 

this plant 

association 

9 inches 

8-10 Whole Trees Largest 

LP on Site Plus Retain all 

Other Species 

0.1-0.3 

in lodgepole 

Mixed Conifer 11-42 9 inches 11-38 Whole Trees 

16-22 inches in diameter 

2.6-10 

Slash Disposal/Prescribed Burning Operations 

• Slash disposal using prescribed fire would be accomplished during the cool and moist seasons 

of spring and fall. 

• Prescribed burning would be accomplished in a mosaic pattern with unburned areas within the 

burn, in addition to unburned designated leave areas. No underburning or broadcast burning 

would take place in early-seral or mid-seral mixed conifer stands, and lodgepole pine habitat 

types other than minor creeping from burning piles. Exceptions would be in early-seral mixed 

conifer stands that are managed to emphasize ponderosa pine and/or sugar pine associated 

species and within areas identified as needed for strategic fuel reduction. 

• To concurrently meet wildlife objectives for retention of larger dead wood and fuel objectives 

for reduction of large fire risk, burn prescriptions and fuels moistures should be such that snags 

greater than 15 inches in diameter and down wood greater than 12 in diameter at the large end 

would be protected. It is assumed that reduction of snags and down wood less than 9 inches is 

most effective in reducing rate of fire spread. Grapple and hand piles would not include 

material greater than 7 inches in lodgepole pine and 9 inches in all other plant associations 

would be retained. If snag and down wood diameters do not meet objectives within a unit, the 

largest material available would be retained. Within the Eastside Screens, fire prescription 

parameters will ensure that consumption will not exceed 3 inches total (1.5 inches per side) in 

featured log sizes in Table 2-7 (Interim Direction Scenario A, 2). 

• Burning operations would be utilized to create snags, where deficiencies occur. 

Invasive Plant Species 

The Region 6 Invasive Plant Final Environmental Impact Statement (FEIS) Record of Decision (ROD) 

(USDA Forest Service, 2005) amended the Deschutes LRMP, adding additional standards for invasive 

plant prevention and control. Prevention would be emphasized as the preferred strategy for invasive 

plant management by adhering to Regional Standards as adopted by central Oregon Forest Plans. The 

following identifies which standards apply to this project.

• Actions conducted or authorized by written permit (contracts) that operate outside the limits of 

the road prism, require cleaning of all heavy equipment (i.e., bulldozers, skidders, other logging 

equipment) prior to entering National Forest System Lands. 

• Conduct road blading, brushing and ditch cleaning in areas with high concentrations of invasive 

plants in consultation with District or Forest-level invasive plant specialists, incorporate 

invasive plant prevention practices as appropriate (road maintenance and re-opening roads). R6 
BLT Project Environmental Impact Statement 

Chapter 2 

36

• Forest Service employees would inspect, remove, and properly dispose of weed seed and plant 

parts found on their clothing and personal equipment prior to leaving a project site infested with 

weeds. 

• Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants 

before use and transport. Treat or require treatment of infested sources before any use of pit 

material. Use only gravel, fill, sand, and rock that are judged to be weed free by District or 

Forest weed specialists. There are no activities, including road reconstruction planned within 

the BLT analysis area that requires rock from a quarry. 

• Noxious weed risk assessments will be completed, and weed management will be considered in 

all NEPA planning activities where ground disturbance or invasive plant dispersal vectors are 

involved. 

Air Quality 

• Reduce particulate emission through utilization to the extent practical (i.e. pulling trees to the 

landing with limbs attached and biomass utilization versus prescribed burning). 

• The objective is to minimize human-caused visual impacts to the Class 1 airshed (Diamond 

Peak Wilderness and Maiden Peak Inventoried Roadless Area). Prescribed burning operations 

would be restricted during the period of July 1 – September. Also, prescribe burn operations to 

dissipate smoke away from the Class 1 airshed (i.e. burn during forecasted westerly winds). 

• Warning signs would be posted at prominent road junctions to inform the public of prescribed 

burning operations, and will remain in place until there is no visible smoke. If feasible, roads 

may be temporarily closed for the protection of public safety. 

• As part of the plan to inform the public, notify local businesses prior to the burning season and 

on the day of planned prescribed burning operations. Also, notify adjacent landowners of 

burning operations conducted in units within 1⁄4 mile of their property. 

Mitigations Common to All Action Alternatives 

The following mitigation measures are an integral part of each of the action alternatives. These are 

different from Project Design Features in that they are typically tied to a specific unit and they are used 

to avoid, minimize, rectify, reduce, or compensate an impact (40 CFR 1508.20). They are listed here 

separately to avoid repeating them in each alternative description. 

The effectiveness of each measure is rated at high, moderate, or low to provide a qualitative assessment 

of how effective the practice will be in preventing or reducing resource impacts. These mitigation 

measures and design elements are considered in the effects discussions of Chapter 3. 

Effectiveness ratings of High, Moderate or Low are based on the following criteria: a) Literature and 

Research, b) Administrative Studies (local or within similar ecosystem), c) Experience (judgment of 

qualified personnel by education and/or experience, d) Fact (obvious by reasoned, logical, response). 

High: Practice is highly effective (greater than 90 percent), meets one or more of the rating criteria, 

and documentation is available. 
Environmental Impact Statement BLT Project 

 Chapter 2 

37

Moderate: Documentation shows that practice is 75 to 90 percent effective; or logic indicates that 

practice is highly effective, but there is no documentation. Implementation and effectiveness of this 

practice needs to be monitored and the practice will be modified if necessary to achieve the 

mitigation objective. 

Low: Effectiveness is unknown or unverified, and there is little or no documentation; or applied 

logic is uncertain and practice is estimated to be less than 60 percent effective. This practice is 

speculative and needs both effectiveness and validation monitoring. 

Vegetation Management 

1. Within all mapped wildlife connectivity corridors site-specific field reconnaissance would 

be performed by a wildlife biologist, silviculturist, and fuels specialist to determine 

appropriate treatments and maintain consistency with Regional Forester’s Amendment #2 

Eastside Screens and Figure 3-25. For details, reference Connectivity and Fragmentation in 

the Wildlife section, Chapter 3. High

Table 2-8. Connectivity Corridor Acres by Alternative 

Unit Alt B Alt C Alt D 

45 1 1 1 

65 29 29 

80 1 1 1 

125 6 6 6 

135 15 15 15 

150 10 10 

155 16 16 

165 2 2 

175 0 0 

195 8 8 8 

200 7 7 7 

245 3 3 

265 2 2 2 

310 11 

335 15 15 15 

405 7 

420 23 23 

435 0 

460 3 

465 1 1 

485 1 1 

505 11 11 

535 0 0 

561 0 

570 39 39 

625 5 5 

640 4 4 

655 11 

670 12 12 

690 4 

751 2 2 2 

790 0 0 0 

815 12 12 12 
BLT Project Environmental Impact Statement 

Chapter 2 

38

Unit Alt B Alt C Alt D 

835 8 8 

845 4 4 4 

870 1 

875 1 

900 4 4 

1061 2 2 2 

1070 3 

1235 3 3 

TOTAL 287 247 73 

Invasive Plants 

2. Within and adjacent to unit 875, restrict mechanized equipment to areas outside of known 

populations of the invasive plant leafy spurge. Control populations with approved methods 

prior to project implementation. All other Project Design Features for clean equipment 

apply. 

Soil and Water Quality 

3. To achieve acceptable productivity potential following land management activities (Forest 

Plan page 4-70, SL-1 and SL-3), Guidelines (FSM 2500, R-6 supplement 2500-98-1), 

Forest Service Region 6 Supplement 2520.3 – Policy, use subsoiling to relieve compacted 

soils in the following units: High

a. Alternative B: 30, 45, 55, 65, 80, 135, 150, 155, 165, 175, 185, 200, 210, 265, 

270, 295, 300, 310, 311, 312, 315, 316, 317, 320, 340, 350, 405, 410, 420, 435, 

460, 465, 485, 505, 525, 530, 570, 575, 590, 610, 625, 635, 640, 655, 675, 690, 

705, 725, 755, 770, 775, 790, 820, 835, 840, 855, 856, 865, 875, 915, 1035, 1070, 

1085, 1100, 1110, 1130, 1135, 1160, 1165, 1175, 1180, 1185, 1190, 1195, 1200, 

1205, 1210, 1215, 1230, 1235, 1240, 1255, 1260, 1265, 1270, 1275, 1300, and 

1310. 

b. Alternative C: 45, 65, 80, 135, 150, 155, 165, 175, 185, 200, 210, 265, 270, 300, 

315, 316, 317, 320, 340, 350, 420, 465, 485, 505, 525, 530, 570, 590, 610, 625, 

635, 640, 725, 755, 770, 775, 790, 835, 840, 855, 856, 865, 875, 915, 1035, 1085, 

1100, 1110, 1135, 1160, 1165, 1175, 1180, 1190, 1195, 1205, 1210, 1215, 1230, 

1235, 1255, 1260, 1265, 1270, 1275, and 1310. 

c. Alternative D: 30, 45, 80, 135, 200, 265, 270, 295, 300, 315, 316, 317, 340, 410, 

525, 610, 725, 790, 820, 840, 1195, 1205, 1215, 1255, 1265 and 1300. 

4. In unit 725, approximately 4 acres contain slopes over 30 percent. Utilize this portion for 

the areas for retention in a passive management scenario. High

5. In "fuels only units", restrict mechanical equipment to existing areas considered in a 

detrimental condition such as skid trails and landings. High 

a. Alternative B: 45, 80, 115, 620 and 940 

b. Alternative C: 45, 80, 115, 620 and 940 

c. Alternative D: 45, 80, 115 
Environmental Impact Statement BLT Project 

 Chapter 2 

39

Matsutake Mushrooms 

6. In units where matsutake mushrooms have been determined or are suspected to be present, 

tractor skidding and mechanized felling shall be on frozen ground or sufficient snow depth 

as determined by the Forest Service except for units 770 and 785 which overlap the Beals 

Butte groomed snowmobile trail. This applies to tractor units and advanced systems, if 

mechanized felling is used. This mitigation shall be incorporated in the following units: 

Moderate

a. Alternative B: 125, 195, 200, 210, 245, 265, 270, 285, 300, 310, 311, 312, 315, 

316, 320, 335, 340, 410, 460, 525, 820, 835, 845, 915, 1035, 1100 and 1135. 

b. Alternative C: 125, 195, 200, 210, 245, 265, 270, 300, 315, 316, 320, 335, 340, 

525, 835, 845, 915, 1035, 1100, and 1135. 

c. Alternative D: 125, 195, 200, 265, 270, 300, 315, 316, 335, 340, 410, 525, 820, 

and 845. 

Wildlife 

7. Seasonal restrictions as described in Table 2-5 would be applied to mule deer fawning and 

elk calving habitat. No activities may occur from May 1 through June 30 in all or portions 

of units: High

a. Alternative B: 45, 80, 100, 115,130, 150, 155, 165, 175, 245, 265, 610, 751, 820, 

840, 855, 856, 865, 870, 875, 1061, 1070, 1085, 1130, 1135, 1185, 1190, 1200, 

1205, 1210, 1215, 1235, 1240, 1265, and 1300. 

b. Alternative C: 80, 115, 150, 155, 165, 175, 245, 265, 610, 751, 840, 855, 856, 

865, 875, 1061, 1085, 1190, 1205, 1210, 1215, and 1265. 

c. Alternative D: 45, 80, 115, 265, 610, 751, 1061, 1205, 1215, 1265 and 1300. 

If requested, waivers may be considered if surveys are conducted and determine deer 

and/or elk are not present in individual units during the calving/fawning season. 

8. Within unit 785, maintain a minimum 6 acre unthinned clump centered on the Muttonchop 

guzzler to provide big game hiding cover. Alternatives B, C, and D. High

9. To provide Northern goshawk nesting habitat in the Little Deschutes River Old Growth 

Management Area (units 835, 840, 900, and 915), retain a consolidated 30 acres in a 

passive management scenario in an area with the largest diameter and most dense patch of 

ponderosa pine. High

10. To protect potential Crater Lake Tightcoil mollusks in unit 1061, prohibit prescribed 

burning of decadent willow clumps within 10 meters of permanently wetted portions of 

riparian zones, unless additional surveys are conducted. High

Recreation 

11. To protect access and quality of winter snowmobile trails and to maintain safety of users, 

seasonal restrictions for harvest operations would be between April 2 and November 30 in 

the following units: High

a. Alternative B: 410, 460, 525, 770, and 785. 

b. Alternatives C and D: 525 and 785. 
BLT Project Environmental Impact Statement 

Chapter 2 

40

Wild and Scenic River 

Reference the Little Deschutes Wild and Scenic River Plan which adopted Visual Quality Objectives 

for Partial Retention (high level of scenic integrity) from the Deschutes Forest Plan as seen from access 

roads along the river corridor. All units are within the Northwest Forest plan and outside the Eastside 

Screen boundary. 

12. Timing of cleanup along FS roads 5830300 and 5835300 will be 2 years following activity 

in units: 

a. Alternative B: 1185, 1215, 1265, 1200, 1245, 1246, and 1300 

b. Alternative C: 1185, 1215, and 1265, and 

c. Alternative D: 1185, 1215, 1265, and 1300 

Little Deschutes Wild and Scenic Management Plan, page 12 High

13. Large diameter trees (24 inches in diameter) or greater will not be harvested unless they 

meet the specific criteria listed on page 4-123 of the Forest Plan in Retention and Partial 

Retention. Little Deschutes Wild and Scenic Management Plan, page 12 High

14. Design skid trails and landings to minimize visibility. Landings closer than 300 feet and 

skid trails closer than 150 feet would be approved on a case by case basis. Little Deschutes 

Wild and Scenic Management Plan, page 12 High

15. Handpile and dispose of slash within 150 feet of FS roads 5830300 and 5835300 within 

two years. Little Deschutes Wild and Scenic Management Plan, page 12 High

16. The objective is to have no visible marking paint to visitors from the river or the roadways 

after completion of the harvest operations. Individual Tree Mark (ITM) all units within the 

corridor. Remove tags, ribbons, boundary signs, and other means of designating activity. 

Little Deschutes Wild and Scenic Management Plan, page 12 High

17. Use 15 percent retention areas to maintain vegetative diversity and screen potential activity 

areas that may be visible from the roadway. Little Deschutes Wild and Scenic 

Management Plan, page 12 Moderate

Scenery along Highway 58 

18. Timing of cleanup along Highway 58 will be 2 years following activity in units:

Forest Plan Standard and Guideline M9-8 and M9-58. High 

a. Alternative B: 200, 210, 260, 270, 285, 335, 350, 435, 455, 465, 516, 751 

and 800; 

b. Alternative C: 200, 210, 260, 270, 285, 335, 350, 465, 751 and 800: and 

c. Alternative D: 200, 260, 270, 335, 455, 751 and 800. 

19. Design skid trails and landings to minimize visibility. Landings closer than 200 feet would 

be approved on a case by case basis. Forest Plan Standard and Guideline M9-4 and M9-57. 

High 

20. Handpile and dispose of slash within 200 feet of Highway 46 within two years. Forest Plan 

Standard and Guideline M9-8 and M-9-58. High 
Environmental Impact Statement BLT Project 

 Chapter 2 

41

21. The objective is to have no visible marking paint to visitors on the roadway. After 

activities are completed, remove tags, ribbons, boundary signs and other means of 

designating activity. Forest Plan Standard and Guideline M9-4 and M9-57 High 

Alternatives Considered but Eliminated from Detailed Study 

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed 

in detail (40 CFR 1502.14). Public comments received in response to the Proposed Action provided 

suggestions for alternative methods for achieving the purpose and need. Some of these alternatives may 

have duplicated the alternatives considered in detail or were determined to be unable to meet the 

project’s Purpose and Need. Alternatives that were considered but dismissed from detailed 

consideration and the reasons for dismissal are summarized below. 

Prioritizing Stands for Thinning to Optimize Potential Matsutake Production 

The analysis in the Botany section divided stands into three categories of potential matsutake habitat. 

These categories were developed and analyzed using plant association group (PAG) combinations, 

crown closure class and structure/size classes. Potential habitat is assumed to be capable of supporting 

current matsutake populations, or potentially within 5-10 years. The three categories are “Thin to 

Quality Habitat” (Thin), “Good Quality Habitat” (Good), and “Grow to Quality Habitat” (Grow), based 

on aggregated attributes of crown cover class and size/structure class. Approximately 1,950 acres in the 

BLT analysis area were identified where stands could be thinned to provide a higher quality habitat for 

matsutake (Thin to Quality Habitat). Alternative B would thin to provide higher quality habitat for 

matsutake on 776 acres in all Plant Association Groups, or approximately 40 percent of those 1,950 

acres. The remaining acres (1,174) that could be thinned to create quality matsutake habitat are mostly 

not available for thinning. They are located in parts of the 5th field watershed where management 

activity is restricted such as Wilderness (where mushroom harvesting is not permitted), or management 

areas that are not proposed for activity at this time (Oregon Cascades Recreation Area). In addition, 

some dense areas were not proposed for activity to provide for dependent wildlife species that need 

connectivity between late and old forests. Therefore, an alternative that would prioritize stands to 

optimize potential matsutake habitat was eliminated from detailed consideration. 

Avoid Management Activities in Matsutake Habitat 

Some commenters have requested that the Forest Service avoid matsutake habitat altogether. The 

botany analysis in Chapter 3 indicates this could be 98 percent of the planning area, which is similar to 

Alternative A, No Action. From the original Proposed Action in 2003 until now, the acres of active 

management have been reduced from approximately 14,000 to 7,499. A considerable amount of 

refinement is attributed to stakeholder input on prime matsutake picking areas (Table 2-1). In addition, 

Alternative D was specifically designed to address the issue of a short term reduction in matsutake 

production by excluding management in the most productive areas. Therefore, an alternative that 

avoids management in matsutake habitat completely was eliminated from detailed consideration. 

Stage BLT Activities So That Short-Term Matsutake Production is not removed All at Once 

Some matsutake harvesters on a field trip in October, 2004 suggested a staggered implementation of 

timber sales to minimize short-term loss of production. Since 2004, the proposed action was modified 

almost by one half, in part, to avoid the very best picking areas identified by the mushroom harvesters. 

In addition, Alternative D was developed to avoid most picking areas west of Highway 58. 

Due to the nature of timber sales, it is not unusual for one to have delayed implementation over a 

timeframe of 5-10 years (i.e. Baja Environmental Assessment). Given the estimated recovery time 

from harvest operations for matsutake production ranging from 2-10 years (Botany, Chapter 3), it is 
BLT Project Environmental Impact Statement 

Chapter 2 

42

likely staged timber sales would not remove matsutake production all at once. In addition, the 

Responsible Official always has the option to delay or stage timber sales. 

Limit Fire Hazard Reduction to Non-Commercial Activities within Strategic Placement of 

Treatments (SPOTS) 

This alternative was considered and modeled to determine if adequate risk reduction can be achieved 

through non-commercial activities in current SPOTS maintained through time. However, the analysis 

determined larger blocks of modified fire behavior are necessary for a long-term protection strategy 

(e.g. populated subdivisions). In order to maintain these areas over time, the stands need to be thinned 

to a condition where prescribed burning is feasible; that is, it will not cause mortality to the larger more 

desirable trees in the stand. A comparison of alternatives and their overlap onto SPOTS is shown in 

Chapter 3, Fire and Fuels Management. 

The Purpose and Need for the BLT project was to limit the extent of disturbance processes across the 

landscape. By focusing on only risk reduction in SPOTS, much of the landscape would remain at an 

elevated risk from insect and disease agents (similar to Alternative and Alternative D to a lesser extent). 

Therefore, this alternative was eliminated from detailed consideration. 

 

Thinning Limited to Small Diameter (8-15 inches) 

Some commenters suggested that the analysis area should be managed only through the thinning of 

small-diameter trees. This alternative was eliminated from detailed study because modeling of 

vegetation indicated that small diameter thinning by itself would not considerably move the analysis 

area towards the desired condition and would not meet the Purpose and Need of the project. 

Also, reintroduction of fire is not a viable option in most stands where only small-diameter thinning has 

occurred or where lodgepole pine is the dominate species type. In this scenario, trees would remain 

dense enough that prescribed fire would cause an undesired level of mortality to the overstory trees; 

retention of overstory trees is desirable and is part of the Purpose and Need of the BLT project. 

Figure 2-4 displays the results of modeling small-tree (trees 8-12 inches in diameter and smaller) 

thinning in 30 randomly selected stands within the Five Buttes project area. The Five Buttes project 

was a good surrogate for the BLT project because there are similar environmental conditions. Points 

above the typical basal area line are where a stand (in general) is at risk to an uncharacteristic loss of 

large trees. Small diameter thinning by itself does not appreciably ameliorate a stand’s competition for 

scarce resources thus the risk of uncharacteristic disturbance processes. 

Additional modeling was completed to determine the effects of thinning trees 15 inches dbh and 

smaller. The results were not appreciably different from those depicted in Figure 2-4. Therefore, an 

alternative that would limit thinning to small diameter trees (exclusively) was eliminated from detailed 

consideration. 
Environmental Impact Statement BLT Project 

 Chapter 2 

43

Small Tree Thin Basal Area Comparison

0

50

100

150

200

250

300

350

400

0 5 10 15 20 25 30 35

Stand

Basal Area (square feet) per acre

Pre-thinning BA

Post-thin BA 8" max

Post-thin BA 12" max

Heavy Thinning

Light Thinning

Typical BA

Figure 2-4. Comparison of anticipated effects of small-tree thinning on basal area 

Sale Area Improvement Projects________________________ 

Money may be collected from the timber sales to complete certain projects such as required 

reforestation, identified mitigation, and enhancement and restoration projects in the vicinity of the 

timber sale areas. Required reforestation items (R) and mitigation measures (M) have the highest 

priority for funding, but may be funded by other means such as appropriated funds to insure that 

requirements are accomplished. Items marked with an (E) are considered Enhancement. 

This list is intended to serve as an overall guide for the analysis area. As timber sales are delineated 

within the project area, specific priorities may be adjusted to meet the needs for each sale area. This 

priority setting should be documented briefly in the implementation file for each timber sale. 

1. Subsoiling (M) 

2. Seeding of Temporary Roads and Ditches of Stream Crossings with Natural Seed (E) 

3. Small Diameter Thinning (E) 

4. Invasive Plant Monitoring (E) 

5. Prescribed Burning (E) 

6. Pruning (E) 

7. Snag Creation (E) 

8. Grapple Piling and Disposal of Hazardous Fuels (E) 

9. Great Gray Owl Nest Platforms (E) 

10. “Closed Road” Sign Posting (E) 
BLT Project Environmental Impact Statement 

Chapter 2 

44

Comparison of Alternatives ____________________________ 

This section provides a summary of the effects of implementing each alternative. Information in Tables 

2-9, 2-10, and 2-11, is focused on activities and effects where different levels of effects or outputs can 

be distinguished quantitatively or qualitatively among alternatives. 

Table 2-9. Comparison of the Activities by Alternative 

Activity Alt. A Alt. B Alt C Alt. D 

Commercial Harvest (acres) 0 7,086 5,436 2,304 

Logging Systems (acres) 

Ground-based 

Cable or Helicopter 

0 

0 

6,624 

462 

5,005 

431 

2,206 

98 

Fuels Reduction Outside Harvest Units (acres) 0 413 334 312 

Additional Prescribed Fire in Stands to Return 

to a Frequent Fire Regime 1 0 2,312 1,764 824 

Temporary Road Construction (miles) 0 9.7 8.7 4.8 

Activities Overlap Identified Strategic 

Placement of Treatments (SPOTS) 0 2,017 1,149 425 

Table 2-10. Comparison of How Each Alternative Responds to the Purpose and Need 

Purpose and 

Need 

Alternative 

A 

No Action 

Alternative 

B 

Preferred 

Alternative

Alternative 

C 

Alternative 

D 

There is a need to reduce forest vegetation density so as to lessen 

the risk that disturbance events such as insect, disease, and wildfire 

will lead to large-scale loss of forest. 

Acres 

Changed to a 

More 

Sustainable 

Condition 

0 7,499 Acres 5,771 Acres 2,616 

Acres

There is a need to contribute to the local and regional economies by 

providing timber and other wood fiber products. 

Estimated 

Timber 

Volume 

(million 

board feet) 

0 12.1 9.8 5.2 
Environmental Impact Statement BLT Project 

 Chapter 2 

45

Table 2-11. Comparison of How Each Alternative Responds to the Key Issues 

Issue and Indicators Alternative 

A 

Alternative 

B 

Alternative 

C 

Alternative 

D 

Key Issue 1: Wildlife Habitat – Management Indicator Species 

Goshawk – acres/percent habitat 

changed from nesting and foraging 

14,211 acres 

existing nesting 

and foraging 

1,270 acres 

 (9%) changed 

to foraging only 

1,016 acres 

(7%) changed 

to foraging 

only 

378 acres 

(3%) changed to 

foraging only 

Black-backed woodpecker – 

acres/percent habitat changed from 

nesting, roosting, foraging 

57,107 acres 

existing nesting, 

roosting and 

foraging 

6,547 acres 

(12%) changed 

to potential for 

nesting; 

general stand 

avoidance for 

roosting and 

foraging 

4,987 acres 

(9%) changed 

to potential for 

nesting; 

general stand 

avoidance for 

roosting and 

foraging 

2,247 acres 

(4%) changed 

to potential for 

nesting; 

general stand 

avoidance for 

roosting and 

foraging 

Three-toed woodpecker – 

acres/percent habitat changed from 

nesting, roosting, foraging 

57,107 acres 

existing 

6,547 acres 

(12%) less 

likely to nest; 

general stand 

avoidance as 

roosting and 

foraging 

4,987 acres 

(9%) less 

likely to nest; 

general stand 

avoidance as 

roosting and 

foraging 

2,247 acres 

(4%) less 

likely to nest; 

general stand 

avoidance as 

roosting and 

foraging 

Key Issue 2: Potential Reduction of Mushroom Production in the Short Term 

Detrimental soil following 

restoration activities 0 1,524 1,166 468 

Acres of change from closed to open

canopy (mixed conifer) 0 56 56 17 

Acres of change from closed to open

canopy (lodgepole) 0 1,108 754 341 

Acres of change from closed to open

canopy (ponderosa pine) 0 290 244 66 

Total acres 0 1,454 1,054 424 

Net shift towards less productive 

habitat due to active management 0 1,120 859 352 

Acres of forest changed to a more 

sustainable condition 0 7,499 5,771 2,616 
BLT Project Environmental Impact Statement 

Chapter 3 - Introduction 

46

CHAPTER 3. AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 

Introduction _________________________________________ 

This chapter summarizes the physical, biological, social, and economic environments of the analysis 

area and the anticipated effects of implementing each alternative on that environment. 

“Affected Environment” refers to the existing biological, physical and social conditions of an area that 

are subject to change directly, indirectly, or cumulatively as a result of a proposed human action. 

Information on the affected environment is found in each resource section under “Existing Condition.” 

The following discussion of effects follows CEQ guidance for scope (40 CFR 1508.25(c)) by 

categorizing them as direct, indirect, and cumulative. The focus is on cause and consequences. Effects 

exist in a chain of consequences and thus may be labeled “indirect” (occurring later in time or farther in 

distance, 40 CFR 1508.8(b)), rather than cumulative. For this analysis, in general, direct and indirect 

effects have been discussed in the context that most readers are accustomed to: those consequences 

which are caused by the action and either occur at the same time and place, or are later in time or 

farther removed in distance but are still reasonably foreseeable (40 CFR 1508.8). Cumulative effects 

are discussed where there is an effect to the environment which results from the incremental effect of 

the action when added to other past, present, or reasonably foreseeable future actions (40 CFR 1508.7). 

There are basically two methodologies the individual resource subjects use in discussing cumulative 

actions and consequences. The first method would be to describe each individual past, present and 

reasonably foreseeable action – including mitigation (cataloging). The second would be to “lump” 

individual actions if the information regarding those actions would not be useful to illuminate or predict 

the effects of the proposed action and its alternatives. A mere “cataloging” of effects may not provide 

the most useful discussion. In some cases, lumping past actions and describing them in terms of “where 

we are today” can be the most informative. No matter which method is used, it will be formulated to 

provide the most relevant, useful, helpful, necessary and informative format for the public and deciding 

official. 

Measures to mitigate or reduce adverse effects caused by the implementation of any of the actions 

proposed are addressed in Chapter 2, Resource Protection Measures. Effective mitigation avoids, 

minimizes, rectifies, reduces, or compensates for potential effects of actions. After mitigation is 

applied, any unavoidable adverse effect to each resource area is addressed in the section titled “Other 

Disclosures” in this chapter of the EIS. 

The temporal and spatial scale of the analysis is variable depending upon the resource concern being 

evaluated, particularly for cumulative effects. The landscape within the BLT analysis area boundary is 

the focus of this EIS, but adjacent lands are considered in this analysis process. 

Changes Between Draft and Final EIS _______________ 

The following changes were made between the BLT Project Draft and Final EIS. This list does not 

include minor grammatical corrections, editorial formatting, and clarification of data previously 

presented. The changes were driven by public comment and a comprehensive internal review. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Introduction 

47

• Public comment provided a contrary view to the Forest Service literature cited regarding 

northern goshawks use. The FEIS reflects this information. Disclosure of effects to the goshawk, 

including the number of acres of nesting habitat affected and the return interval of actively-managed 

stands to functioning nesting habitat remains unchanged between the Draft and Final EIS. 

Cumulative Effects of Past, Present and Reasonably 

Foreseeable Future Actions___________________________ 

The Environmental Consequences disclosures in this EIS include discussion of cumulative effects. 

Where there is an overlapping zone of influence, or an additive effect, this information is disclosed. 

In order to understand the contribution of past actions to the cumulative effects of the proposed 

action and alternatives, this analysis relies on current environmental conditions as a proxy for the 

impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior 

human actions and natural events that have affected the environment and might contribute to 

cumulative effects. 

This cumulative effects analysis does not attempt to quantify the effects of past human actions by 

adding up all prior actions on an action-by-action basis. There are several reasons for not taking 

this approach. First, a catalog and analysis of all past actions would be impractical to compile and 

unduly costly to obtain. Current conditions have been impacted by innumerable actions over the 

last century (and beyond), and trying to isolate the individual actions that continue to have residual 

impacts would be nearly impossible. Second, providing the details of past actions on an individual 

basis would not be useful to predict the cumulative effects of the proposed action or alternatives. In 

fact, focusing on individual actions would be less accurate than looking at existing conditions, 

because there is limited information on the environmental impacts of individual past actions, and 

one can not reasonably identify each and every action over the last century that has contributed to 

current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the 

important residual effects of past natural events, which may contribute to cumulative effects just as 

much as human actions. By looking at current conditions, we are sure to capture all the residual 

effects of past human actions and natural events, regardless of which particular action or event 

contributed those effects. Finally, the Council on Environmental Quality issued an interpretive 

memorandum on June 24, 2005 regarding analysis of past actions, which states, “agencies can 

conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past 

actions without delving into the historical details of individual past actions.” 

The cumulative effects analysis in this (EA or EIS) is also consistent with Forest Service National 

Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects 

of past actions that warrant consideration, the agency assesses the extent that the effects of the 

proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The 

final analysis documents an agency assessment of the cumulative effects of the actions 

considered (including past, present, and reasonable foreseeable future actions) on the affected 

environment. With respect to past actions, during the scoping process and subsequent preparation 

of the analysis, the agency must determine what information regarding past actions is useful and 

relevant to the required analysis of cumulative effects. Cataloging past actions and specific 

information about the direct and indirect effects of their design and implementation could in some 

contexts be useful to predict the cumulative effects of the proposal. The CEQ regulations, 

however, do not require agencies to catalogue or exhaustively list and analyze all individual past 

actions. Simply because information about past actions may be available or obtained with 
BLT Project Environmental Impact Statement 

Chapter 3 - Introduction 

48

reasonable effort does not mean that it is relevant and necessary to inform decision making. (40 

CFR 1508.7)” 

Table 3-1. Past, Present, and Reasonably Foreseeable Future Actions 

Project/Event 

Name General Description of Activities Status 

Baja EA (1998-

2003) 

2,878 acres understory thin (1,068 within suitable 

northern spotted owl habitat); 166 acres salvage in 

lodgepole pine; 904 acres prescribed burning in 

appropriate stands; and 250 acres of early seral stands in 

lodgepole pine. 610 acres of prescribed fire in lodgepole 

stands to create black-backed woodpecker habitat was 

not implemented to provide short-term matsutake 

production. 

Completed 

Boundary Springs 

CE (2004) 

Hazardous fuels reduction in the Little Walker Mountain 

Watershed along private land. Includes small diameter 

thinning, utilization, and disposal. 

Completed 

Region 6 Invasive 

Plant EIS (2005) 

No overlapping geographical zone of influence. In 

context to cumulative effects, however this project 

implements Standards and Guidelines and prevention 

strategies to manage invasive plant species. 

Implementation

Crescent Lake 

WUI (2004) 

Commercial thinning and fuels reduction on 3,400 acres 

within the wildland-urban interface at Crescent Lake; 

208 acres of non-commercial fuels reduction; 169 acres 

of meadow enhancement; and access improvement for 

residence egress. 162 acres was in suitable northern 

spotted owl habitat. 

Implementation

Crown Pacific 

Land Exchange 

EIS (1998) 

Exchange of National Forest lands on 31, 256 acres for 

34, 319 acres of Crown Pacific land to consolidate land 

ownership and enhance long-term resource conservation. 

In the trade, the Forest Service acquired additional 

allocated Old Growth on 4,352 acres (most near the BLT 

area) and sensitive wetlands outside the BLT analysis 

area. 

Completed 

Davis Fire 

Restoration 

Project (2004) 

Salvage of burned trees on 3,785 acres for accelerating 

return of late-successional reserve characteristics and 

economic return in appropriate areas. 

Completed 

Danger tree 

removal (Annual) 

Removal of identified hazard trees along roads and in 

recreation areas and parking lots. Dependent upon the 

magnitude of disturbance events, an average year would 

fell 100 hazard trees or less district-wide per year. 

Ongoing 

5825 Fuel 

Reduction Project 

CE (2001) 

Fuel reduction activities including small diameter 

thinning, utilization of dead and down material, mowing, 

and underburning on 770 acres near and adjacent to the 

Two Rivers subdivision in the Wildland Urban Interface. 

Completed 

Five Buttes EIS 

(2007) 

4,235 acres of commercial thinning retaining the largest 

trees; 4,235 acres of fuels treatments associated with 

commercial harvest units; 3,931 acres of additional fuels 

treatments in units where commercial thinning will not 

take place. 

Implementation
Environmental Impact Statement BLT Project 

 Chapter 3 - Introduction 

49

Project/Event 

Name General Description of Activities Status 

Lakeside WUI CE 

(2008) 

Small tree thinning (to an upper diameter limit of 3 

inches) and fuels treatments in the wildland-urban 

interface on 640 acres. Prescriptions maintain suitable 

habitat for northern spotted owls. 

Implementation

Maintenance Burn 

CE (2005) 

Prescribed fire on 1,933 acres in appropriate stands to 

maintain and or restore fire in proper intervals. Implementation

(1997) Prescribed 

Underburning and 

Mowing Project 

CE 

2,553 acres of prescribed burning in appropriate areas 

and mastication of brush (mowing) on the southern half 

of the Crescent Ranger District, much that overlaps the 

BLT area. 

Implementation

Rosedell CE 

(2005) 

Commercial thinning and fuels reduction activities on 

166 acres in the wildland-urban interface around the 

town of Crescent and Odell Lake summer homes. 

Prescriptions maintain suitable habitat for northern 

spotted owls. 

Implementation

Seven Buttes 

(1996) 

Commercial understory thinning on 8,511 acres to lessen 

extent of disturbance events; 32 acres of regeneration 

harvest in stands where disease infestation precludes 

thinning options; and salvage of 1,149 acres of lodgepole 

pine. 3,341 acres was in suitable northern spotted owl 

habitat. 

Completed 

Seven Buttes 

Return (2001) 

Commercial understory thinning on 5,950 acres; small 

tree thinning on 230 acres for forest health, salvage of 

560 acres primarily in lodgepole pine. No activities 

occurred in suitable northern spotted owl habitat. 

Implementation

Small Tree 

Thinning (2008 

and annually) 

Thinning of small trees primarily in plantations on 2,590 

acres. Typically, a range of 2,000 to 3,000 acres of trees 

are annually thinned in this manner. 

Planning 

Spruce Creek 

Restoration CE 

(2007) 

100 acres of lodgepole pine thinning <3”dbh along 

Spruce Creek and an un-named tributary of Spruce 

Creek. 

Implementation

Travel 

Management Rule 

(expected 2009) 

Motorized travel in central Oregon would be restricted to 

designated trails, only. Planning 

Table 3-2. Sample of Projects and Rationale why they will not be discussed in Cumulative Effects 

Analysis 

Project Name Rationale for Exemption from Cumulative Effects Analysis 

Big Marsh Restoration 

Project Phase 2 

Meadow restoration; no overlap with scope of activities in the BLT 

project 

Charlie Brown EA (2000) Not relevant due to lack of spatial and temporal overlap. Northern 

spotted owl suitable habitat that was removed was included in 

environmental baseline disclosed in the BLT analysis. 

Greater La Pine 

Community Wildland 

Urban Interface project on 

Bureau of Land 

Management 

Not relevant due to lack of spatial proximity. 
BLT Project Environmental Impact Statement 

Chapter 3 - Introduction 

50

Project Name Rationale for Exemption from Cumulative Effects Analysis 

Trapper Creek Restoration 

Project (2000) 

Fish habitat restoration project with no overlap with scope of 

activities. 

Wickiup Acres Wildland 

Urban Interface (est. 2008) 

Not relevant due to lack of spatial proximity. 

Sun Forest Hazardous 

Fuels Reduction 

Not relevant due to lack of spatial proximity. 

Blowdown Salvage, South, 

and Pawn timber sales of 

the 1980s 

The objective for these activities was to capture economic value 

from dead and dying lodgepole pine and lower risk of a large 

disturbance in the area. The effects from the sales have diminished 

to the point where they are not quantifiable on a categorical basis. 

Disclosure of the existing condition for the zone of influence that 

overlaps these timber sales is included in the snags and down wood 

and forested vegetation sections in Chapter 3. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

51

Soil Quality _____________________________________ 

Introduction 

Forest soils are considered to be a non-renewable resource, as measured by human life spans, and 

maintenance or enhancement of soil productivity is an integral part of National Forest 

management. Therefore, an evaluation of the potential effects on soil productivity is essential for 

integrated management of forest resources. 

The long-term sustainability of forest ecosystems depends on the productivity and hydrologic 

functioning of soils. Ground-disturbing management activities directly affect soil properties, 

which may adversely change the natural capability of soils and their potential responses to use 

and management. A detrimental soil condition often occurs where heavy equipment or logs 

displace surface organic layers or reduce soil porosity through compaction. Detrimental 

disturbances reduce the soil’s ability to supply nutrients, moisture, and air that support soil 

microorganisms and the growth of vegetation. The biological productivity of soils relates to the 

amount of surface organic matter and coarse woody debris retained or removed from affected 

sites. 

Scope of the Analysis 

The soil resource may be directly, indirectly and cumulatively affected within each of the activity 

areas. For analysis of the soil resource, an activity area is defined as “the total area (unit) of 

ground impacted activity, and is a feasible unit for sampling and evaluating” (FSM , R-6 

supplement 2500-98-1 and Forest Plan, page 4-70 and 71, Table 4-30, Footnote #1). For this 

project proposal, activity area boundaries are considered to be the smallest identified area where 

the potential effects and soil quality standards would be focused on the units proposed for 

silvicultural and fuel reduction treatments. The activity areas range in size from about 5 to 277 

acres. 

Quantitative analyses and professional judgment were used to evaluate the proposed alternatives 

by comparing existing conditions to the anticipated conditions which would result from 

implementing the proposed actions. The temporal scope of the analysis is defined as short-term 

effects to soil properties that would generally revert to pre-existing conditions within 5 years or 

less, and long-term effects are those that would substantially remain for 5 years or longer. This 

analysis also considered the effectiveness and probable success in project design and 

implementation of the management requirements, mitigation measures, and Best Management 

Practices (BMPs) that are designed to avoid, minimize or reduce potentially adverse impacts to 

soil productivity. 

The following indicators were used to compare the alternatives: 

1. Change in the extent of detrimental soil conditions following proposed harvest and 

mitigation treatments within individual harvest units or other activity areas proposed for 

vegetation and fuel treatments. 

2. Amount of coarse woody debris (CWD) and surface organic matter that would likely be 

retained to protect mineral soils from erosion and provide short and long-term nutrient 

supplies for maintaining soil productivity on areas of activity. 

3. The probable success in project design and implementation of management requirements 

and mitigation measures that would be applied to minimize adverse effects to soil 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

52

productivity in the individual activity areas. Unit specific mitigation measures are found 

in Chapter 2 and BMPs can be found in Appendix A. 

Management Direction 

The Deschutes Land and Resource Management Plan (LRMP) specifies that management 

activities be prescribed to promote maintenance or enhancement of soil productivity by leaving a 

minimum of 80 percent of an activity area in a condition of acceptable productivity potential 

following land management activities. This is accomplished by following Forest-wide standards 

and guidelines to ensure that soils are managed to provide sustained yields of managed vegetation 

without impairment of the productivity of the land. Applicable Standards and Guidelines include: 

• SL-4, which directs the use of rehabilitation measures when the cumulative effects of 

management activities are expected to cause damage exceeding soil quality standards and 

guidelines on more than 20 percent of an activity area. 

• SL-5, which limits the use of mechanical equipment in sensitive soil areas. Operations 

would be restricted to existing logging facilities (i.e., skid trails, landings) and roads, 

whenever feasible. 

• SL-6, which provides ground cover objectives to minimize accelerated erosion rates on 

disturbed sites with unprotected soils. 

Guidelines (FSM 2500, R-6 supplement 2500-98-1) describe conditions detrimental to soil 

productivity and outlines Soil Quality Standards to limit the extent of these conditions to less than 

20 percent of an activity area. Detrimental soil conditions are described in the Soil Quality 

Standards as follows: 

• Detrimental soil compaction in volcanic ash/pumice soils is an increase in soil bulk 

density of 20 percent or greater over the undisturbed level. 

• Detrimental puddling occurs when the depth of ruts or imprints is six inches or greater. 

• Detrimental displacement is the removal of more than 50 percent of the A horizon from 

an area greater than 100 (10’ x 10’) square feet and at least 5 feet in width. 

• Detrimental burn damage requires significant color change of the mineral soil surface in 

an area greater than 100 (10’ x 10’) square feet to an oxidized reddish color, with the next 

one-half inch below blackened from organic matter charring as a result of heat conducted 

from the fire. 

• Detrimental erosion requires visual evidence of surface loss over an area greater than 100 

(10’ x 10’) square feet, rills or gullies, and/or water quality degradation from sediment or 

nutrient enrichment. 

The Forest Service Region 6 Supplement also includes policy direction for designing and 

implementing management practices which maintain or improve soil and water quality. An 

emphasis is placed on protection over restoration. Specifically, under 2520.3 – Policy, the 

narrative reads: 

 “When initiating new activities: 

• Design new activities that do not exceed detrimental soil conditions on more than 20 

percent of an activity area. This includes the permanent transportation system. 

• In areas where less than 20 percent detrimental soil conditions exist from prior activities, 

the cumulative detrimental effect of the current activity following project implementation 

and restoration must not exceed 20 percent. 

• In areas where more than 20 percent detrimental soil conditions exist from prior 

activities, the cumulative detrimental effects from project implementation and restoration 

must, at a minimum, not exceed the conditions prior to the planned activity and should 

move toward a net improvement in soil quality.” 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

53

This Regional policy is consistent with the LRMP interpretation of Forest-wide standards and 

guidelines SL-3 and SL-4, on file at the Crescent Ranger District office. 

Target Landscape Condition 

The primary goal for managing the soil resource is to maintain or enhance soil conditions at 

acceptable levels without impairment of the productivity of the land. The extent of detrimental 

soil disturbances is minimized through the application of project design criteria, management 

requirements and mitigation measures designed to minimize, avoid or eliminate potentially 

significant effects, or rectifying effects in site-specific areas by restoring the affected 

environment. The land effectively takes in and distributes water, and erosion rates are controlled 

to near-natural levels. The biological productivity of soils is ensured by management 

prescriptions that retain adequate supplies of surface organic matter and coarse woody debris 

without compromising fuel management objectives. 

Affected Environment and Existing Conditions 

The BLT analysis area covers approximately 80,000 acres in the High Cascade physiographic 

area, where essentially all landforms, rocks, and soil are products from volcanic events or from 

glaciations that occurred as recently as ten thousand years ago. The landscape is generally 

characterized by smooth, nearly level glacial moraines and outwash plains, gentle to uneven lava 

plains with a few cinder cones and buttes. Muttonchop Butte, Little Odell Butte, and Beales 

Butte are cinder cones; these are areas of relief on which a few slopes are greater than 30 percent. 

The major landform in the analysis area is the Little Deschutes Canyon. This canyon is the 

longest and the deepest on the east flanks of the High Cascades. The highest point in the analysis 

area is Miller Mt., with an elevation of approximately 7,513 ft, and the lowest point is 4,330 feet 

at the confluence of Little Deschutes River and Crescent Creek. The majority of the slopes in the 

analysis area range between 5 and 25 percent. 

The eruption of Mt. Mazama 7,700 years ago covered the area with ash and pumice to depths up 

to ten feet (SRI 1976). The rhyolitic Mazama ash and pumice fall is relatively coarse textured 

and undeveloped due to a young age of 7,700 years. Surface and subsurface textures range from 

coarse sand to small gravel sized material. Surface mineral A horizons are generally less than 3 

inches thick, with a shallow A/C horizon of less than 10 inches in thickness. C horizon material 

varies from 20 to 40 inches thick before the slightly more developed buried soil is reached. 

Higher bulk densities and coarse fragment contents are the most distinguished features of the 

residual buried soils. Soil moisture regimes are xeric in the basin and the eastern edges of the 

area and ustic in the higher elevation sections. Soil temperature regimes range from frigid to 

cryic. 

The Soil Resource Inventory (SRI, 1976) is the only mapped coverage of soils within the analysis 

area. This survey was conducted as a broad scale mapping of soil types across the Deschutes 

National Forest and includes basic soil information and interpretations. The BLT analysis area 

contains 39 landtype units based on similarities in landforms, geology, and climatic conditions 

that influence defined patterns of soil and vegetation. The biophysical characteristics of these 

landtype units can be interpreted to identify hazards, suitability, and productivity potentials for 

natural resource planning and management (see Table 3-3 for specific characteristics of each soil 

type and percentage of each type in the BLT analysis area). 

 

Soils within the analysis area have developed under the influence of local geologic parent 

materials, topography, annual precipitation, and associated vegetative communities. Soil types 

within the analysis area located on the slopes of the larger buttes are primarily comprised of a 

deep mantle of ash, pumice fall from Mt. Mazama over an older paleosol derived of airfall ash, 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

54

and basaltic residuum (weathered in place). A deep mantle of ash and pumice fall also overlies 

an older soil located above glacial outwash within the La Pine Basin. 

 

Soils derived from Mazama ash tend to be non-cohesive (loose) and have very little structural 

development due to their young geologic age. Dominant soils in the analysis area have naturally 

low bulk densities and low compaction potential. However, mechanical disturbances can reduce 

soil porosity to levels that limit vegetative growth, especially where there is a lack of woody 

debris and surface organic matter to help cushion the weight distribution of ground-based 

equipment. Dominant soils in the analysis area are not susceptible to soil puddling damage due to 

their lack of plasticity and cohesion. 

Soil displacement is one of the most readily recognized problems associated with pumice soils. 

Detrimental soils displacement is defined by the Forest Service Manual, R-6 Supplement No. 

2500.98-1, 2521.03, 3, “detrimental displacement is the removal of more than 50 percent of the A 

horizon from a area greater than 100 square feet. The surface layers are easily removed by 

mechanical activity exposing light-colored material. The maneuvering of equipment is most 

likely to cause soil displacement damage on the steeper landforms. On gentle to moderately 

sloping terrain, moving of equipment generally does not detrimentally remove soil surface 

layers.” 

The absence of rock fragments on the surface and within soil profiles makes these soils well 

suited for tillage treatments (subsoiling). Tillage will loosen compacted soil layers and improve 

the soil’s ability to supply nutrients, moisture, and air that support vegetative growth and biotic 

habitat for soil organisms. 

The dominant landtypes within the analysis area exhibit high water infiltration rates and are 

classified as well to excessively drained. Surface soils are ash fall, pumeceous loamy sands and 

sands. Permeability is very rapid in surface soils and moderate to rapid in the buried soils. Some 

of these soils (SRI 02, 05, 43, WE, and WH) have a water table that can be encountered within 

two to five feet from the surface - typically near valley bottoms. There are landtypes that occur 

as a result of ash and pumeceous deposits on top of glacial outwash plains. These landtypes have 

somewhat poorly drained soils and are usually associated high water tables. Underlined bedrock 

in the planning area is mostly basalts and andesites that have a high to moderate capacity to store 

water and a low to moderate rate of water transmission unless storage capacity is exceeded. 

Table 3-3 displays the SRI polygons that occur in the BLT analysis area and their key 

interpretation. An asterisk (*) denotes sensitive soils. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

55

Table 3-3. SRI Mapping Unit Interpretations and Amounts of Each Soil Type in the BLT 

Analysis Area 

Mapping 

Unit* 

% 

Slope 

Natural 

Stability 

Surface 

Erosion 

Potential 

Compaction 

Potential 

Displacement 

Potential 

Sediment 

Yield 

Potential 

Acres 

% of 

Land 

scape 

01 0-30 Very 

Stable N/A N/A N/A N/A 218.0 0.27 

02* 0-50 

Occasional 

small 

slumps 

Moderate Moderate Moderate Moderate 

to Low 190.1 0.24 

03 40-100 Stable Moderate N/A NA Moderate 

to Low 246.6 0.31 

05* 0-10 Very 

Stable Low Moderate Low LowModerate 1,048 1.31 

06* 30-80 Moderatel

y Stable 

ModerateHigh Low Low LowModerate 839.3 1.05 

09* 25-70 Stable Low Low High Low 44.2 0.06 

12* 20-70 Stable Moderate Low High to 

Moderate Moderate 279.3 0.35 

2B 0-30 Very 

Stable 

LowModerate LowModerate LowModerate Low 2,931.2 3.66 

43* 0-5 Very stable Low High Low LowModerate 2,564.5 3.20 

5A* 30-80 Stable High Low High Moderate 388.5 0.49 

81* 25-70 Stable Moderate Low High LowModerate 26.9 0.03 

84* 30-8- Stable LowModerate Low High LowModerate 83.1 0.10 

8A* 30-70 Stable LowModerate Low High Moderate 37.5 0.05 

8P* 25-65 Stable Moderate Low High Low 59.6 0.07 

96 0-30 Very 

Stable Low Low LowModerate Low 22,597.8 28.23 

97 0-30 Very stable Low Low Moderate Low 4,497.2 5.62 

98 0-30 Very 

Stable Low Low Moderate Low 284.8 0.36 

9B* 30-70 Stable ModerateHigh Low High LowModerate 906.3 1.13 

9C* 30-70 Stable ModerateHigh Low High LowModerate 1109.4 1.39 

9F 0-30 Very 

Stable 

LowModerate LowModerate LowModerate Low 2,529.8 3.16 

9K 0-30 Very 

Stable Low Low Moderate Low 1,861.8 2.33 

9L 0-30 Very 

Stable Low Low Moderate Low 12,193 15.23 

9M 0-30 Very 

Stable 

LowModerate Low Moderate Low 3,493.4 4.36 

9N* 30-70 Stable ModerateHigh Low High LowModerate 3,046.4 3.81 

9P* 30-70 

Moderatel

y Stable to 

Unstable 

High to 

Moderate Low High LowModerate 2,117.8 2.65 

9R* 30-70 Moderatel

y Stable 

High to 

Moderate Low High LowModerate 1,272.8 1.59 

9T* 25-60 Moderatel

y Stable 

ModerateHigh Low High LowModerate 683 0.85 

9W* 0-30 Very 

Stable Low Low Moderate Low 1,559.1 1.95 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

56

Mapping 

Unit* 

% 

Slope 

Natural 

Stability 

Surface 

Erosion 

Potential 

Compaction 

Potential 

Displacement 

Potential 

Sediment 

Yield 

Potential 

Acres 

% of 

Land 

scape 

9Y 10-40 Moderatel

y Stable Moderate Low Moderate LowModerate 627.5 0.78 

9Z* 30-70 Stable Moderate Low High LowModerate 339.1 0.42 

PC* 20-70 Stable High to 

Moderate Low High Moderate to Low 628.5 0.79 

PG 0-30 Very 

Stable 

LowModerate LowModerate LowModerate Low 5,734.1 7.16 

PH* 0-30 Very 

Stable Low LowModerate 

LowModerate Low 116.6 0.15 

PK 0-30 Very 

Stable Low Low LowModerate Low 231.7 0.29 

PN* 0-70 Stable Low-High Low ModerateHigh 

LowModerate 702.3 0.88 

PP* 0-70 Very 

Stable 

High to 

Moderate Low LowModerate 

LowModerate 337.8 0.42 

WE* 0-5 Very 

Stable 

LowModerate Low-High LowModerate Low 121 0.15 

WH* 0-10 Very 

Stable 

LowModerate ModerateLow LowModerate LowModerate 3691.9 4.61 

Erosional Processes 

Erosion is a function of many soil and environmental factors that affect soil particle detachment 

and movement by runoff water. The severity of soil erosion depends on many factors, including 

slope gradient, inherent soil erodability, the amount of bare ground, and the intensity of 

precipitation events. All soils are susceptible to soil movement whenever rainfall intensities or 

snowmelts are great enough to cause overland flow. On undisturbed sites with gentle slopes, 

surface erosion occurs at naturally low rates because soils are protected by vegetation and organic 

litter layers. Accelerated erosion occurs at a rate greater than natural, which is usually associated 

with disturbances that reduce vegetative cover, displace organic surface layers, or reduce soil 

porosity through compaction (or increase runoff through upslope roads, compaction). Steep 

slopes with sparse vegetation generally have greater amounts of surface runoff which increases 

the erosion potential. Due to the lack of structural development, volcanic ash-influenced soils are 

easily eroded where water becomes channeled on disturbed sites such as road surfaces, skid trails, 

water-bar outlets, and road drainage structures. 

Inherent erosion hazard is a relative rating for surface erosion based on the ability of the soil to 

take in water, resistance of the soil surface to the effect of rainfall and water movement, and the 

effect of topography or slope gradient. The rating for surface erosion potential assumes that the 

surface cover of vegetation or litter has been disturbed or destroyed and bare surface soils are 

exposed to the elements of erosion. The following ratings are intended for planning purposes to 

indicate relative potential erosion hazards. 

Low: Soils are generally on gentle to moderate slopes with no appreciable hazard for 

erosion. 

Moderate: Some loss of surface materials can be expected, but soils are sufficiently 

resistant to erosion to permit limited and temporary exposure of bare soil during 

development or use. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

57

High: Considerable loss of surface materials can be expected. Unprotected soils will 

erode sufficiently to severely damage productivity. 

Severe: Large loss of surface soil material can be expected, with severe damage to soil 

productivity. 

There are sensitive soils with high to moderate erosion hazards within the analysis unit areas 

Table 3-5). Identified in Table 2-2 in Chapter 2 for advanced logging systems, these areas where 

the majority of the unit is greater than 30 percent would have restrictions on mechanized 

equipment. These soils consist of moderately deep pumice soils on slopes greater than 30 

percent. Steep areas are much more susceptible to accelerated soil erosion during high-intensity 

rainfall events. 

In addition, the Deschutes LRMP Standard and Guideline SL-6 (page 4-70 and 4-71) provides 

ground cover objectives to minimize accelerated erosion rates on disturbed sites with unprotected 

soils. Effective ground cover includes all living or dead herbaceous or woody materials and rock 

fragments greater than three-fourths (3/4) of an inch in diameter in contact with the ground 

surface, including trees or shrub seedlings, grass, forbs, litter, and woody biomass. Effective 

ground cover is measured as a percent of natural conditions for representative soils and landtypes. 

In order to minimize soil erosion by water or wind, the following ground cover objectives should 

be met within the first two years after completion of ground-disturbing management activities. 

Table 3-4. Minimum Ground Cover Objectives to Minimize Soil Erosion by Water and 

Wind 

Minimum Effective Ground Cover 

(Percent of Existing Background Levels)

Surface Soil Erosion Potential 

(Deschutes Soil Resource 

Inventory) 1st Year 2nd Year 

Low 20 - 30 31 – 45 

Moderate 31 – 45 46 – 60 

High 46 – 60 61 – 75 

Severe 61 - 75 76 – 90 

Land Suitability and Inherent Soil Productivity 

The suitable lands database for the Deschutes National Forest LRMP identifies areas of land 

which are considered to be suitable for timber production using criteria affecting reforestation 

potential (FSH 2409.13). This data was developed to designate a broad-scale timber base area for 

forest-wide planning purposes. Project level planning requires that lands proposed for harvest 

have their suitability verified based on the criteria outlined in the Forest Service Handbook (FSH 

1909.12). Forest Service Handbook 1909.12 requires project analysis and decision to determine 

suitability for acres proposed to harvest. A March 3, 1992 letter of direction for the Deschutes 

National Forest outlines a process to follow criteria for tracking refinements to the unsuitability 

lands data base. It does not require a Forest Plan amendment for each and every single 

determination. The process outlined by the Forest is a cumulative process and tracked by Land 

Management Planning to revise the Plan when the Forest Supervisor deems it necessary. 

The productivity of forest soils can be measured as the Cubic Foot Site Class (Mean Annual 

Increment in cubic feet/year) for primary tree species growing on undisturbed or minimally 

disturbed sites. These volume indices provide valuable baseline information regarding soil 

productivity potential for each soil type in the Deschutes SRI (Soil Resource Inventory, 1976). 

Site classes on the Deschutes National Forest range from Very Low (Site Class 7) to High (Site 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

58

Class 4). Soil types having Site Class 7 are considered unsuited for forest production because the 

mean annual increment is generally less than 20 cubic feet per year. All lands proposed for active 

management in the BLT analysis area are classified “suitable”. 

Sensitive Soil Types 

Criteria for identifying soils sensitive to management are listed in the Deschutes LRMP 

(Appendix 14, Objective 5). Sensitive soil types include: 

• Soils on slopes over 30 percent, 

• Slopes with a high hazard rating for surface erosion, 

• Potentially wet soils with seasonal or year-long high water tables; and 

• Soils associated with frost pockets in cold air drainages and basins 

Approximately 54 percent (43,390 ac) of the analysis area contains landtypes with localized areas 

of sensitive soils (Table 3-5). Areas of sensitive soils are typically confined to specific segments 

of the dominant landform and they are generally too small to delineate on maps. It is 

emphasized that only portions of these total landtype acres actually contain sensitive soils. 

Table 3-5. Land type acres that contain localized areas of sensitive soils within the BLT 

Analysis Area (Soil Resource Inventory, Deschutes National Forest, 1976) 

SRI Map Unit 

Symbol

Geomorphology 

(Representative landforms) 

Type of 

Concern9

Land type 

Acres

01,06, 09, 12, 5A, 

81, 84, 8A, 9B, 9C, 

9N, 9P, 9R, 9T, 9Z, 

PC, PN, PP 

Cinder cones, high elevation rock, 

lava flows, outcrops, composite 

volcanoes (30 percent slope), 

high or extreme erosion hazard. 

1, 4 13,060 

96, PH Depressions or flats 2 22,714 

02, 05, 43, WE, 

WH Seasonal high water table 3 7,615 

Figure 3-1 displays sensitive soils overlaid with proposed harvest units and Table 3-5, displays 

acres of sensitive soils in each proposed harvest unit. These site-specific conditions were 

determined using Geographical Information Systems and field verified. 

Advance harvest systems such as skyline or helicopter would be required on slopes greater than 

30 percent unless the unit contains a steep pitch (slopes of 30 percent or steeper) less than 100 

feet long. In that case, equipment would be permitted to make one pass out and one pass back to 

harvest trees (Project Design Features, Chapter 2). Advanced harvest systems on these steeper 

slopes are prescribed to reduce potential for soil displacement and erosion by reducing 

disturbance. It is assumed and has been observed the effects to these types of sensitive soils using 

an advance harvest system would be much less than ground-based harvest systems. 

Seasonally or permanently wetted soils have been avoided altogether in project design. For frost 

pockets, they are only considered a sensitive soil type because of difficulty associated with tree 

 9 Management Concerns

1. On slopes greater than 30 percent, loose sandy soils are susceptible to soil displacement 

2. Very low productivity due to frost heaving, low fertility, and temperature extremes 

3. Seasonal high water tables 

4. High or extreme erosion hazard 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

59

regeneration. Since there are no harvest prescriptions proposed in BLT that require tree 

regeneration, there is no further need to address this aspect of sensitive soils. 

Detrimental Soil Disturbance 

To estimate soil conditions within the analysis area, the following resources were utilized: 

Geographical Information System (GIS), aerial photos, field reconnaissance, best available 

research, past monitoring of logging systems on the Deschutes National Forest, and personal 

communication with Timber Sale Administrators and other district personnel. GIS analysis 

utilized the soil resource inventory and past harvest data to determine the location and extent of 

soil effects and existing conditions. 

Natural Events 

Mass movements, or landslides, occur when earthen materials become unstable and slide 

downslope in response to gravity. There are no management-related landslides known to exist 

within the activity areas. The high permeability of the pumice and ash-influenced soil materials 

generally precludes the buildup of hydraulic pressures that could trigger landslides. 

Management-Related Disturbances 

Timber Management 

Based on harvest history, various silvicultural prescriptions including thinning treatments, 

intermediate harvest, and regeneration harvest have occurred within the analysis area between 

1950 and the present. Temporary roads, log landings, and primary skid trails were constructed 

and used to access individual harvest units of past timber sales. Research studies and local soil 

monitoring have shown that soil compaction and soil displacement account for the majority of 

detrimental soil conditions resulting from ground-based logging operations (Deschutes N.F. Soil 

Monitoring Reports; Page-Dumroese 1993). Some long-term adverse effects to soil productivity 

still exist where surface organic layers were displaced and/or multiple equipment passes caused 

deep compaction. 

The previous use of ground-based harvest activity has been identified to have disturbed soils on 

approximately 35 percent (27,711 acres) of the BLT analysis area. Much of the random 

disturbance between main skid trails and away from landings has decreased naturally over time. 

Research has shown that the detrimental effects of soil compaction generally require more than 3 

to 5 equipment passes over the same piece of ground (McNabb and Froehlich, 1983). Where logs 

were skidded with only 1 or 2 equipment passes, soil compaction was shallow (2 to 4 inches) and 

the bulk density increases did not qualify as a detrimental soil condition. It is expected that soils 

in these areas have returned to undisturbed density levels in the short-term (less than 5 years) 

through natural processes (i.e., root penetration, frost heave, rodent activity, freeze-thaw and 

wetting drying cycles). The establishment of ground cover vegetation and accumulation of 

organic matter has been improving areas of past soil displacement. 

Roads 

GIS information was used to estimate the current road densities to assess the amount of soil 

compaction as a result of roads in the planning area. Roads are grouped into three categories by 

size and maintenance level. Average road widths were determined after personal communication 

with the District Road Maintenance Engineer. Table 3-6 summarizes road types and contains the 

equations that were used to estimate acres of road per mile. 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

60

Table 3-6. Road Categories and Determination of Respective Detrimental Soil Condition 

Road 

Type 

Description Equation Used to Determine Amount of Detrimental 

Soil Condition 

Arterial Main road 1 mi. (5280 ft) x 20 ft. wide / 43,560 sq. ft./ac. 

Collector Secondary road 1 mi. (5280 ft) x 14 ft wide / 43,560 sq. ft. /ac. 

Local Tertiary road 1 mi. (5280 ft) x 12 ft/ 43,560 sq. ft. /ac. 

The planning area contains approximately 296 miles (502 acres) of system roads. Segments of 

these existing roads cross through portions of activity areas proposed for treatment. Existing 

roads classify the area of disturbance as non-productive. Most of the precipitation that falls on 

compacted road surfaces is transmitted as surface runoff, and roads are primary sources of 

accelerated surface erosion. The amount of detrimentally disturbed soil committed to existing 

roads is included in the estimated percentages displayed in Tables 3-10, 3-14, and 3-18. 

Recreation Activities 

Effects from dispersed recreation activities are usually found along existing roads, trails and 

along streams. The extent of detrimental soil conditions associated with recreation use is 

relatively minor in comparison to existing roads and past logging disturbances. There are no 

developed recreation sites and only two dispersed recreation sites that overlap proposed harvest 

units. There are snowmobile trails that are located on adjacent roads associated with units. The 

assumption is that there is no detrimental soil disturbance caused by snowmobiles; therefore, they 

have not been included in the road calculations for disturbance. 

The actual area of overlap within units is so minor it is assumed dispersed recreational use does 

not have an additive effect on overall site productivity within the individual activity areas 

proposed for this project. 

There is a small amount (less than 1 percent of the planning area) of Off Highway Vehicle (OHV) 

use in the area, primarily originating from the Two Rivers Subdivision north, in the Mowich mill 

site. The main use of the user-created trail system is away from riparian vegetation and on 

existing roads. Occasionally, in order to connect between roads, or to access areas on nearby 

Mutton Chop Butte to experience challenge, the trail system utilizes areas such as skid trails and 

closed roads that have been accounted for in the existing condition description in this section. 

There is no known OHV use that overlaps any activity areas planned within the BLT project. 

Livestock Grazing 

There has been no grazing in the planning area since 1994. Residual effects from livestock 

grazing to the soil resource are mainly in localized areas of past concentrated use, such as around 

cattle watering developments. Detrimental soil conditions from grazing have been reduced and 

likely eliminated by natural processes such as frost heaving. Therefore, effects of past grazing 

allotments have not been included in Tables 3-10, 3-14, and 3-18. 

Coarse Woody Debris (CWD) and Surface Organic Matter 

The effects of management activities on soil productivity also depend on the amount of coarse 

woody debris (CWD) and surface organic matter retained or removed on affected sites. Decaying 

wood on the forest floor is critical for maintaining the soil’s ability to retain moisture and provide 

both short and long-term nutrient supplies for the growth of vegetation. Mycorrhizal fungi and 

soil organisms depend upon the continuing input of woody debris and fine organic matter. The 

requirement of logging over snow or frozen ground will be applied to most of the units that have 

known populations of matsutake mushrooms. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

61

Summary 

The existing condition of the soil resource mainly has been influenced by the transportation 

system and ground-based logging facilities used for harvest in past timber sales. Most projectrelated impacts to soils occurred on and adjacent to heavy-use areas such as skid trail systems, log 

landings, and roads that were used for access in past timber sale units. The extent of 

detrimentally disturbed soil associated with other land uses is relatively minor in comparison. 

In activity areas (units) proposed in Alternative B, there are 925 acres of soil classified as existing 

detrimental. There are 703 acres of classified detrimental soils in Alternative C units, and 166 

acres of detrimental soils in Alternative D. All ground disturbance such as roads, recreation and 

past harvest activities are considered in these totals. Existing detrimental soil conditions within 

proposed activity units in the BLT analysis area are summarized in Tables 3-10, 3-14, and 3-18. 

Environmental Consequences 

Alternative A

Under Alternative A (No Action), no active management with potential for directly affecting soil 

quality would take place. 

Indicator #1: Detrimental Soil Disturbance 

Under Alternative A, no additional land would be removed from production. There would be no 

cumulative increase in detrimental soil conditions above current levels. Implementation of 

project design criteria and mitigation measures would not be necessary. 

Although disturbed soils would continue to recover naturally from the effects of past 

management, the current percentages of detrimental soil conditions would likely remain 

unchanged for an extended period of time. This alternative would defer opportunities for soil 

restoration treatments that reduce existing impacts and help move conditions toward a net 

improvement in soil quality. 

Soil productivity would not change appreciably although this alternative has the greatest 

likelihood of a stand replacement event with potential for altering soil productivity from groundlevel heating. A recent wildfire event (Davis Fire) did not appreciably alter soil productivity (less 

than 10 percent) due to conditions present at the time of the ignition. However, wildfire can 

change soil properties, typically resulting result from extreme surface temperatures of long 

duration, such as the consumption of large diameter logs on the forest floor. Although hazardous 

fuels have been reduced in some previously managed areas in the BLT area, fire exclusion has 

resulted in undesirable vegetation conditions and excessive fuel loadings in other portions of the 

analysis area (Forested Vegetation and Fire and Fuels Management, Chapter 3). If a large 

amount of fuel is present during a wildfire, soil temperatures can remain high for an extended 

period of time. Excessive soil heating would be expected to produce detrimental changes in the 

chemical, physical and biological properties of burned soils. Severe burning may cause soils to 

repel water, thereby increasing surface runoff and subsequent erosion. The loss of protective 

ground cover would increase the risk for accelerated wind erosion on the loose, sandy-textured 

soils found throughout the analysis area. 

Indicator #2: Coarse Woody Debris and Surface Organic Matter

Currently, in ponderosa stands there is an estimated 31.2 tons/ac course woody material in all size 

classes, in mixed conifer there is an estimated 25.8 ton/ac, and in lodgepole pine stands there is an 

estimated 19 ton/ac. In the short term, the amount of coarse woody debris (CWD) and surface 

litter would gradually increase or remain the same. In forested areas, coarse woody materials will 

continue to increase through natural mortality, windfall, and recruitment of fallen snags over 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

62

time. Short-term nutrient sources will also increase through the accumulation of small woody 

material from shrub and tree branches, annual leaf and needle fall, and decomposition of grass 

and forb materials. 

In the long term, the accumulation of CWD and forest litter would increase the potential for 

intense wildland fires which may completely consume heavy concentrations of fuel and ground 

cover vegetation. High to extreme fire hazard and potential for excessive soil heating exists when 

downed woody debris exceeds 30 to 40 tons per acre (Brown et al., 2003). With this much fuel 

loading, intense ground-level fire would likely create areas of severely burned soil and increase 

the potential for accelerated erosion. The loss of organic matter would adversely affect ground 

cover conditions and the nutrient supply of affected sites. 

Indicator #3: Project Design, Management Requirements and Mitigation Measures 

Under Alternative A, no Project Design Features or Mitigation Measures would be necessary. 

This indicator is not applicable to Alternative A. 

Effects Common to All Action Alternatives (Alternatives B, C, and D) 

The following section provides a discussion of the potential effects on soil physical properties and 

biological conditions from implementing the various vegetation and fuel reduction activities 

proposed under the action alternatives. 

Proposed units for each alternative have been overlaid with past harvest areas to identify areas of 

potentially unacceptable detrimental soils conditions. Aerial photos, scale 1:12000, were used to 

refine the location of overlap between past and proposed treatment units. Research by Froelich 

(1981) and Garland (1983) was used to estimate soil compacted areas on flat ground, in small 

timbered stands using tractor logging systems. Communication with District Sale Administrators 

was used to validate this research and insure site-specific conditions were considered. Other 

district personnel that had information about historical and current logging activities were also 

consulted. Past monitoring and field reconnaissance were used to insure assumptions made were 

within acceptable limits. This analysis also considered the effectiveness and probable success of 

implementing the management requirements, mitigation measures, and Best Management 

Practices (BMPs) which are designed to avoid, minimize or reduce potentially adverse effects to 

soil productivity. 

Forest monitoring has shown that soil disturbance increases with each management entry that is 

accomplished using mechanical equipment. The amount of additional soil disturbance depends 

on existing soil condition and whether the previous logging systems can be utilized (landings and 

skid trails), type of equipment used, and type of management activity. The types of activities that 

have the most potential for affecting soil quality in this project are commercial thinning, tree 

removal, utilization of forest products (post and pole, biomass), machine piling or burning of 

slash. 

This analysis assumes activities such as commercial harvest, fuels reduction and slash-disposal 

activities would occur on existing soil detrimentally affected areas as much as possible. Units 

where machine grapple piling would be used during post harvest operations would have traffic 

limited to operating areas previously detrimentally disturbed such as skid trails and landings. 

Prescribed underburning would be utilized in the appropriate areas. 

The potential for detrimental changes to soil physical properties was quantitatively analyzed by 

the extent (surface area) of temporary roads, log landings and designated skid trail systems that 

would likely be used to facilitate yarding activities within each of the proposed activity areas. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

63

Factors used to evaluate changes to soil productivity include the amount and composition of 

coarse woody debris, surface cover from organic matter, habitat for soil biological activity, and 

nutrient reservoirs. 

Ground-based Harvest and Assumptions/Methodology 

The following rationale was applied in calculating detrimental effects displayed in Tables 3-10, 3-

14, and 3-18. Research by Froelich (1981) and Garland (1983) suggest that the area of a unit with 

compacted soils is in direct relation to the skid trail spacing. On flat ground, patterns of skid 

trails are generally parallel, with the exception of landings where skid trails come together. 

Spacing of skid trails corresponds to the year the logging activity occurred. Logging activities 

that occurred prior to 1990 had closer spacing because logging contractors had fewer restrictions 

on their activity. These are estimated to be 50 feet apart and 12 feet wide (personal 

communication with sale administrator Linda Fitzer). This results in an estimated 20 or greater 

percent of the total unit area being disturbed or in a detrimental state. In the early 1990s, with the 

establishment of Forest Plan Standards and Guidelines that changed management practices, skid 

trail spacing increased to 75 feet with a corresponding 14 percent soil compaction in the unit area. 

Since 1994, main skid trails have typically been spaced 100 feet apart, which represents an 

average of 11 percent compacted area in the harvest unit. When predicting detrimental conditions 

where slopes are less than 30 percent, the development and use of new logging facilities would 

result in compaction of approximately 13 percent of the harvest unit area (11 percent in skid trails 

plus 2 percent in log landing). Note: The worst case scenario was accounted in estimating 

ground-based detrimental effects to the soil. However, in those units prescribed for harvest over 

snow or frozen ground to protect matsutake production, these estimates would be very 

conservative and the actual effects would likely result in less detrimental soil conditions. 

In areas where the slopes are less than 30 percent and to conservatively account for predicted 

effects of mechanical entry, a factor of 7 percent was used to predict detrimental soil conditions. 

The rationale for this percentage is because existing landings and skid trails would be utilized 

when possible, and monitoring on the forest (Craigg, 2000) has estimated anticipated increases in 

soil disturbance to be between 5 and 10 percent. In addition, in previously managed stands, past 

skid trail spacing and harvest intensity was also factored in; for this, the assumptions were 17 

percent for thinning prescriptions, 23 percent for partial removal, and 29 percent for regeneration 

harvest. These percentages can vary within units. For example, there are no units in BLT that 

completely overlap a previously regenerated area. Therefore, the percentages used reflect the 

appropriate portion. It is acknowledged that these estimates are conservative and do not account 

for natural processes that reverse detrimental conditions over time. 

Cable or Helicopter Logging

Research has shown that approximately 4 to 9 percent of an activity area will have detrimental 

soil effects (compaction or displacement) when skyline or helicopter logging is implemented 

(Clayton 1990). A skyline or helicopter logging system that can achieve partial to full suspension 

of logs during inhaul yarding operations would minimize soil disturbance. To be conservative, 

estimates of soil disturbance assume 8 percent of each unit that is skyline or helicopter logged 

would have detrimental disturbance; this disturbance area includes landings and temporary roads. 

This amount is included in the estimates of detrimental soil conditions displayed in Tables 3-10, 

3-14, and 3-18. 

Landings 

Based on communication with the Forest Service Representative (Linda Fitzer) and personal 

observation, landings for ground based tractor logging usually measure 100 feet by 100 feet at a 

density of one landing per ten acres. This equates to approximately 2 percent of the harvest unit. 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

64

This amount is included in the estimates of detrimental soil conditions displayed in Tables 3-10, 

3-14, and 3-18. 

Forest Product Removal 

Monitoring and professional experience were the basis for estimating the percent of the area for 

additional soil disturbance associated with removal of forest products. Post-harvest fuel 

treatment may be accomplished using machinery or prescribed burning operation to dispose of 

unwanted slash. 

Removal of special forest products such as firewood, post and pole, or some form of biomass 

usually requires equipment that results in a greater footprint on the ground in addition to large 

commercial operations. Existing skid trails would be utilized where possible. Skid trails remain 

100 feet apart; however, more off-trail travel may be necessary because of the number of pieces 

to be picked up. To be conservative in this estimate, it is assumed 10 percent of the area would 

have additional detrimental soil disturbance, in order to allow for a range of methods and 

equipment (such as pickup trucks and home-made skidders). This amount is included in the 

estimates of detrimental soil conditions displayed in Tables 3-10, 3-14, and 3-18. 

Grapple Piling

The action alternatives include grapple piling on all the tractor harvest units. Alternative B has 

approximately 6,666 acres that would be grappled, Alternative C - 5,047 acres, and Alternative D 

- 2,227 acres. Grapple operations would be restricted to existing roads, landings and skid trails 

(Project Design Features, Chapter 2). For this reason, it has not been included in the estimates of 

detrimental soil conditions displayed in Tables 3-10, 3-14, and 3-18. 

Prescribed Burning 

Under typical conditions, underburning has no effect to the productivity of soils. Typical 

prescribed burn conditions that protect soil productivity are: 

• Prescribed underburning occurs in the early spring or late fall when air temperatures are 

cool and when fuels have sufficient moisture to burn under relatively cool conditions. 

These types of burns can be categorized as light to moderate burns. 

• In light to moderate burns, the surface duff layer is charred and partially consumed. 

• Large logs may be deeply charred but mineral soil under the ash is not appreciably 

changed in color. 

• Underburning is accomplished using controlled methods with specific prescriptive 

conditions. 

• Duff, organic matter and large logs are retained to the greatest extent possible. 

• If natural barriers are not available, a handline is sometimes utilized to protect some 

resources; this causes some soil displacement, but not enough to be considered 

detrimental. 

In addition, detrimental burn damage requires significant color change of the mineral soil surface 

in an area greater than 100 (10’ x 10’) square feet to an oxidized reddish color. Handpiles do not 

have sufficient size or heat pulse to considerably alter the soil properties under the pile. Further, 

retention of organic matter is likely. 

For these reasons, prescribed underburning and handpile burning have not been included in the 

estimates of detrimental soil conditions displayed in Tables 3-10, 3-14, and 3-18. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

65

“Fuels Only” Activities outside Harvest Units 

The action alternatives include areas where fuels activities are proposed and the emphasis for 

utilization would be for special forest products such as post and poles, biomass, and firewood. 

The fuels vegetative prescription includes small diameter thinning up to 8 inches in diameter, 

removal of lower limbs (pruning), utilization, then handpiling and disposal. All activities would 

be non-mechanical except for the special forest product removal. In this case, mechanical 

equipment would only be allowed on existing areas considered in a detrimental condition such as 

existing skid trails and landings that have not been rehabilitated. Also, handpiling does not 

considerably alter soil properties. For these reasons, this activity is not included in the 

calculations for detrimental soil conditions as displayed in Tables 3-10, 3-14, and 3-18. 

Soil Restoration 

Extensive areas of soils within the analysis area are covered by loose, non-cohesive ash deposits 

that consist of sandy textured soils with little or no structural development. Mechanized 

equipment has the potential to decrease soil porosity and increase soil strength; however, 

compacted sites can be mitigated by subsoiling with a winged subsoiler (Powers, 1999). 

Dominant soils within the proposed activity areas are well suited for tillage treatments due to 

their naturally low bulk densities and the absence of rock fragments within soil profiles. 

Soil restoration (subsoiling) is used to mitigate Forest and Regional thresholds for compaction 

specified under the heading “Management Direction” for soil quality. It has been implemented 

on the Crescent Ranger District with success due to the absence of rock fragments on the surface 

and within soil profiles. Most surface organic matter remains in place because the equipment is 

designed to pick up the soil and drop it in the same place to loosen the compacted soils. The tines 

are adequately separated and have enough clearance between the tool bar and the ground, thereby 

allowing smaller slash materials to pass through without building up. Mixing of soil and organic 

matter does not cause detrimental soil displacement because these materials are not removed off 

site. Restoration treatments likely improve subsurface habitat by restoring the soils ability to 

supply nutrients, moisture, and air that support soil microorganisms. Since the winged subsoiler 

produces nearly complete loosening of compacted soil layers without causing substantial 

displacement, subsoiled areas are expected to reach full recovery within the short-term (less than 

5 years) through natural recovery processes. 

Research studies on the Deschutes National Forest have shown that the composition of the soil 

biota populations and distribution rebounds back toward pre-impact conditions following 

subsoiling treatments on compacted skid trail and landings. 

The winged subsoiling equipment used on the Deschutes National Forest lifts and fractures 

compacted sub-surface soil layers in greater than 90 percent of the compacted zone with one 

equipment pass (Craigg, 2000). Subsoiling directly fractures compacted soil particles and 

increases macro pore space within the soil profile, both of which contribute to increased water 

infiltration and enhanced vegetative root development. Soil compaction associated with harvest 

operations may disrupt mycorrhizal connectivity; subsequent subsoiling to break up the 

compaction may enhance new host plant root growth and mycorrhiza (Luoma, unpublished 

report, Diamond Lake Ranger District, 2007) or may disturb the existing mycorrhizal network 

(Abbott, p.c.). Although subsoiling does not completely return these areas to pre-impact 

conditions, it considerably rectifies physical properties to a condition where other soil processes 

can recover on site. Subsoiling is very effective in reducing soil strengths incurred by the 

compression and vibration effects of machine traffic. Soil probes taken before and after 

subsoiling operations show reductions to or below natural levels after a single pass of the 

implement. Following subsoiling, soils can be very fluffed, and returned to natural bulk density 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

66

levels after a year or two of physical settling and moisture percolation through the soil profile 

(Deschutes Soil Monitoring, 1995 through 2001). 

Alternative B 

Indicator #1: Detrimental Soil Disturbance 

Of the action alternatives, implementation of Alternative B would result in potentially the greatest 

extent of physical soil effects, mainly from compaction. 

Alternative B proposes the removal by commercial harvest on an estimated 7,086 acres. 

Mechanical harvest methods would be used on about 6,666 acres and advanced logging systems 

such as skyline or helicopter would be used on 420 acres (Table 3-7). Harvest operations would 

occur on relatively gentle to moderately sloping lava plains. The development and use of 

temporary roads, log landings, and skid trail systems are the primary sources of direct physical 

disturbance that would result in adverse changes to soil productivity. Mechanical harvest and 

yarding systems would likely be accomplished using ground-based machines equipped with a 

felling head (harvester shear). Feller bunchers with a 24 ft. boom (17 ft. effective reach) are one 

of the most common harvester machines used in this geographic area. Similar equipment would 

be used in proposed activity areas for this project. Felled trees would be whole-tree yarded to 

main skid trail networks and rubber-tired grapple machines would then transport the bunched 

trees to landings for processing and loading. Mechanical harvesters would be allowed to make a 

limited number of equipment passes (2) on any site-specific area between skid trails or away from 

log landings10. Skidding equipment would be restricted to designated skid trails. The majority of 

soil effects would be confined to known locations in heavy use areas that would be rehabilitated 

when logging transportation systems are no longer needed for future management. A Project 

Design Feature would accelerate temporary roads to a revegetated state by planting native grass 

seed, where feasible. 

Cable or aerial harvest systems are proposed where steeper slopes (30 percent slopes or greater) 

are found on Muttonchop Butte, Beales Butte, Chinquapin Butte, Little Odell Butte, and other 

unnamed steep areas or Buttes (Table 3-9). Fuel treatments would consist of whole tree yarding 

with tops attached, thinning to 6 inches or less, handpiling, pile disposal or prescribed 

underburning. In addition, mechanical operations would occur on sufficient snow or frozen 

ground in most harvest units that contain known or suspected populations of matsutake 

mushrooms. This is defined to have a snow depth of at least 1 foot of packed snow (not powder 

snow) and/or at least 6 inches of frozen ground. An indication of potential detrimental 

disturbance would be identifiable when ruts, or indentations in the ground after equipment travel 

appears 6 inches in depth or greater. This measure has proven to be very effective in past harvest 

operations, such as the Tums Timber Sale (Linda Fitzer, Timber Sale officer, personal 

communication). It would apply to units 125, 195, 200, 210, 245, 265, 270, 285, 300, 310, 312, 

315, 316, 320, 335, 340, 410, 460, 525, 820, 835, 845, 915, 1035, 1100, and 1135 for a total 

1,564 acres. However, it is not required in units prescribed for advanced harvest systems if they 

do not use shears or feller/bunchers. 

Detrimental soil conditions can affect matsutake fruiting and production by affecting mycelia, 

which can be damaged by compaction and rutting associated with harvest. Harvest over frozen 

ground maintains and intact soil profile as demonstrated on numerous projects around the forest, 

therefore the below-ground environment of shiro development remains unchanged.

 

10 For the purposes of this project and analysis, “pass” is defined as a single movement of the equipment to 

or from a trail or landing. Therefore, movement of a machine out into the unit and back to the skid trail or 

landing would equal two passes. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

67

Access Management (Roads) 

There would be no new construction of permanent transportation system roads. Commercial 

activities would require the use and maintenance of 160 miles of system roads under Forest 

Service jurisdiction. Road maintenance activities includes roadside brushing, removal of hazard 

trees, blading and shaping of travel way, restoring existing surface drainage, cleaning culverts and 

ditches, and installing water bars after periods of haul. There would be an estimated 9.7 miles of 

temporary road construction to access harvest units. All temporary roads would be restored and 

returned to a hydrologically functional condition after activities are completed. Restoration 

includes subsoiling equipment that loosens and stabilizes soil. Native grass seed would be used 

to accelerate vegetation, where feasible. 

Table 3-7 (below) displays a summary of the proposed activities in Alternative B. Measurements 

(acres and miles) are approximate. 

 Table 3-7. Alternative B Summary 

Harvest and Fuels Reduction Activities (acres) 

Ground-based Tractor 

Skyline or Helicopter 

“Fuels Only” Outside Harvest Units

6,666 ac. 

 420 ac. 

 413 ac. 

Road Management (miles) 

Road Maintenance 

Commercial Hauling 

Temporary Road Construction 

160 mi. 

160 mi. 

9.7 mi. 

Soils Resources (acres) 

 Current Detrimental Soil Condition 

 Soil Restoration (subsoiling) 

 Detrimental Soil Condition After Soil Restoration 

 Activities on Landtypes that include sensitive soils 

925 ac. 

530 ac. 

1,524 ac. 

462 ac. 

Units for which temporary road construction would be needed: 15, 30, 115, 125, 200, 310, 350, 

530, 570, 595, 615, 625, 785, 815, 856, 865, 1085, 1130, 1135, 1200, and 1300 

Ground Disturbing Management Activities 

Actions proposed in Alternative B comply with LRMP standards and guidelines 

SL-3 and SL-4, and Regional policy (FSM 2520, R-6 Supplement No. 2500-98-

1) for maintaining soil productivity. 

The following conclusions summarize the potential increases in detrimental soil conditions 

associated with temporary roads and logging transportation system needed to facilitate yarding 

operations in each of the activity areas. 

Under implementation of Alternative B (7,499 acres of total activity), existing detrimental 

disturbance within units is approximately 925 acres. After-harvest operations and beforerestoration activities, there would be an additional 1,129 acres (for a total 2,054 acres) classified 

in a detrimental condition. Soil restoration activities would rehabilitate approximately 530 acres. 

This figure represents the total acres needed to restore compacted soils to meet Regional and 

Forest Plan Standards and Guidelines for soil productivity. The total acres of detrimental 

disturbance after restoration activities are completed would be 1,524 acres. For a display of a unit 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

68

by unit basis of how each meets Forest and Regional Soil Quality Standards and Guidelines after 

restoration activities, refer to Table 3-10. Typically, stand tendering (such as thinning and fuels 

reduction activities) is needed every 20-30 years. Some areas in a compacted state (such as roads 

and trails) are retained for future management access. 

Project design criteria, including operational guidelines for equipment use are incorporated into 

the following discussion and are assumed to minimize the extent of detrimentally disturbed soil 

from harvest activities between main skid trails and away from log landings. 

The primary factor that affects soil compaction off designated skid trails is the amount of 

equipment traffic. Research has shown that the first one or two equipment passes over an area 

compact the upper few inches of the soil. Additional passes cause greater increases in bulk 

density and compact the soil to greater depths. The detrimental effects of soil compaction 

generally require more than 3 to 5 equipment passes (McNabb, Froehlich, 1983). Therefore, on 

ground-based logging systems only, the effects of only two passes by harvester machines on any 

site-specific area are not expected to qualify as a detrimental soil condition. Frost heaving and 

freeze-thaw cycles can generally offset soil compaction near the soil surface. Other natural 

processes that help restore soil porosity in soil surface layers include root penetration, rodent 

activity, wetting and drying cycles, and the accumulation of organic matter. On gentle to 

moderately sloping terrain, the maneuvering of equipment generally does not remove soil surface 

layers in large enough areas (at least 5 feet in width) to qualify as detrimental displacement (FSM 

2520, R-6 Supplement). Smaller areas of gouging or the mixing of soil and organic matter would 

not constitute detrimental soil displacement. Conservative estimates were used to predict 

amounts of detrimental soil conditions associated with harvest activities based upon monitoring 

of past similar projects and professional judgment. Incidental soil disturbances are accounted for 

in these estimates. 

Sensitive Soils 

Under Alternative B, there would be activity on 462 acres of landtypes that contain sensitive soils 

(Table 3-7). It is emphasized that only portions these landtypes actually contain sensitive 

soils. Development and use of log landings and skid trail systems are the primary sources of 

physical disturbance. The majority of effects would occur on and adjacent to sensitive soils areas 

where multiple equipment passes typically cause detrimental soil compaction. Project design 

criteria such as advanced logging systems in units with a high erosion hazard and over 30 percent 

slopes include units: 195, 340, 675, 1100, 1230, 1246, 1260, 1275, and 1310 (Table 3-9). 

However, units categorized as having a steep slope do not necessarily require advanced systems 

for protection. Portions of some units may also serve as retention areas for wildlife. Or, a Project 

Design Feature that allows ground-based systems shears one pass up and one pass down the slope 

can adequately maintain soil quality. This method applies to the following units that have a small 

amount of slopes over 30 percent in less than 10 percent of the unit area: 175 (1 percent), 300 (8 

percent) 751 (2 percent), 755 (1 percent), 1035 (1 percent), 1065 (3 percent), 1070 (7 percent), 

1110 (6 percent), and 1135 (1 percent). Unit 725 has approximately 4 acres (20 percent) with 

slopes over 30 percent. A mitigation measure was included that retains these 4 acres in a 

retention area, allowing ground-based systems to operate in the remaining portion. Project 

Design Features and Measures such as these have been utilized on numerous past harvest 

operations such as Baja East and West, and Critter Timber Sale with successful outcomes. In 

addition, on all slopes, slash from harvest operations can provide additional ground cover to 

improve the soil’s ability to resist surface erosion. 

The Soils Resource Inventory has identified units that have seasonal high water tables (Table 3-

5). In the majority of these units, there is a small portion adjacent to a riparian or wet area. All 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

69

units would be outside the riparian zones (ACS and RHCA) with a minimum 150 feet (non-fish 

bearing) and 300 feet (fish bearing). All boundaries would have on-site visits to verify correct 

distances prior to activity. 

There are a large number of units that have been identified as sensitive soils due to frost pockets. 

Frost pockets can hinder growth of some tree species when they are first planted. Since the BLT 

project prescriptions require retention of sufficient trees to be fully stocked and no planting is 

needed, advanced harvest systems are not necessary to protect these soils. The following Table 

3-8 displays mechanical activity on landtypes that contain sensitive soils and Table 3-9 shows 

those units prescribed for advanced systems. Typically, these systems are utilized throughout the 

entire unit. 

Table 3-8. Mechanical Vegetation Activity on Landtypes that Contain Sensitive Soils in 

Alternative B 

Management Concern Total Acres11 Alternative B Units 

Slopes greater than 30 

percent, High Erosion 

Hazard 208 

175, 195, 210, 300, 311, 

340, 570, 615, 635, 675, 

725, 751, 55, 845, 1035, 

1065, 1070, 1100, 1110, 

1135, 1230, 1246, 1260, 

1275, 1310 

Low productivity sites 

with low fertility and 

climatic factors/ or 

high water tables 

256 

155, 200, 265, 270, 285, 

295, 300, 310, 311, 312, 

315, 317, 340, 410, 435, 

455, 460, 516, 560, 625, 

751, 856, 870, 940, 

1061, 1070, 1085, 1100, 

1180, 1205, 1300 

Table 3-9. Alternative B Units with Slopes Greater Than 30 Percent Prescribed for 

Advanced Logging Systems 

Unit # Soil Code 

Acres of Sensitive 

Soils 

Unit Total 

Acres 

Sensitive Soils 

Percent of 

Unit 

195 9N 11.1 37.5 30% 

340 9C 8.0 22.7 35% 

675 9T 23.6 29.5 80% 

1100 9R 12.4 20.5 61% 

1230 9N 41.3 111.2 37% 

1246 9N 6.3 17.1 37% 

1260 9B, 9N, 9W 59.3 172.0 34% 

1275 9N, 9W 8.1 18.1 45% 

1310 9B, 9N 10.5 10.5 100% 

Total 180.5 420 

Fuels Reduction Activities in Harvest Units 

With the implementation of Alternative B, fuel reduction would be accomplished by whole tree 

yarding, prescribed underburning, hand piling, grapple piling, handpile burning, grapple pile 

 

11 Total includes only the portion of the units that are classified as sensitive 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

70

burning and utilization. Much of the unusable stemwood and tops would likely be machine piled 

and burned on log landings after all the material is utilized. In the current market, very little is 

disposed by burning. There would be no mechanized equipment associated with post-sale 

activities off existing skid trails or log landing. Logging slash will be piled in skid trails or 

landings. Although this method removes potential sources of woody debris off-site, it would not 

cause additional soil effects because burning would occur on disturbed soils that already have 

detrimental conditions. Restoration treatments to restore natural soil processes would be 

implemented to reduce the amount of detrimentally disturbed soil committed to log landings 

following these post-harvest activities. Grapple piling machines would stay on designated skid 

trail and landings and would not cause any additional effects to soils. 

Prescribed underburning would occur on 2,312 acres. Detrimental burn damage requires 

significant color change of the mineral soil surface in a 100 square feet (10 foot by 10 foot) area 

or larger to an oxidized reddish color, with the next one-half inch below blackened from organic 

matter charring as a result of heat conducted from the fire. Since underburns occur in early spring 

or late fall when weather conditions are cool and moist, detrimental effects to soils would not 

occur. 

Where prescribed burning of piles overlaps skid trails that are restored through subsoiling, if the 

burn damage exceeds 100 square feet, it is considered to remain in a detrimental condition. This 

effect was accounted for because many machine piles are less than 100 square feet, this condition 

only occurs where tractors are used for harvesting, and not all skid trails are restored and remain 

in a detrimental condition regardless of pile burning. In addition, estimates for detrimental soil 

conditions are very conservative and the worse case scenario was used. Harvest over snow and 

frozen ground would likely result in less detrimental conditions, therefore, the amount of 

detrimental conditions as a result of pile burning on skid trails is well within the range of effects 

disclosed. 

Summary 

Table 3-10 displays quantitative unit-specific information that shows the predicted amounts of 

detrimental soil conditions before and after implementation of project activities. The acres and 

percentages of existing soil impacts are shown in Column 4. The cumulative increases in 

detrimental soil conditions following mechanical harvest are shown in Column 5. The net 

changes following soil mitigation (subsoiling treatments) are shown in Column 6. The subsoiling 

acres (Column 7) are calculated by multiplying the estimated percentage (after soil restoration in 

Column 6) by the unit acres (Column 2) and subtracting this amount from the disturbed acres in 

Column 5. Note, these acres in Column 7 are very conservative, especially in those activity areas 

that are harvested over frozen ground. Units indicated for soil restoration would receive that 

treatment unless site-specific monitoring indicates otherwise. Column 8 displays increase in 

acres of detrimental soil conditions after all activities are completed. Surface calculation of 

designated areas such as roads, main skid trails, and log landings determines how much area 

needs to be subsoiled within the activity areas in order to meet Regional and Forest Plan 

Standards and Guidelines. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

71

Table 3-10. Estimated Effects to Soil Productivity for Alternative B 

Unit12 Unit 

Acres 

Vegetative 

Prescription and 

Associated 

Activities13

Existing 

Detrimental 

Soil Conditions

(Percent/Acres)

Detrimental 

Soil After 

Management 

Activities14 and 

Before 

Restoration 

(Percent/Acres)

Detrimental Soil 

Conditions After 

Soil Restoration 

(Percent/Acres) 

Restored 

Acres 

 Increase in 

Detrimental 

 Soil 

 Conditions 

 after 

 Restoration 

 is Complete 

 (Acres) 

15 71.1 HIM, GP 4.1% 2.9 17.1% 12.2 17.1% 12.2 0.0 9.3 

30 46.5 HTH, SDT, GP 1.7% 0.8 24.7% 11.5 20.0% 9.3 2.2 8.5 

45 49.1 SDT, HP 7.3% 3.6 30.3% 14.9 20.0% 9.8 5.1 6.2 

55 43.0 HIM, SDT, GP, UB 2.1% 0.9 25.1% 10.8 20.0% 8.6 2.2 7.7 

65 164.7 HTH, PP, GP, UB 1.8% 2.9 24.8% 40.8 20.0% 32.9 7.9 30.0 

80 90.2 SDT, HP 17.3% 15.6 40.3% 36.4 20.0% 18.0 18.3 2.4 

90 13.4 HTH, GP 3.0% 0.4 16.0% 2.1 16.0% 2.1 0.0 1.7 

100 31.6 HIM, GP 4.1% 1.3 17.1% 5.4 17.1% 5.4 0.0 4.1 

115 150.7 HP 3.0% 4.5 16.0% 24.1 16.0% 24.1 0.0 19.6 

125 85.8 HIM, GP 0.7% 0.6 13.7% 11.8 13.7% 11.8 0.0 11.1 

130 9.0 HTH, GP 2.2% 0.2 15.2% 1.4 15.2% 1.4 0.0 1.2 

135 102.7 HIM, SDT, GP 16.2% 16.6 39.2% 40.3 20.0% 20.5 19.7 3.9 

150 104.3 HIM, GP 17.8% 18.6 30.8% 32.1 20.0% 20.9 11.3 2.3 

155 55.4 HTH, SDT, GP 9.9% 5.5 32.9% 18.2 20.0% 11.1 7.1 5.6 

165 46.2 HTH, SDT, GP 5.4% 2.5 28.4% 13.1 20.0% 9.2 3.9 6.7 

170 13.0 HTH, HP, UB 1.5% 0.2 14.5% 1.9 14.5% 1.9 0.0 1.7 

175 219.0 HTH, SDT, HP, UB 2.0% 4.3 25.0% 54.8 20.0% 43.8 11.0 39.5 

185 18.1 HIM, GP, HP 18.8% 3.4 31.8% 5.7 20.0% 3.6 2.1 0.2 

195* 37.5 HTH, HP 2.7% 1.0 10.7% 4.0 10.7% 4.0 0.0 3.0 

200 240.7 HIM, SDT, GP 1.9% 4.6 24.9% 59.9 20.0% 48.1 11.8 43.5 

210 35.5 HTH, SDT, GP,UB 3.7% 1.3 26.7% 9.5 20.0% 7.1 2.4 5.8 

245 27.6 HTH, GP, HP 6.2% 1.7 19.2% 5.3 19.2% 5.3 0.0 3.6 

260 8.2 HTH, GP, HP 0.0% 0.0 13.0% 1.1 13.0% 1.1 0.0 1.1 

265 66.7 HIM, SDT, GP 0.1% 0.1 23.1% 15.4 20.0% 13.3 2.1 13.2 

270 66.8 HTH, SDT, GP 1.9% 1.3 24.9% 16.6 20.0% 13.4 3.3 12.1 

285 78.4 HTH, GP 1.5% 1.2 14.5% 11.4 14.5% 11.4 0.0 10.2 

290 5.7 HIM, GP, HP 3.5% 0.2 16.5% 0.9 16.5% 0.9 0.0 0.7 

295 13.2 HIM, SDT, GP 1.5% 0.2 24.5% 3.2 20.0% 2.6 0.6 2.4 

300 51.8 HTH, SDT,GP, UB 10.2% 5.3 33.2% 17.2 20.0% 10.4 6.8 5.1 

310 207.7 HIM, GP, UB 12.4% 25.8 25.4% 52.8 20.0% 41.5 11.2 15.7 

311 4.7 HIM, GP 21.3% 1.0 29.3% 1.3 21.3% 1.0 0.3 0.0 

312* 10.9 HIM, GP 27.5% 3.0 34.5% 3.8 27.5% 3.0 .8 0.0 

315* 18.0 HTH, GP 20.0% 3.6 27.0% 4.9 20.0% 3.6 1.3 0.0 

316 7.2 HTH, GP 27.8% 2.0 34.8% 2.5 27.8% 2.0 .5 0.0 

317 5.6 HTH, GP 8.9% 0.5 21.9% 1.2 20.0% 1.1 0.1 0.6 

320 13.1 HTH, GP 7.6% 1.0 20.6% 2.7 20.0% 2.6 0.1 1.6 

335 50.5 HTH, GP 0.6% 0.3 13.6% 6.9 13.6% 6.9 0.0 6.6 

340* 22.7 HTH, HP 22.9% 5.2 30.9% 7.0 22.9% 5.2 1.8 0.0 

350 138.4 HIM, SDT, GP 9.9% 13.7 32.9% 45.5 20.0% 27.7 17.9 14.0 

355 12.3 HIM, GP, HP 2.4% 0.3 15.4% 1.9 15.4% 1.9 0.0 1.6 

405 84.1 HIM, SDT, GP 24.6% 20.7 37.6% 31.6 24.6% 20.7 10.9 0.0 

410 8.4 HTH, SDT, GP, 23.0% 1.9 40.0% 3.4 23.0% 1.9 1.4 0.0 

420 230.6 HTH, HP, UB 24.5% 56.5 31.5% 86.5 22.6% 56.5 16.1 0.0 

435 78.5 HIM, HP 19.6% 15.4 36.6% 28.1 20.0% 15.7 13.0 0.4 

455 5.5 HTH, GP 1.8% 0.1 14.8% 0.8 14.8% 0.8 0.0 0.7 

 

12 Asterisk * denotes advanced harvest systems such as cable or helicopter 13 HTH = Commercial Thin, GP = Grapple Piling of Fuels, HIM = Harvest Improvement Cut, SDT = Small Diameter 

Thin with Special Forest Products (post and pole, firewood or biomass) Opportunity, UB = Underburn, HP = Handpile 14 Includes calculations for post-sale activities and existing detriment conditions 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

72

Unit12 Unit 

Acres 

Vegetative 

Prescription and 

Associated 

Activities13

Existing 

Detrimental 

Soil Conditions

(Percent/Acres)

Detrimental 

Soil After 

Management 

Activities14 and 

Before 

Restoration 

(Percent/Acres)

Detrimental Soil 

Conditions After 

Soil Restoration 

(Percent/Acres) 

Restored 

Acres 

 Increase in 

Detrimental 

 Soil 

 Conditions 

 after 

 Restoration 

 is Complete 

 (Acres) 

460 51.5 HTH, SDT, GP 24.3% 12.5 43.1% 22.2 24.3% 12.5 9.7 0.0 

465 24.4 HTH, GP 22.1% 5.4 29.1% 7.1 22.1% 5.4 1.7 0.0 

480 16.7 HTH, GP, HP 1.2% 0.2 14.2% 2.4 14.2% 2.4 0.0 2.2 

485 46.1 HTH, GP, HP, UB 11.1% 5.1 24.1% 11.1 20.0% 9.2 1.9 4.1 

505 43.4 HTH, GP, HP, UB 23.5% 10.2 30.5% 13.2 23.5% 10.2 5.6 0.0 

516* 7.3 HTM, GP, HP 1.4% 0.1 14.4% 1.1 14.4% 1.1 0.0 1.0 

517 5.5 HIM, GP, HP 0.0% 0.0 13.0% 0.7 13.0% 0.7 0.0 0.7 

520 91.6 HIM, GP, HP 0.5% 0.5 13.5% 12.4 13.5% 12.4 0.0 11.9 

525 94.0 HIM, SDT, GP, HP 25.6% 24.1 42.6% 40.1 25.6% 24.1 16.0 0.0 

530 122.9 HTH, SDT, GP, HP 9.5% 11.7 32.5% 39.9 20.0% 24.6 15.4 12.9 

535 20.3 HIM, GP 3.0% 0.6 16.0% 3.2 16.0% 3.2 0.0 2.6 

540 11.1 HTH, GP 0.9% 0.1 13.9% 1.5 13.9% 1.5 0.0 1.4 

560* 70.7 HTH, GP 0.1% 0.1 13.1% 9.3 13.1% 9.3 0.0 9.2 

561 6.1 HTH, GP 1.6% 0.1 14.6% 0.9 14.6% 0.9 0.0 0.8 

570 277.1 HIM, GP 23.9% 66.2 30.9% 85.6 23.9% 66.2 19.4 0.0 

575 148.6 HTH, SDT, GP 23.9% 35.5 40.9% 60.8 23.9% 35.5 25.3 0.0 

580 14.4 HTH, GP 1.4% 0.2 13.4% 1.9 13.4% 1.9 0.0 1.7 

590 18.8 HIM, GP 25.6% 4.8 32.6% 6.1 25.6% 4.8 1.3 0.0 

595 132.6 HTH, GP, UB 1.1% 1.5 14.1% 18.7 14.1% 18.7 0.0 17.2 

610 46.1 HIM, SDT, GP 1.1% 0.5 24.1% 11.1 20.0% 9.2 1.9 8.7 

615 74.7 HIM, GP, UB 0.5% 0.4 13.5% 10.1 13.5% 10.1 0.0 9.7 

616 32.2 HIM, GP, UB 2.4% 0.8 15.4% 5.0 15.4% 5.0 0.0 4.2 

620 17.6 SDT, HP 23.2% 4.1 23.2% 4.1 23.2% 4.1 0.0 0.0 

625 49.6 HIM, GP, UB 23.0% 11.4 30.0% 14.9 23.0% 11.4 3.5 0.0 

635 188.9 HIM, SDT, GP 23.7% 44.8 40.7% 88.7 23.7% 32.1 43.5 0.0 

640 55.4 HIM, SDT, GP 17.7% 9.8 40.7% 22.6 20.0% 11.1 11.5 1.3 

645 5.8 HIM, GP 3.4% 0.2 16.4% 1.0 16.4% 1.0 0.0 0.8 

646 8.2 HIM, GP 3.6% 0.3 16.6% 1.4 16.6% 1.4 0.0 1.1 

655 38.7 HTH, GP, UB 15.0% 5.8 28.0% 10.8 20.0% 7.7 3.1 1.9 

660 95.6 HTH, GP, UB 0.8% 0.8 13.8% 13.2 13.8% 13.2 0.0 12.4 

670 39.2 HTH, GP 4.1% 1.6 17.1% 6.7 17.1% 6.7 0.0 5.1 

675* 29.5 HTH, HP 24.7% 7.3 31.7% 9.4 24.7% 7.3 2.1 0.0 

690 62.2 HIM, SDT, HP, UP 0.0% 0.0 23.0% 14.3 20.0% 12.4 1.9 12.4 

705 16.6 HTH, GP, HP 38.0% 6.3 45.0% 7.5 38.0% 6.3 1.2 0.0 

725 20.8 HTH, GP 27.0% 5.6 40.0% 8.3 27.0% 5.6 2.7 0.0 

751* 12.2 HIM, HP 2.0% 0.2 15.0% 1.8 15.0% 1.8 0.0 1.6 

755 133.9 HIM, SDT, GP 25.6% 34.3 42.6% 57.0 25.6% 34.3 22.8 0.0 

770 59.5 HIM, GP 25.5% 15.2 32.5% 19.3 25.5% 15.2 4.2 0.0 

775 39.9 HTH, GP, UB 18.5% 7.4 31.5% 12.6 20.0% 8.0 4.6 0.6 

785 188.1 HIM, GP, UB 3.8% 7.1 16.8% 31.6 16.8% 31.6 0.0 24.5 

790 11.0 HTH, SDT, GP 1.8% 0.2 24.8% 2.7 20.0% 2.2 0.5 2.0 

800 15.4 HTH, GP, UB 4.5% 0.7 17.5% 2.7 17.5% 2.7 0.0 2.0 

815 124.3 HTH, GP, UB 5.4% 6.7 18.4% 22.9 18.4% 22.9 0.0 16.2 

820 20.8 HTH, SDT, GP 3.9% 0.8 26.9% 5.6 20.0% 4.2 1.4 3.4 

835 89.8 HTH, SDT, UB 10.9% 9.8 33.9% 30.5 20.0% 18.0 12.5 8.2 

840 34.4 HTH, GP 16.3% 5.6 29.3% 10.1 20.0% 6.9 3.2 1.3 

845 94.5 HTH, GP, UB 3.3% 3.1 16.6% 15.7 16.6% 15.7 0.0 12.6 

855 30.0 HIM, GP 24.0% 7.2 37.0% 11.1 24.0% 7.2 3.9 0.0 

856 30.9 HIM, GP 22.9% 7.1 29.9% 9.3 22.9% 7.1 2.2 0.0 

865 50.3 HIM, GP 22.7% 11.4 29.7% 14.9 22.7% 11.4 3.5 0.0 

870 23.3 HTH, GP 0.0% 0.0 13.0% 3.0 13.0% 3.0 0.0 3.0 

875 30.6 HIM, SDT, GP 3.6% 1.1 26.6% 8.1 20.0% 6.1 2.0 5.0 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

73

Unit12 Unit 

Acres 

Vegetative 

Prescription and 

Associated 

Activities13

Existing 

Detrimental 

Soil Conditions

(Percent/Acres)

Detrimental 

Soil After 

Management 

Activities14 and 

Before 

Restoration 

(Percent/Acres)

Detrimental Soil 

Conditions After 

Soil Restoration 

(Percent/Acres) 

Restored 

Acres 

 Increase in 

Detrimental 

 Soil 

 Conditions 

 after 

 Restoration 

 is Complete 

 (Acres) 

900 23.0 HIM, GP 0.9% 0.2 13.9% 3.2 13.9% 3.2 0.0 3.0 

915 54.6 HIM, SDT, GP, UB 0.0% 0.0 23.0% 12.5 20.0% 10.9 1.6 10.9 

940 4.7 SDT, HP 0.0% 0.0 10.0% 0.5 10.0% 0.5 0.0 0.5 

1035 20.8 HIM, GP 23.0% 4.8 30.0% 6.3 23.0% 4.8 1.5 0.0 

1061 21.9 HP 1.4% 0.3 1.4% 0.3 1.4% 0.3 0.0 0.0 

1065 45.2 HTH, GP 2.0% 0.9 15.0% 6.8 15.0% 6.8 0.0 5.9 

1070 50.0 HIM, GP 14.6% 7.3 27.6% 13.8 20.0% 10.0 3.8 2.7 

1085 24.0 HIM, GP 23.0% 5.5 30.6% 7.2 23.0% 5.5 1.7 0.0 

1100* 20.5 HTH, HP 24.4% 5.0 31.4% 6.4 24.4% 5.0 1.4 0.0 

1110 26.3 HTH, GP 25.5% 6.7 31.5% 8.5 25.5% 6.7 1.4 0.0 

1130 115.0 HIM, GP 22.9% 26.3 29.9% 34.9 22.9% 26.3 8.1 0.0 

1135 84.1 HIM, GP 23.1% 19.4 36.1% 30.3 23.1% 19.4 10.9 0.0 

1160 29.9 HTH, SDT, GP 24.4% 7.3 41.4% 12.4 24.4% 7.3 5.1 0.0 

1165 10.6 HTH, SDT, GP 24.6% 2.6 41.6% 4.4 24.6% 2.6 1.8 0.0 

1175 46.9 HIM, SDT, GP 24.1% 11.3 41.1% 19.3 24.1% 11.3 8.0 0.0 

1180 41.3 HIM, SDT, GP 24.2% 10.0 41.2% 17.0 24.2% 10.0 7.0 0.0 

1181 21.7 HIM, GP 1.4% 0.3 14.4% 3.1 14.4% 3.1 0.0 2.8 

1185 107.7 HIM,PP, GP, UB 24.9% 26.8 41.9% 45.1 24.9% 26.8 18.3 0.0 

1190 15.6 HIM, SDT, GP 6.4% 1.0 29.4% 4.6 20.0% 3.1 1.5 2.1 

1195 38.7 HTH, SDT, GP 0.5% 0.2 23.5% 9.1 20.0% 7.7 1.4 7.5 

1200 57.0 HIM, SDT, GP 0.5% 0.3 23.5% 13.4 20.0% 11.4 2.0 11.1 

1205 68.5 HIM, SDT, GP, UB 0.4% 0.3 23.7% 16.2 20.0% 13.7 2.5 13.4 

1210 6.6 HIM, GP 24.4% 1.6 31.4% 2.1 24.4% 1.6 0.5 0.0 

1215 128.3 HIM, GP, UB 13.3% 17.1 26.3% 33.7 20.0% 25.7 8.1 8.6 

1230* 111.2 HTH, HP 30.9% 34.4 38.9% 43.3 30.9% 34.4 8.9 0.0 

1235 30.7 HIM, SDT, GP 25.0% 7.7 42.0% 12.9 25.0% 7.7 5.2 0.0 

1240 18.2 HIM, SDT, GP 2.2% 0.4 25.2% 4.6 20.0% 3.6 0.9 3.2 

1245 68.8 HTH, GP 1.9% 1.3 14.9% 10.2 14.9% 10.2 0.0 8.9 

1246* 17.1 HTH, HP 4.7% 0.8 12.7% 2.2 12.7% 2.2 0.0 1.4 

1255 46.2 HTH, GP 20.8% 9.6 27.8% 12.8 20.8% 9.6 3.2 0.0 

1260* 172.0 HTH, HP 24.8% 42.6 31.8% 54.7 24.8% 42.7 12.0 0.1 

1265 36.5 HTH, GP 20.3% 7.4 27.3% 10.0 20.3% 7.4 2.6 0.0 

1275* 18.1 HTH, HP 27.0% 4.9 34.0% 6.2 27.0% 4.9 1.3 0.0 

1300 47.5 HIM, SDT, GP 0.0% 0.0 23.0% 10.9 20.0% 9.5 1.4 9.5 

1310* 10.5 HTH, HP 24.8% 2.6 31.8% 3.4 24.8% 2.6 0.8 0.0 

Total 7499 925 2054 1524 530 600 

Indicator #2: Coarse Woody Debris (CWD) and Surface Organic Matter 

Coarse woody debris (greater than 3 inches in diameter) is needed for biological activity and 

long-term nutrient cycling. Small woody material and surface litter (i.e., leaves, twigs, and 

branches less than 3 inches in diameter) are needed for erosion control and short-term nutrient 

cycling. 

Commercial harvest and whole-tree yarding can affect soil productivity through the removal of 

nutrients in the form of tree boles, limbs and branches. Although these forest management 

practices remove potential sources of future CWD, ground-based harvest activities also recruit 

CWD to the forest floor through breakage of limbs and tops and toppling of some trees during 

felling and skidding operations. 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

74

In Alternative B, the removal of tree boles would have little or no effect on nutrient cycling 

processes during the short term. Most of the tree’s short-term nutrient supply is stored in the 

leaves (needles), branches, and roots, and much of this would remain on-site. In the longer term, 

Project Design Features for snags and large down wood (Chapter 2) in addition to 15 percent 

retention areas in a passive management scenario would provide sufficient habitat for biological 

activity and long-term nutrient recycling. All activity units have been designed to meet or exceed 

well-distributed coarse woody debris Standards and Guidelines specified in the Northwest Forest 

Plan ROD for Matrix lands (C-40) and Eastside Screens Interim Wildlife Standard which far 

exceeds minimum recommendations of 10 to 15 tons per acre be retained on site to insure 

adequate sources of CWD for nutrient recycling and ground cover. 

Indicator #3: Project Design, Management Requirements and Mitigation Measures 

Project Design Features, management requirements and mitigation measures to protect the soil 

resource are identified in Chapter 2 of this EIS. All requirements would be met to ensure 

compliance with applicable Standards and Guidelines. 

Under implementation of Alternative B there would be 530 acres of soil restoration treatments 

that would be applied to specific units using a self-drafting winged subsoiler to loosen and 

stabilize detrimentally compacted soil (Table 3-7). This would be required mitigation to comply 

with Regional policy and Forest Plan Standards (SL-3, SL-4, and SL-6) for soil productivity. 

Alternative C

Alternative C proposes to commercial harvest 9.8 million board feet on 5,771 acres. Alternative 

C has an additional 334 acres of fuel reduction activities outside of harvest units. Logging 

systems and prescriptions proposed in Alternative C are identical to Alternative B where 

proposed units overlap. Region 6 and LRMP Standards and Guidelines would not be exceeded 

in any activity area. Therefore, the proposed actions comply with LRMP standards and 

guidelines SL-3 and SL-4, and Regional policy (FSM 2520, R-6 Supplement No. 2500-98-1) 

for maintaining soil productivity. 

Access Management (Roads) 

There would be no new construction of permanent transportation system roads. Commercial 

activities would require the use and maintenance of 126 miles of system roads under USDAForest Service jurisdiction. Road maintenance activities includes roadside brushing, removal of 

hazard trees, blading and shaping of travel way, restoring existing surface drainage, cleaning 

culverts and ditches, and installing water bars after periods of haul. Alternative C would require 

approximately 8.7 miles of temporary road construction. All temporary roads would be restored 

and return to proper hydrologic function following completion of activities. 

As in Alternative B, Alternative C mechanical operations would occur on sufficient snow or 

frozen ground in most harvest units that contain known or suspected populations of matsutake 

mushrooms. This is defined to have a snow depth of at least 1 foot of packed snow (not powder 

snow) and/or at least 6 inches of frozen ground. An indication of potential detrimental 

disturbance would be identifiable when ruts, or indentations in the ground after equipment travel 

appears 6 inches in depth or greater. This will apply to the following units: 125, 195, 200, 210, 

245, 265, 270, 300, 315, 316, 320, 335, 340, 525, 835, 845, 915, 1035, 1100, and 1135, for a total 

of 1,203 acres. However, it is not required in units prescribed for advanced harvest systems if 

they do not use shears or feller/bunchers. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

75

Table 3-11 displays a summary of the proposed activities in Alternative C. Measurements (acres 

and miles) are approximate. 

Table 3-11. Alternative C Summary 

Harvest and Fuels Reduction Activities (acres) 

 Ground-based Tractor 

 Skyline or Helicopter 

 “Fuels Only” Outside Harvest Units

5,027 ac 

410 ac 

334 ac 

Road Management (miles) 

 Temporary Roads construction 

 Commercial Haul 

 Road Maintenance 

8.7 mi 

126 mi 

126 mi

Soils Resources (acres) 

 Current Detrimental Soil Condition 

 Soil Restoration (subsoiling) 

 Detrimental Soil Condition After Soil Restoration 

 Activities on Sensitive Soils 

703 ac 

500 ac 

1,166 ac 

311 ac

Units where temporary road construction is needed: 115, 125, 200, 350, 530, 570, 615, 625, 785, 

815, 856, 865, 1100, and 1135. 

Ground Disturbing Management Activities 

Actions proposed in Alternative C comply with LRMP standards and guidelines 

SL-3 and SL-4, and Regional policy (FSM 2520, R-6 Supplement No. 2500-98-

1) for maintaining soil productivity. 

Ground-disturbing management activities vary in their intensity of site disturbance. The 

following conclusions summarize the potential increases in detrimental soil conditions associated 

with temporary roads and logging transportation system needed to facilitate yarding operations in 

each of the activity areas. 

Under implementation of Alternative C (5,771 ac), existing detrimental disturbance within units 

is 703 acres. After harvest operations and before restoration activities, there would be an 

additional 864 acres of soils classified as detrimental condition for a total 1,567 acres. Soil 

restoration activities would rehabilitate approximately 400 acres. The total acres of detrimental 

disturbance after restoration activities are completed would be 1,166 acres. For a display of a unit 

by unit basis of how each meets Forest and Regional Soil Quality Standards and Guidelines after 

restoration activities, reference Table 3-14. Typically, stand tendering (such as thinning and fuels 

reduction activities) is needed every 20-30 years. Some areas in a compacted state (such as roads 

and trails) are retained for future management access. 

As displayed in Alternative B, Alternative C uses the same rationale for estimates of existing and 

predicted amounts of detrimental soil conditions associated with temporary roads and logging 

facilities. These totals are included and the percentages displayed for each of the proposed 

activity areas in Table 3-14. 

Sensitive Soils 

Under Alternative C, there would be activity on 311 acres of sensitive soils. As described in 

Alternative B, project design criteria such as advanced logging systems in units over 30 percent 

slope include: 195, 340, 1100, 1230, 1246, 1260, 1275, and 1313 (Table 3-13). 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

76

The Soils Resource Inventory has identified units that have seasonal high water tables (Table 3-

12). In the majority of these units, there is a small portion adjacent to a riparian or wet area. All 

boundaries would be designated where harvest activities would occur outside the riparian zones 

(ACS and RHCA) with a minimum 150 feet (non-fish bearing) and 300 feet (fish bearing). All 

boundaries would have on-site visits to verify correct distances prior to activity. Only one 

activity is proposed within riparian resources (unit 1061), it is non-mechanical, and it would 

restore meadow habitats and rejuvenate riparian vegetation through prescribed burning. 

There are a large number of units that have been identified as sensitive soils due to frost pockets. 

Frost pockets can hinder growth of some tree species when they are first planted. Since the BLT 

project prescriptions require retention of sufficient trees to be fully stocked and no planting is 

needed, advanced harvest systems are not necessary. 

Table 3-12. Mechanical Vegetation Activities on Landtypes that Contain Sensitive Soils in 

Alternative C 

Management Concern Total 

Acres15 Alternative C Units 

Slopes greater than 30 

percent, High Erosion 

Hazard 

180 

175, 195, 210, 300, 340, 570, 615, 635, 725, 751, 

755 845, 1035, 1065, 1100, 1110, 1135, 1230, 1246, 

1260, 1275, 1310 

Low productivity sites 

From Climatic Factors/ 

or High Water Tables 

131 

80, 115, 150, 155, 165, 200, 265, 270, 300, 315, 

317, 320, 335, 340, 355, 455, 535, 560, 610, 625, 

751, 840, 856, 875, 940, 1061, 1085, 1100, 1175, 

1180, 1181, 1205, 1210, 1215, 1235, 1265 

Table 3-13. Alternative C Units with Slopes Greater Than 30 Percent Prescribed for 

Advanced Logging Systems 

Unit Soil Code Acres of Sensitive 

Soils (ac) 

Unit Total 

Acres 

Sensitive Soils 

Percent of Unit 

195 9N 11.1 37.5 30% 

340 9C 8.0 22.7 35% 

1100 9R 12.4 20.5 61% 

1230 9N 41.3 111.2 37% 

1246 9N 6.3 17.1 37% 

1260 9B, 9N, 9W 59.3 172.0 34% 

1275 9N, 9W 8.1 18.1 45% 

1310 9B, 9N 10.5 10.5 100% 

Total 164 499 

 

15 Total acres includes only the portion that is classified as sensitive 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

77

Table 3-14. Estimated Effects to Soil Productivity for Alternative C 

Unit16

Acres 

Vegetative 

Prescription with 

Associated 

Activities17

Existing 

Detrimental 

Soil Conditions

Percent/Acres

Detrimental Soil After 

Management 

Activities18 and Before 

Restoration 

Percent/Acres 

Detrimental Soil 

Conditions After 

Soil Restoration 

Percent/Acres 

Restored 

Acres 

Increase in 

Detrimental 

Soil Conditions 

after Activity is 

Complete 

(Acres) 

45 49.1 SDT, HP 7.3% 3.6 30.3% 14.9 20.0% 9.8 5.1 6.2 

65 164.7 HTH, GP, UB 1.8% 2.9 24.8% 40.8 20.0% 32.9 7.9 30.0 

80 90.2 SDT, HP 17.3% 15.6 40.3% 36.4 20.0% 18.0 18.3 2.4 

115 150.7 SDT, HP 3.0% 4.5 16.0% 24.1 16.0% 24.1 0.0 19.6 

125 85.8 HIM, GP 0.7% 0.6 13.7% 11.8 13.7% 11.8 0.0 11.1 

135 102.7 HIM, SFP, GP 16.2% 16.6 39.2% 40.3 20.0% 20.5 19.7 3.9 

150 104.3 HIM, GP 17.8% 18.6 30.8% 32.1 20.0% 20.9 11.3 2.3 

155 55.4 HTH, SDT, GP 9.9% 5.5 32.9% 18.2 20.0% 11.1 7.1 5.6 

165 46.2 HTH, SDT, GP 5.4% 2.5 28.4% 13.1 20.0% 9.2 3.9 6.7 

170 13.0 HTH, GP, UB 1.5% 0.2 14.5% 1.9 14.5% 1.9 0.0 1.7 

175 219.0 HTH, SDT, GP, UB 2.0% 4.3 25.0% 54.8 20.0% 43.8 11.0 39.5 

185 18.1 HIM, GP 18.8% 3.4 31.8% 5.7 20.0% 3.6 2.1 0.2 

195* 37.5 HTH, HP 2.7% 1.0 10.7% 4.0 10.7% 4.0 0.0 3.0 

200 240.7 HIM, SDT, GP 1.9% 4.6 24.9% 59.9 20.0% 48.1 11.8 43.5 

210 35.5 HTH, SDT, GP, UB 3.7% 1.3 26.7% 9.5 20.0% 7.1 2.4 5.8 

245 27.6 HTH, GP 6.2% 1.7 19.2% 5.3 19.2% 5.3 0.0 3.6 

260 8.2 HTH, GP 0.0% 0.0 13.0% 1.1 13.0% 1.1 0.0 1.1 

265* 66.7 HIM, SDT, GP 0.1% 0.1 23.1% 15.4 20.0% 13.3 2.1 13.2 

270* 66.8 HTH, SDT, GP 1.9% 1.3 24.9% 16.6 20.0% 13.4 3.3 12.1 

290 5.7 HIM, GP 3.5% 0.2 16.5% 0.9 16.5% 0.9 0.0 0.7 

300** 51.8 HTH, SDT, GP, UB 10.2% 5.3 33.2% 17.2 20.0% 10.4 6.8 5.1 

315* 18.0 HTH, GP 20.0% 3.6 27.0% 4.8 20.0% 3.6 1.3 0.0 

316 7.2 HTH, GP 27.8% 2.0 34.8% 2.5 27.8% 2.0 0.5 0.0 

317 5.6 HTH, GP 8.9% 0.5 21.9% 1.2 20.0% 1.1 0.1 0.6 

320 13.1 HTH, GP 7.6% 1.0 20.6% 2.7 20.0% 2.6 0.1 1.6 

335 50.5 HTH, GP 0.6% 0.3 13.6% 6.9 13.6% 6.9 0.0 6.6 

340* 22.7 HTH, HP 22.9% 5.2 30.9% 7.0 22.9% 5.2 1.8 0.0 

350 138.4 HIM, SDT, GP 9.9% 13.7 32.9% 45.5 20.0% 27.7 17.9 14.0 

355 12.3 HIM, GP 2.4% 0.3 15.4% 1.9 15.4% 1.9 0.0 1.6 

420 230.6 HTH, GP, UB 24.5% 56.5 31.5% 72.6 24.5% 56.5 16.1 0.0 

455 5.5 HTH, GP 1.8% 0.1 14.8% 0.8 14.8% 0.8 0.0 0.7 

465 24.4 HTH, GP 22.1% 5.4 29.1% 7.1 22.1% 5.4 1.7 0.0 

485 46.1 HTH, GP, UB 11.1% 5.1 24.1% 11.1 20.0% 9.2 1.9 4.1 

505 43.4 HTH, GP, UB 23.5% 10.2 30.5% 13.2 23.5% 10.2 3.9 0.0 

520 91.6 HIM, GP 0.5% 0.5 13.5% 12.4 13.5% 12.4 0.0 11.9 

525 94.0 HIM, SDT, GP 25.6% 24.1 42.5% 40.0 25.6% 24.1 15.9 0.0 

530 122.9 HTH, SDT, GP 9.5% 11.7 32.5% 39.9 20.0% 24.6 15.4 12.9 

535 20.3 HIM, GP 3.0% 0.6 16.0% 3.2 16.0% 3.2 0.0 2.6 

560 70.7 HTH, GP 0.1% 0.1 13.1% 9.3 13.1% 9.3 0.0 9.2 

570 277.1 HIM, GP 23.9% 66.2 30.9% 85.6 23.9% 66.2 19.4 0.0 

580 14.4 HTH, GP 1.4% 0.2 13.4% 1.9 13.4% 1.9 0.0 1.7 

590 18.8 HIM, GP 25.6% 4.8 32.6% 6.1 25.6% 4.8 1.3 0.0 

610 46.1 HIM, SDT, GP 1.1% 0.5 24.1% 11.1 20.0% 9.2 1.9 8.7 

615 74.7 HIM, GP, UB 0.5% 0.4 13.5% 10.1 13.5% 10.1 0.0 9.7 

616 32.2 HIM, GP, UB 2.4% 0.8 15.4% 5.0 15.4% 5.0 0.0 4.2 

620 17.6 SDT, HP 23.2% 4.1 23.2% 4.1 23.2% 4.1 0.0 0.0 

625 49.6 HIM, GP, UB 23.0% 11.4 30.0% 14.9 23.0% 11.4 3.5 0.0 

 

16 Asterisk * denotes advanced harvest systems such as cable or helicopter 17 HTH = Commercial Thin, GP = Grapple Piling of Fuels, HIM = Harvest Improvement Cut, SDT = Small Diameter 

Thin with special forest products (post and pole, firewood, or biomass) opportunity, UB = Underburn, HP = Handpile 18 Includes calculations for post-sale activities and existing detrimental condition 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

78

Unit16

Acres 

Vegetative 

Prescription with 

Associated 

Activities17

Existing 

Detrimental 

Soil Conditions

Percent/Acres

Detrimental Soil After 

Management 

Activities18 and Before 

Restoration 

Percent/Acres 

Detrimental Soil 

Conditions After 

Soil Restoration 

Percent/Acres 

Restored 

Acres 

Increase in 

Detrimental 

Soil Conditions 

after Activity is 

Complete 

(Acres) 

635 188.9 HIM, SDT, GP 23.7% 44.8 40.7% 76.9 23.7% 44.8 32.1 0.0 

640 55.4 HIM, SDT, GP 17.7% 9.8 40.7% 22.6 20.0% 11.1 11.5 1.3 

645 5.8 HIM, GP 3.4% 0.2 16.4% 1.0 16.4% 1.0 0.0 0.8 

646 8.2 HIM, GP 3.6% 0.3 16.6% 1.4 16.6% 1.4 0.0 1.1 

660 95.6 HTH, GP, UB 0.8% 0.8 13.8% 13.2 13.8% 13.2 0.0 12.4 

670 39.2 HTH, GP 4.1% 1.6 17.1% 6.7 17.1% 6.7 0.0 5.1 

725 20.8 HTH, GP 27.0% 5.6 34.0% 7.1 27.0% 5.6 1.5 0.0 

751 12.2 HIM, GP 2.0% 0.2 15.0% 1.8 15.0% 1.8 0.0 1.6 

755 133.9 HIM, SDT, GP 25.6% 34.3 42.6% 57.0 25.6% 34.3 22.8 0.0 

775 39.9 HTH, GP, UB 18.5% 7.4 31.5% 12.6 20.0% 8.0 4.6 0.6 

785 188.1 HIM, GP, UB 3.8% 7.1 16.8% 31.6 16.8% 31.6 0.0 24.5 

790 11.0 HTH, SDT, GP 1.8% 0.2 24.8% 2.7 20.0% 2.2 0.5 2.0 

800 15.4 HTH, GP, UB 4.5% 0.7 17.5% 2.7 17.5% 2.7 0.0 2.0 

815 124.3 HTH, GP, UB 5.4% 6.7 18.4% 22.9 18.4% 22.9 0.0 16.2 

835 89.8 HTH, SDT, UB 10.9% 9.8 33.9% 30.5 20.0% 18.0 12.5 8.2 

840 34.4 HTH, GP, HP 16.3% 5.6 29.3% 10.1 20.0% 6.9 3.2 1.3 

845 94.5 HTH, GP, UB 3.3% 3.1 16.6% 15.7 16.6% 15.7 0.0 12.6 

855 30.0 HIM, GP 24.0% 7.2 31.0% 9.3 24.0% 7.2 2.1 0.0 

856 30.9 HIM, GP 22.9% 7.1 29.9% 9.32 22.9% 7.1 2.2 0.0 

865 50.3 HIM, GP 22.7% 11.4 29.7% 14.9 22.7% 11.4 3.5 0.0 

875 12.7 HIM, SDT, GP 8.7% 1.1 26.6% 3.4 20.0% 2.5 0.8 1.4 

900 23.0 HIM, GP 0.9% 0.2 13.9% 3.2 13.9% 3.2 0.0 3.0 

915 54.6 HIM, SDT, GP, UB 0.0% 0.0 23.0% 12.5 20.0% 10.9 1.6 10.9 

940 4.7 SDT, HP 0.0% 0.0 10.0% 0.5 10.0% 0.5 0.0 0.5 

1035 20.8 HIM, GP 23.0% 4.8 30.0% 6.3 23.0% 4.8 1.5 0.0 

1061 21.9 HP 1.4% 0.3 1.4% 0.3 1.4% 0.3 0.0 0.0 

1065 45.2 HTH, GP 2.0% 0.9 15.0% 6.8 15.0% 6.8 0.0 5.9 

1085 24.0 HIM, GP 23.0% 5.5 30.0% 7.2 23.0% 5.5 1.7 0.0 

1100* 20.5 HTH, HP 24.4% 5.0 32.4% 6.6 24.4% 5.0 1.6 0.0 

1110 26.3 HTH, GP 25.5% 6.7 32.5% 10.1 25.5% 6.7 3.4 0.0 

1135 84.1 HIM, GP 23.1% 19.4 30.1% 25.3 23.1% 19.4 5.9 0.0 

1160 29.9 HTH, SDT, GP 24.4% 7.3 41.4% 12.4 24.4% 7.3 5.1 0.0 

1165 10.6 HTH, PP, GP, HP 24.6% 2.6 41.6% 4.4 24.6% 2.6 1.8 0.0 

1175 46.9 HIM, SDT, GP 24.1% 11.3 41.1% 19.3 24.1% 11.3 8.0 0.0 

1180 41.3 HIM, SDT, GP 24.2% 10.0 41.2% 17.0 24.2% 10.0 7.0 0.0 

1181 21.7 HIM, GP 1.4% 0.3 14.4% 3.1 14.4% 3.1 0.0 2.8 

1190 15.6 HIM, SDT, GP 6.4% 1.0 29.4% 4.6 20.0% 3.1 1.5 2.1 

1195 38.7 HTH, SDT, GP 0.5% 0.2 23.5% 9.1 20.0% 7.7 1.4 7.5 

1205 68.5 HIM, SDT, GP, UB 0.4% 0.3 23.7% 16.2 20.0% 13.7 2.5 13.4 

1210 6.6 HIM, GP 24.4% 1.6 37.4% 2.5 24.4% 1.6 0.9 0.0 

1215 128.3 HIM, GP, UB 13.3% 17.1 26.3% 33.7 20.0% 25.7 8.1 8.6 

1230* 111.2 HTH, HP 30.9% 34.4 38.9% 43.3 30.9% 34.4 8.9 0.0 

1235 30.7 HIM, SDT, GP 25.0% 7.7 42.0% 12.0 25.0% 7.7 7.1 0.0 

1245 68.8 HTH, GP 1.9% 1.3 14.9% 10.2 14.9% 10.2 0.0 8.9 

1246* 17.1 HTH, HP 4.7% 0.8 12.7% 2.2 12.7% 2.2 0.0 1.4 

1255 46.2 HTH, GP 20.8% 9.6 27.8% 12.8 20.8% 9.6 3.2 0.0 

1260* 172.0 HTH, HP 24.8% 42.6 32.8% 56.4 24.8% 42.7 13.8 0.1 

1265 36.5 HTH, GP 20.3% 7.4 27.3% 10.0 20.3% 7.4 2.6 0.0 

1275* 18.1 HTH, HP 27.0% 4.9 35.0% 6.4 27.0% 4.9 1.5 0.0 

1310* 10.5 HTH, HP 24.8% 2.6 32.8% 3.4 24.8% 2.6 0.8 0.0 

Total 5771 703 1,567 1,166 400 464 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

79

Alternative D

Alternative D proposes to commercial harvest 5.2 million board feet on 2,616 acres. Alternative 

D has an additional 312 acres of fuel reduction activities outside of harvest units. Logging 

systems and prescriptions proposed in Alternative D are identical to Alternatives B where 

proposed units overlap. Region 6 and LRMP Standards and Guidelines would not be 

exceeded in any activity area. Therefore, the proposed actions comply with LRMP 

standards and guidelines SL-3 and SL-4, and Regional policy (FSM 2520, R-6 Supplement 

No. 2500-98-1) for maintaining soil productivity. 

Access Management (Roads) 

As in Alternatives B and C, there would be no new construction of permanent transportation 

system roads. Commercial activities would require the use and maintenance of 76 miles of 

system roads under Forest Service jurisdiction. Road maintenance activities includes roadside 

brushing, removal of hazard trees, blading and shaping of travel way, restoring existing surface 

drainage, cleaning culverts and ditches, and installing water bars after periods of haul. 

Alternative D would require approximately 4.7 miles of temporary road construction. All 

temporary roads would be restored to a proper hydrologic condition following completion of 

activities. 

Mechanical operations would occur on sufficient snow or frozen ground in most harvest units that 

contain known or suspected populations of matsutake mushrooms. This is defined to have a snow 

depth of at least 1 foot of packed snow (not powder snow) and/or at least 6 inches of frozen 

ground. An indication of potential detrimental disturbance would be identifiable when ruts, or 

indentations in the ground after equipment travel appears 6 inches in depth or greater. This will 

apply to the following units: 125, 195, 200, 265, 270, 300, 315, 316, 335, 340, 410, 820, and 845. 

However, it is not required in units prescribed for advanced harvest systems if they do not use 

shears or feller/bunchers 

Table 3-15 displays a summary of the proposed activities in Alternative D. Measurements (acres 

and miles) are approximate. 

Table 3-15. Alternative D Summary 

Harvest and Fuels Reduction Activities (acres) 

 Ground-based Tractor 

 Skyline or Helicopter 

 “Fuels Only” Outside Harvest Units

2,227 ac. 

77 ac. 

312 ac. 

Road Management (miles) 

 Temporary Road Construction 

 Commercial Haul 

 Road Maintenance 

4.7 mi. 

76.0 mi. 

76.0 mi. 

Soils Resources (acres) 

 Current Detrimental Soil Condition 

 Soil Restoration (subsoiling) 

 Detrimental Soil Condition After Soil Restoration 

 Activities on Sensitive Soils 

166 ac. 

119 ac. 

468 ac. 

151 ac.

Units where temporary road construction is needed: 15, 30, 125, 135, 200, and 615. 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

80

Ground Disturbing Management Activities

Of the action alternatives, implementation of Alternative D would result in 

potentially the least extent of physical soil effects, mainly from compaction. 

Ground-disturbing management activities vary in their intensity of site disturbance. The following 

conclusions summarize the potential increases in detrimental soil conditions associated with 

temporary roads and logging transportation system needed to facilitate yarding operations in each 

of the activity areas. 

Under implementation of Alternative D (2,616 ac), existing detrimental disturbance within units 

is 166 acres (Table 3-15). After harvest operations and before restoration activities, there would 

be an additional 421 acres of soils classified as detrimental condition for a total 587 acres. Soil 

restoration activities would rehabilitate approximately 119 acres. The total acres of detrimental 

disturbance after restoration activities are completed would be 468 acres. For a display of a unit 

by unit basis of how each meets Forest and Regional Soil Quality Standards and Guidelines after 

restoration activities, reference Table 3-18. Typically, stand tendering (such as thinning and fuels 

reduction activities) is needed every 20-30 years. Some areas in a compacted state (such as roads 

and trails) are retained for future management access. 

As displayed in Alternative B, Alternative D uses the same rationale for estimates of existing and 

predicted amounts of detrimental soil conditions associated with temporary roads and logging 

facilities. These totals are included in the percentages displayed for each of the proposed activity 

areas in Table 3-18. 

As in Alternatives B and C, Alternative D mechanical operations would occur on sufficient snow 

or frozen ground in most harvest units that contain known or suspected populations of matsutake 

mushrooms. This is defined to have a snow depth of at least 1 foot of packed snow (not powder 

snow) and/or at least 6 inches of frozen ground. An indication of potential detrimental 

disturbance would be identifiable when ruts, or indentations in the ground after equipment travel 

appears 6 inches in depth or greater. This will apply to the following units: 125, 195, 200, 265, 

270, 300, 315, 316, 335, 340, 820, and 845, totaling 742 acres. 

Alternative D utilized the same assumptions and methodologies to calculate effects to soil quality 

and a unit by unit basis is displayed in Table 3-18. 

Sensitive Soils 

Under Alternative D there would be activity on 151 acres of sensitive soils. As described in 

Alternative B, project design criteria such as advanced logging systems in units over 30 percent 

slope include: 195, 340, and 1246 (Table 3-17). 

The Soils Resource Inventory has identified units that have seasonal high water tables (Table 3-

16). In the majority of these units, there is a small portion adjacent to a riparian or wet area. All 

units would be outside the riparian zones (ACS and RHCA) with a minimum 150 feet (non-fish 

bearing) and 300 feet (fish bearing). All boundaries would have on-site visits to verify correct 

distances prior to activity. 

There are a large number of units that have been identified as sensitive soils due to frost pockets. 

Frost pockets can hinder growth of some tree species when they are first planted. Since the BLT 

project prescriptions require retention of sufficient trees to be fully stocked and no planting is 

needed, advanced harvest systems are not necessary. There are no units in Alternative D that 

overlay soils identified as “unsuitable for timber production”. 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

81

Table 3-16. Mechanical Vegetation Activities on Landtypes that Contain Sensitive Soils in 

Alternative D 

Management Concern Total Acres Alternative D Units 

Slopes greater than 30 

Percent, High Erosion 

Hazard 

31 195, 300, 340, 615, 725, 

751, 845, 1246 

Low productivity sites 

with low fertility and 

climatic factors/ or 

high water tables 

120 

80, 115, 200, 265, 270, 

295, 300, 315, 317, 335, 

340, 355, 410, 455, 610, 

751, 840, 1061, 1205, 

1265, 1300 

Table 3-17. Alternative D Units with Slopes Greater Than 30 Percent Prescribed for 

Advanced Logging Systems 

Unit Soil Code 

Acres of Sensitive 

Soils 

Unit Total 

Acres 

Sensitive Soils 

Percent of 

Unit 

195 9N 11.1 37.5 30% 

340 9C 8.0 22.7 35% 

1246 9N 6.3 17.1 37% 

Total 25.4 77.3 

Table 3-18. Estimated Effects to Soil Productivity for Alternative D 

Unit19 Acres 

Proposed 

Mechanical 

Activities20

Existing 

Detrimental 

Soil Conditions

Percent/Acres

Detrimental Soil 

Disturbance 

Associated with 

Management 

Activities21

Percent/Acres 

Detrimental Soil 

Conditions After 

Soil Restoration 

Percent/Acres 

Restored 

Acres 

Increase in 

Detrimental 

Soil 

Conditions 

after Activity 

is Complete

Acres 

15 71.1 HIM, GP 4.1% 2.9 17.1% 12.2 17.1% 12.2 0.0 9.3 

30 46.5 HTH, SDT, GP 1.7% 0.8 24.7% 11.5 20.0% 9.3 2.2 8.5 

45 49.1 SDT, HP 7.3% 3.6 30.3% 14.9 20.0% 9.8 5.1 6.2 

80 90.2 SDT, GP 17.3% 15.6 40.3% 36.4 20.0% 18.0 18.3 2.4 

115 150.7 SDT, HP 3.0% 4.5 16.0% 24.1 16.0% 24.1 0.0 19.6 

125 85.7 HIM, GP 0.7% 0.6 13.7% 11.7 13.7% 11.7 0.0 11.1 

135 102.7 HIM, SDT, GP 16.2% 16.6 39.2% 40.3 20.0% 20.5 19.7 3.9 

170 13.0 HTH, GP, UB 1.5% 0.2 14.5% 1.9 14.5% 1.9 0.0 1.7 

195* 37.5 HTH, HP 2.7% 1.0 10.7% 4.0 10.7% 4.0 0.0 3.0 

200 240.7 HIM, SDT, GP 1.9% 4.6 24.9% 59.9 20.0% 48.1 11.8 43.5 

260 8.2 HTH, GP 0.0% 0.0 13.0% 1.1 13.0% 1.1 0.0 1.1 

265 66.7 HIM, SDT, GP 0.1% 0.1 23.1% 15.4 20.0% 13.3 2.1 13.2 

270 66.3 HTH, SDT, GP 2.0% 1.3 24.9% 16.5 20.0% 13.3 3.2 12.0 

295 13.2 HIM, SDT, GP 1.5% 0.2 24.5% 3.2 20.0% 2.6 0.6 2.4 

300 51.8 HTH, SDT, GP, UB 10.2% 5.3 33.2% 17.2 20.0% 10.4 6.8 5.1 

315 18.0 HTH, GP 20.0% 3.6 33.0% 6.0 20.0% 3.6 2.3 0.0 

 

19Asterisk * denotes advanced harvest systems such as cable or helicopter 20HTH = Commercial Thin, GP = Grapple Piling of Fuels, HIM = Harvest Improvement Cut, SDT = Small Diameter 

Thin with Special Forest Products (post and pole, firewood or biomass) Opportunity, HP = Hand Pile, UB = Underburn 21 Includes calculations for post-sale activities and existing detriment conditions 
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

82

Unit19 Acres 

Proposed 

Mechanical 

Activities20

Existing 

Detrimental 

Soil Conditions

Percent/Acres

Detrimental Soil 

Disturbance 

Associated with 

Management 

Activities21

Percent/Acres 

Detrimental Soil 

Conditions After 

Soil Restoration 

Percent/Acres 

Restored 

Acres 

Increase in 

Detrimental 

Soil 

Conditions 

after Activity 

is Complete

Acres 

316 7.2 HTH, GP 27.8% 2.0 40.8% 2.9 27.8% 2.0 0.9 0.0 

317 5.3 HTH, GP 9.4% 0.5 21.9% 1.2 20.0% 1.1 0.1 0.6 

335 50.5 HTH, GP 0.6% 0.3 13.6% 6.9 13.6% 6.9 0.0 6.6 

340* 22.7 HTH, HP 22.9% 5.2 30.9% 7.0 22.9% 5.2 1.8 0.0 

355 12.3 HIM, GP 2.4% 0.3 15.4% 1.9 15.4% 1.9 0.0 1.6 

410 8.2 HTH, SDT, GP 23.5% 1.9 46.0% 3.8 23.0% 1.9 1.9 0.0 

455 5.5 HTH, GP 1.8% 0.1 14.8% 0.8 14.8% 0.8 0.0 0.7 

480 16.7 HTH, GP 1.2% 0.2 14.2% 2.4 14.2% 2.4 0.0 2.2 

520 91.6 HIM, GP 0.5% 0.5 13.5% 12.4 13.5% 12.4 0.0 11.9 

525 94.0 HIM, SDT, GP 25.6% 24.1 48.6% 45.7 25.6% 24.1 21.6 0.0 

540 11.1 HTH, GP 0.9% 0.1 13.9% 1.5 13.9% 1.5 0.0 1.4 

580 14.4 HTH, GP 1.4% 0.2 13.4% 1.9 13.4% 1.9 0.0 1.7 

610 46.1 HIM, SDT, GP 1.1% 0.5 24.1% 11.1 20.0% 9.2 1.9 8.7 

615 65.4 HIM, GP, UB 0.6% 0.4 13.5% 8.8 13.5% 8.8 0.0 8.4 

616 32.2 HIM, GP, UB 2.4% 0.8 15.4% 5.0 15.4% 5.0 0.0 4.2 

645 5.8 HIM, GP 3.4% 0.2 16.4% 1.0 16.4% 1.0 0.0 0.8 

646 8.2 HIM, GP 3.6% 0.3 16.6% 1.4 16.6% 1.4 0.0 1.1 

725 20.7 HTH, GP 27.1% 5.6 40.0% 8.3 27.0% 5.6 2.7 0.0 

751 12.2 HIM, GP 2.0% 0.2 15.0% 1.8 15.0% 1.8 0.0 1.6 

785 188.1 HIM, GP, UB 3.8% 7.1 16.8% 31.6 16.8% 31.6 0.0 24.5 

790 11.0 HTH, SDT, GP 1.8% 0.2 24.8% 2.7 20.0% 2.2 0.5 2.0 

800 15.4 HTH, GP, UB 4.5% 0.7 17.5% 2.7 17.5% 2.7 0.0 2.0 

815 124.3 HTH, GP, UB 5.4% 6.7 18.4% 22.9 18.4% 22.9 0.0 16.2 

820 20.8 HTH, SDT, GP 3.9% 0.8 26.9% 5.6 20.0% 4.2 1.4 3.4 

840 34.4 HTH, GP 16.3% 5.6 29.3% 10.1 20.0% 6.9 3.2 1.3 

845 94.4 HTH, GP, UB 3.3% 3.1 16.6% 15.7 16.6% 15.7 0.0 12.6 

1061 21.4 HP 1.4% 0.3 1.4% 0.3 1.4% 0.3 0.0 0.0

1195 38.6 HTH, SDT, GP 0.5% 0.2 23.5% 9.1 20.0% 7.7 1.4 7.5 

1205 66.0 HIM, SDT, GP, UB 0.5% 0.3 23.7% 15.6 20.0% 13.2 2.4 12.9 

1215 122.5 HIM, GP, UB 14.0% 17.1 26.3% 32.2 20.0% 24.5 7.7 7.4 

1245 68.8 HTH, GP 1.9% 1.3 14.9% 10.2 14.9% 10.2 0.0 8.9 

1246* 8.0 HTH, HP 10.0% 0.8 12.7% 1.0 12.7% 1.0 0.0 0.2 

1255 46.2 HTH, GP 20.8% 9.6 33.8% 15.6 20.8% 9.6 6.0 0.0 

1265 36.1 HTH, GP 20.5% 7.4 33.3% 12.0 20.5% 7.4 4.6 0.0 

1300* 47.5 HIM, SDT, GP 0.0% 0.0 23.0% 10.9 20.0% 9.5 1.4 9.5 

Total 2,616 166 587 468 119 303 
Environmental Impact Statement BLT Project 

 Chapter 3 - Soils 

83

Figure 3-1. Sensitive Soil Areas Overlaid with Activity Units T.24S. T.25S. R8E. R9E. Crescent Lake

58

- SU 79

61

60

5825

5385

6020

5834

79 55

5679

9758

9760

5826

5830

5216

85 41

5815

5828

79 15

9768

6030

5850

6015

3579

9756

9770

5852

5820

60

5825 06 03

5216

12 6 5

9760

60

5825

6030

5830

5834

5828

5216

5815

5825

9768

9770

Action Alternative Sensitive SoilsAction Alternative

012 0.5

Miles

The USDA is an equal opportunity provider and employerjm 9/22/08T:\r06\des\cre\project\eis\eis_blt\gis\map_product

BLT BoundaryState-BLM-County RoadsArterial RoadsCollector Roads
BLT Project Environmental Impact Statement 

Chapter 3 - Soils 

84

Cumulative Effects 

There are no additive effects associated with past, present, and foreseeable actions because the scope of 

the analysis has defined an activity area as the most logical zone of influence (Forest Plan, page 4-70 

and 71, Table 4-30, Footnote #1). Cumulative soil disturbance from past and proposed activities would 

exceed Regional Forest Plan Standards and Guidelines for soil quality until soil restoration (required 

mitigation) occurs. Past and present actions have been discussed within the context of the existing 

condition because that is the most informative place. Past and present timber sales have been included 

in the existing condition using the Forest Activity Tracking System (FACTS) database. Also, the 

existing condition accounts for access (roads), dispersed recreation, grazing from 1994 and Off 

Highway Vehicle use. For these reasons, the analysis of past actions other than those listed in this 

section is based on current environmental conditions. 

In 2009, the Forest Service will implement the Travel Management Rule which restricts off-trail travel 

to designated routes. In the future, it is possible through site-specific analysis and a public process to 

designate a trail system within the BLT analysis area, but currently there is no such proposal. Upon 

implementation of the Travel Management Rule, it is assumed that inappropriate OHV access in the 

analysis area would be reduced, however the overlap onto activity units for now and in the future is 

expected to be so minimal, the effects are not considered additive. 

There are no future foreseeable actions with potential for causing detrimental soil conditions that 

overlap units of activity in the BLT analysis area. The following table summarizes the action 

alternatives. 

Table 3-19. Summary of the Action Alternatives 

Alternative B Alternative C Alternative D 

Harvest Acres 7, 499 ac. 5,771 ac. 2,616 ac. 

Estimated Volume 12.1 mmbf 9.8 mmbf 5.2 mmbf 

Ground Based Logging Systems 6,666 ac. 5,027 ac. 2,227 ac. 

Advanced Logging Systems 420 ac. 410 ac. 77 ac. 

Additional Fuel Treatments 413 ac. 334 ac. 312 ac. 

Temporary Roads 9.7 mi. 8.7 mi. 4.7 mi. 

Activities On Sensitive Soils 462ac. 311 ac. 151 ac. 

Miles of Road Maintenance 160 130 76 

Existing Detrimental Soil 

Disturbance 925 ac 703 ac. 166 ac. 

Restoration 530 ac. 500 ac. 119 ac. 

Detrimental Soils After Restoration 1,524 ac. 1,166 ac. 468 ac. 

Increase Detrimental Soils 

Condition over Existing Conditions 1,129 ac. 864 ac. 421 ac. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

85

Forested Vegetation __________________________________ 

Introduction 

The forest conditions in the BLT planning area are characterized by departures from reference 

conditions in several classes, especially higher densities in ponderosa pine. Many stands are growing at 

reduced rates and experiencing large tree mortality due to inter-tree competition and dwarf mistletoe 

infection. Also, the last mountain pine beetle epidemic during the 1980s attacked the largest trees and 

cohorts, leaving a residual stand with low potential for improvement. This condition also places the 

future for the BLT area at higher risk, particularly to loss of the larger trees, as individual tree stress 

increases. 

The Desired Future Condition for vegetation in the BLT analysis area is stands that limit the extent of 

the disturbance process. Tree density is at a level that promotes future tree growth and minimizes 

density related mortality. Overstory trees are less likely to infect understory trees with dwarf mistletoe. 

Management Direction 

The BLT area is bisected by management direction found in the Deschutes Land and Resource 

Management Plan (LRMP; USDA Forest Service 1990) as amended by the Northwest Forest Plan and 

Regional Forester’s Plan Amendment 2, Interim Riparian, Ecosystem, and Wildlife standards (Eastside 

Screens). Underlying direction which is a forest-wide Standard and Guideline for forest health 

specifies: “Management strategies should emphasize prevention of pest problems rather than 

suppression activities (FH-3, p. 4-36). 

The main management allocation within the Northwest Forest Plan within the BLT area is for matrix 

lands. While there are no specific standards and guidelines for forest health, it acknowledges 

production of timber and other commodities as an important objective while providing connectivity 

between Late Successional Reserves and providing habitat for a variety of organisms (Record of 

Decision, page B-1). 

The Eastside Screens has the following direction: 

Historical Range of Variability: Characterize the proposed timber sale and its associated watershed 

for patterns of stand structure by biophysical environment and compare to the Historical Range of 

Variability (HRV). Note, HRV is a reference condition and managing within the historical range would 

provide for those species that survived to the present (Eastside Screens, page 4). 

Timber Sale within Late and Old Structure (LOS): Some timber sale activities can occur within 

LOS stages that are within or above HRV in a manner to maintain or enhance LOS within that 

biophysical environment. It is allowable to manipulate one type of LOS to move stands into the LOS 

stage that is deficit if this meets historical conditions (Eastside Screens, Scenario A, page 9). 

Within a particular biophysical environment within a watershed, if the single, existing late and old 

structure (LOS) stage is within or above HRV, or if both types of LOS stages occur and both are within 

or above HRV, then timber harvest can occur within these stages as long as LOS conditions do not fall 

below HRV (Eastside Screens, Scenario B, page 13). 

Maintain all remnant late and old seral and/or structural live trees greater than 21 inches in diameter 

that currently exist within stands proposed for harvest activities (Eastside Screens, page 10). 

The BLT project proposes activity within LOS stands. There would be no net loss of LOS stands. 

Table 3-24 displays Historical Range of Variation for medium and large trees by plant association 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

86

group and seral stage within the Upper Little Deschutes 5th Field Watershed and how the BLT project 

affects that range. 

Methodology of Analysis and Sources of Information 

Sources of vegetation information and data used in this analysis are: Common Stand Exam plots (1996, 

1997), the 1998 Crescent Ranger District Landscape Assessment Plan Summary Report, PMR data, PI 

data, Deschutes National Forest Plant Association Map, 2001 infrared and 2004 color aerial 

photography, and walk-through stand exams and diagnosis (2002, 2003). 

PMR Data 

PMR data was derived from 2001 Landsat imagery updated to 2004 (latest available) to reflect changes 

due to Timber Harvest and Large Wildfire. This data set provides information on size/structure, species 

composition, and canopy closure at 25 meter resolution (Simpson et al. 1994). This data along with 

field reconnaissance and Viable Ecosystem Modeling was used to determine existing and predicted 

future conditions within the analysis area. 

Photo Interpretation GIS Layer 

Individual stands were delineated for the entire Deschutes National Forest using photo interpretation 

between 1997 and 2000 (Forest Data Inc. 2001) 

Viable Ecosystem Model 

The Viable Ecosystem model provides a process to apply ecosystem standards to project-level 

planning. Originally developed for the Ochoco National Forest, it has since been modified for use on 

the Deschutes National Forest. This system compares existing vegetation with site potential (or 

biophysical environment). The model focuses on relationships between combinations of vegetation 

structure and species composition, and habitat requirements for animals, insects, and plants. The 

Viable Ecosystem model stratifies the environmental gradient using plant associations. The Viable 

Ecosystems Management Guide (Simpson, 1994) was used within the BLT planning area to 

characterize and compare seral structural conditions to HRV (and contains a description of Viable 

Ecosystem and analysis methods and tools used to conduct the analysis). Table 3-20 displays the 

attributes modeled. 

Table 3-20. Seral/Structural Matrix and Definitions (Seral Structural Stages) 

Species Composition 

Structure Class 

Early Mid Late 

Grass, forb, shrub (trees may be present but not dominant) E1 M1 L1 

Seedling, sapling (less than 4.9 inches in diameter) E2 M2 L2 

Pole (between 5 and 8.9 inches in diameter), high density E3a M3a L3a 

Pole, low density E3b M3b L3b 

Small (between 9 and 20.9 inches in diameter), high density E4a M4a L4a 

Small, low density E4b M4b L4b 

Med./large (21 inches in diameter and larger), high density E5a M5a L5a 

Medium/large, low density E5b M5b L5b 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

87

Limitations 

Given the uncertainty of any modeling exercise, the results are best used to compare the relative effects 

of the alternatives, rather than as an indicator of absolute effects. 

Assumptions 

The viable outputs of dense and open stands are corollaries for multi and single story stands. The 

medium/large structure class is equivalent to Late and Old Structure (LOS), as identified in the Eastside 

Screens, in all plant associations other than lodgepole. The small and medium/large structure class is 

equivalent to lodgepole LOS. 

Methods - Determining Locations of LOS Stands 

The pixilated data from the Viable Ecosystem Model was aggregated into stand level values in order to 

determine areas of LOS and other structural and compositional characteristics. Using a Geographic 

Information System (GIS) software package, the Viable data was overlaid on the Photo Interpretation 

stands. The values of each pixel in every stand were counted and the value which was most common 

was assigned to the entire stand. 

Existing Conditions 

Descriptions of the current vegetative condition are grouped by plant association groups, or PAGs. The 

plant associations have been evaluated for common characteristics and grouped together to form the 

PAGs. A very brief description of each PAG begins each section. Detailed PAG biophysical 

descriptions can be found in Plant Associations of the Central Oregon Pumice Zone (Volland 1988). 

Complete information on current seral/structural stages compared with HRV can be found in Appendix 

B. 

Conditions common to all PAGs are as follows: 

• Past clearcuts and shelterwood regeneration cuts are common in all but high elevation mountain 

hemlock and whitebark pine plant associations. These are typically stocked with ponderosa 

pine or lodgepole pine, that are mostly twenty years old or more. 

• Small trees in many of the regenerated stands have been thinned with varying degrees of slash 

removal or piling completed. The common approach to these treatments is to retain at least 5 

percent of the activity unit unthinned for diversity. 

• Stumps of trees cut in the 1950s are common on most PP and MC areas that did not have 

regeneration cuts. Generally, these were ponderosa pine cut to meet the Keen’s Risk Tree 

Classification (Miller and Keen 1960) based on age and vigor, to remove the trees most highly 

susceptible to western pine beetle (Dendroctonus occidentalis). 

• During the 1970s, it was common in this area to fall large dead trees (snags) and leave them 

lay. This was done to reduce the chance of lightning-caused fires since the thinking of the day 

was that these large snags could attract lightning similar to a lightning rod. This most often 

was done to the largest and oldest snags since they could be spotted from a distance, generally 

were the taller trees in the stands, and they were the result of endemic bark beetle activity in 

these stands rapidly becoming overstocked. 

• Shrubs are common in disturbed areas on most of the sites. In the dry lodgepole pine and 

ponderosa pine, bitterbrush is a common shrub that can eventually dominate the ground 

vegetation until shaded out by a closed canopy of conifers. Snowbrush ceanothus and greenleaf 

manzanita are common in the mixed conifer dry and ponderosa pine wet stands. Golden 

chinquapin is also a common shrub in some of the higher productivity areas. Upland willow 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

88

can be found in some mixed conifer areas, especially on north slopes of the buttes. Experience 

in this area has shown that competition of shrubs with conifer regeneration is generally not of 

concern. As the conifers grow, they tend to shade out the shrubs. The biggest concern for 

conifers in brushy areas is from fire since the conifers often grow right up through the canopies 

of the shrubs. 

Lodgepole Pine (approximately 39,000 acres and 49 percent) The BLT area has the bulk of the 

lodgepole pine (dry) acres on the Crescent Ranger District. It is characterized by stands dominated by 

lodgepole pine in some of the dryer, lower productivity plant associations. Lodgepole pine moist, 

(approximately 400 acres and less than 1 percent of the planning area), and lodgepole pine wetlands, 

(approximately 1000 acres and 1.3 percent of the planning area) are characterized by stands dominated 

by lodgepole pine in some of the moister, higher productivity plant associations, typically along streams 

or wet areas. Under Viable Ecosystem modeling, lodgepole pine moist was split among dry and 

wetlands. 

Vegetation is characterized by lodgepole pine dominating the conifer component, often with 

Engelmann spruce present in areas with surface moisture or readily available sub-surface moisture. The 

regenerated stands tend to be very dense with natural regeneration often supplementing any planted 

trees to the point where several thousand trees per acre may be found. 

During the 1980s, a mountain pine beetle (Dendroctonus ponderosae) outbreak killed most of the 

lodgepole pine overstories throughout most of central Oregon in the lower elevations. Thousands of 

acres of salvage activities in these stands have been completed since then, but some areas in the 

analysis area remain that had very little or no active management. These areas are characterized by 

“jackstrawed” remains of the fallen overstory trees, remaining overstory trees usually less than 8 in 

diameter, most often with very poor crowns, and dense natural regeneration from the residual overstory 

trees. 

In general, lodgepole stands are vulnerable to mountain pine beetle when they are about 100 years old 

and are comprised of approximately 100 trees per acre that are 9 inches in diameter or greater. Within 

the BLT area, many of the stands were not ready for the 1980-era insect epidemic and are now in the 

window for the next insect attack. 

In areas where previous salvage activities have occurred, the remaining overstory trees are usually less 

than 8 inches in diameter, most often with very poor crowns, and have dense natural regeneration. As 

typical where salvage activities have occurred, less of the down and dead material remains on these 

sites than would have under a passive management scenario. 

Stands that are classified as “imminent susceptible” have been defined as where conditions are such that 

it is very likely a considerable change in structure or character of forest due to a large scale disturbance 

is likely to occur within 10 years. As defined, it relates to the concern for loss of desired wildlife 

habitat, long-tern loss of mushroom productivity, and loss of desired tree species structure. Thirty-three 

(33) percent of lodgepole dry PAGs on the Crescent District are classified as imminently susceptible to 

insect and disease outbreaks (LAP 1998). In lodgepole pine, it is defined as size structure class small 

(9.0 – 20.9 inches in diameter), its combination and larger size classes, and canopy level greater than 71 

percent. When and where there is a proportion of trees greater than 9 inches (roughly 90 trees per acre), 

the stand is considered imminently susceptible to change. The main concern is for mountain pine beetle 

attack and subsequent elevated risk from wildfire. 

Currently, the BLT project is bordered by a wide scale mountain pine beetle infestation event in 

lodgepole pine to the north and south along the Cascade Mountain Crest. Mortality is most evident 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

89

from Diamond/Crater Lake north through the Three Creeks area (Sisters) up to Mount Jefferson and 

over to the Willamette National Forest. 

Lodgepole Pine

-10

-8

-6

-4

-2

0

2

4

6

8

10

DryL5b

MoistL3aMoistL4aMoistL5b

WetL3aWetL5b

WetlandsL3aWetlandsL4bWetlandsL5b

Seral/Structural Stage

Departure from HRV in %

Figure 3-2. Lodgepole Pine Departure from Historical Range of Variability 

Ponderosa Pine - Includes PPD (ponderosa pine dry, 13,010 acres and 16 percent of the planning area) 

and PPM (ponderosa pine mesic, 3,045 acres and 4 percent of the planning area). These stands tend to 

be on the lower slopes of the Cascade Range and the volcanic buttes in the area. At present, few of 

these stands are entirely ponderosa pine. Due to fire exclusion, prolific seed source, and adjacency of 

pure lodgepole pine stands have aggressively invaded many stands previously dominated by ponderosa 

pine. 

The largest overstory trees are 200 to 400 years old. Fire scars are common. Dwarf mistletoe, western 

pine beetle, and wildfires are the most common disturbance agents. Understory trees are ponderosa 

pine, with lodgepole pine often outnumbering them as noted above. The dense stands of ponderosa 

pine regeneration can often stagnate rather than show much competition-induced mortality. 

 

Nineteen (19) percent of the ponderosa pine PAGs are classified as imminently susceptible to insect and 

disease outbreaks (LAP 1998). In ponderosa pine, it is defined as size structure class small (9.0 – 20.9 

inches in diameter), its combination and larger size classes, and canopy level greater than 56 percent. 

In this PAG, the primary agents of change at the landscape scale are the mountain and western pine 

beetles. These agents tend to selectively target the larger trees that are under stress, principally due to 

competition for moisture, with incidence of change greater during periods of drought. 

The stand density/canopy cover tends to reflect the density of small tree and larger size classes, 

although based on experience in this PAG, a high degree of stress can be attributed to seedling and 

sapling size class not accounted for in the canopy cover percent, thus the susceptibility of losing large 

trees may be much higher than estimated. 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

90

Dry Ponderosa Pine

-20

-15

-10

-5

0

5

10

15

20

E2aE3aE4aE4bE5aE5b

M2aM3aM4aM4bM5aM5b

L2aL2bL3bL5b

Seral/Structural Stage

Departure from HRV in %

Figure 3-3. Ponderosa Pine Dry Departure from Historical Range of Variation

Moist Ponderosa Pine

-60

-50

-40

-30

-20

-10

0

10

20

30

E3a E3b M2b M3b M4b L3b L4b L5b

Seral/Structural Stage

Departure from HRV in%

Figure 3-4. Ponderosa Pine Moist Departure from Historical Range of Variation 

Mixed Conifer - This PAG Includes MCD (mixed conifer dry, 5,425 acres and 7 percent of the 

planning area), MCM (mixed conifer moist, 6,523 acres and 8 percent of the planning area), and MCW 

(mixed conifer wet, 357 acres and 1 percent of the planning area). These stands are typically located on 

the slopes of ridges and buttes ranging from about 4500 feet to over 6000 feet in elevation. Stands are 

dominated by a variety of conifer species. Prior to fire exclusion, these stands appeared to have 

frequent fire regimes. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

91

Ponderosa pine and, in some areas, Douglas-fir comprise the oldest and usually the largest trees in the 

overstories of these stands. Fire scars, scorched bark, and scattered charcoal on the ground are very 

common on these sites. Mid and understories are usually dominated by the true fir in dense, pole-sized 

thickets. Lodgepole pine is a common component of the mid and understories of these stands as well. 

Down and dead lodgepole pine is a common component of these stands. 

At the higher elevations, the true firs are dominated by Shasta red fir, which is fairly common on the 

Crescent Ranger District. Grand fir/white fir dominates the mid and lower elevations. Douglas-fir is 

common as is ponderosa pine, but both are definitely subordinate in stocking to the other species. 

Isolated mountain hemlock is also present in many of these stands. 

While departure from HRV varies, the largest departures occur in an over abundance in the larger less 

dense classes. Fifty four (54) percent of the mixed conifer dry PAGs on the Crescent District are 

classified as imminently susceptible to insect and disease outbreaks (LAP 1998). In mixed conifer dry, 

it is defined as size structure class small (9.0 – 20.9 inches in diameter), its combination and larger size 

classes, and canopy level greater than 56 percent. 

This PAG becomes increasingly unstable during extended periods of drought with large early seral 

species dying and/or fir component killed by moisture stress or fir engraver beetle attack. 

The stand density/canopy cover tends to reflect the density of small tree and larger size classes, 

although based on experience in this PAG, a high degree of stress can be attributed to seedling and 

sapling size class not accounted for in the canopy cover percent, thus the susceptibility of losing large 

trees may be much higher than estimated. 

Mixed Conifer Dry

-10

-5

0

5

10

15

20

E3b

E4a

E4b

E5a

E5b

M3a

M3b

M4a

M4b

M5b

L2

L3b

L4b

L5b

Seral/Structural Stage

Departure from HRV in %

Figure 3-5. Mixed Conifer Dry Departure from Historical Range of Variation 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

92

Mixed Conifer Moist

-6

-4

-2

0

2

4

6

8

10

12

E3b E4b E5b M3a M4a M5a M5b L4b L5b

Seral/Structural Stage

Departure from HRV in percent

Figure 3-6. Mixed Conifer Moist Departure from Historical Range of Variation 

Mountain Hemlock - (7,220 acres and 9 percent of the planning area); most often found above about 

6,000 feet in elevation, these stands are characterized by common presence of mountain hemlock with 

Shasta fir, western white pine, and lodgepole pine intermixed. Root rot pockets (laminated root rot, 

Phellinus weiri) are common in these stands. Where such pockets have existed for more than a couple 

of decades they are characterized by western white pine, lodgepole pine, and dense mountain hemlock 

regeneration. The pines are more resistant to the root rot than the mountain hemlock. The mountain 

hemlock tends to grow for two or three decades, before succumbing to the root rot. These pockets tend 

toward increasingly high fuel loads as the trees die and fall over. 

Areas outside of root rot pockets tend to be dominated by mountain hemlock or lodgepole pine. 

Lodgepole pine is an aggressive invader in disturbed areas and may dominate in disturbed areas near a 

lodgepole pine seed source. Most of these areas are dominated by mountain hemlock, usually of 

similar age, since these areas have a fire regime of several centuries without fire followed by large scale 

stand replacement fires (Agee, p.253-254, 1993, Dickman and Cook, Can. J. Bot Vol 67, p.2005-2016, 

1989). 

The smaller mountain hemlock areas on the tops of buttes tend to be more mixed with other species 

than those larger stands along the crest of the Cascade Range. These stands are currently operating 

within HRV. 

Influences on Current Condition 

Fire – Policies of fire exclusion since the early 20th century are evident in current vegetation condition 

(Agee 1993). It has resulted in the increase in dense stands and reduction of early seral and 

seedling/sapling stages in some PAGs when compared to HRV shown in the Viable Ecosystems 

analysis. 

Insects and Disease - Native insects and pathogens of forest trees perform important functions in 

natural ecosystems, killing decadent trees, creating dead and down woody habitat for other species, 

recycling nutrients, and creating gaps for regeneration. Most of the time, these organisms remain at 

levels where they do not cause rapid, large-scale changes in the structure or composition of plant 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

93

communities. Yet certain conditions can trigger major insect or disease outbreaks that result in 

substantial tree mortality. The beetle outbreak of the 1980s killed most of the lodgepole pine overstories 

in the planning area. This is shown in the reduction of several categories of LOS in lodgepole PAGS. 

Outbreaks of mountain pine beetle typically display mortality on an exponential curve where the 

populations build up to epidemic proportions relatively unnoticed until tree mortality is expressed over 

large areas. 

Timber Harvest – Past regeneration harvest prior to 1994 and salvage have resulted in a reduction of 

large trees on the landscape particularly in the Mixed Conifer Plant Association Groups. 

The following table displays assumptions used for assessing effects for forested vegetation. 

Table 3-21. Mushroom Production 

Management Practices Expected Outcomes Underlying Assumptions 

Thinning the overstory Thinning trees improves matsutake 

mushroom production. 

Open stands have increased 

individual tree growth and nutrient 

cycling. 

Increased energy and water reach 

the soil. 

Fluctuations in available water and 

energy are more extreme. 

Pruning low branches 

Increasing the amount of organic 

matter on the forest floor improves 

tree growth but depresses 

production of matsutake 

Pruning reduces canopy 

interception of water and energy. 

Altering the organic litter layer Matsutake mushrooms and their 

management do not affect growth.

Soil organic matter makes soil more 

fertile for tree growth. Thicker 

organic layers favor increased 

diversity of mycorrhizal fungi. 

Matsutake mushrooms do not 

compete strongly with most other 

fungi.

Retaining largest trees on the 

landscape 

Partial cutting retains oldest trees 

and sustains productivity of 

matsutake mushroom colonies. 

Largest trees are natural foci of 

matsutake mushroom colonies. 

Piling and burning 

Piles and high severity fires, such as 

wildfire, reduce the survival of 

matsutake mushroom colonies. 

Mycorrhizae and mycelia lie near 

the soil surface and are damaged by 

fire. 

Concentrating slash burns into 

small areas minimizes negative 

effects of fire on matsutake 

mushroom colonies. 

Vegetation Health 

Direct and Indirect Effects 

Alternative A 

Under the No Action alternative, current management plans would continue to guide management of 

the analysis area. Ongoing maintenance of stands classified as Fire Regime 1 (frequent fire interval) 

would continue on 800 acres within the analysis area. No additional thinning or fuels treatments would 

be implemented to accomplish project goals. Custodial activity would continue, such as routine 

maintenance. Response to environmental emergencies, such as suppression of a wildfire, would 

continue. 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

94

A passive management scenario would continue the path of disturbance identified in the District-wide 

1998 Landscape Analysis Process. It identified 10 years as when conditions are such that it is very 

likely a considerable change in structure or character of forest stands from a large scale disturbance can 

occur. It also identified approximately 33 percent of lodgepole pine, 19 percent of ponderosa pine, and 

54 percent of mixed conifer dry are imminently susceptible to a disturbance process. 

Action Alternatives 

Stands categorized as imminently susceptible to insects and diseases were preferentially selected for 

treatment. In all actively-managed stands, although there is activity in some stands classified as Lateand Old-Structured (Table 3-24), there is no net loss of LOS and no harvest activities occur within 

stages that are below their Historical Range of Variation. 

No activities would occur in lodgepole pine moist or wet, mixed conifer wet and mountain hemlock 

PAGS. Active management was selected due to high stand density and/or poor overstory tree 

condition. Typically prescribed for HTH, dense stands are experiencing levels of intertree competition 

which result in reduced growth and an increased risk of some insect and diseases, primarily mountain 

pine beetle. Once these disturbance agents begin to express signs of mortality in a stand, it is usually 

too late and mortality is imminent. Areas selected for poor overstory tree condition are primarily 

lodgepole pine stands affected by mountain pine beetle where remaining overstory trees exhibit poor 

crowns and dwarf mistletoe which is being transmitted to the understory. These conditions are likely 

prescribed for an improvement cut (HIM). 

Vegetation Health

Direct and Indirect Effects 

Alternative B 

Alternative B would commercially thin (HTH) on 3,146 acres and Improvement Cut (HIM) on 4,018 

acres. Approximately 2,312 acres of commercial harvest would also be underburned adding to the 800 

acres of ongoing maintenance of a frequent fire regime. 

There is considerable evidence that less-dense stands of white fir, lodgepole pine, and ponderosa pine 

are less likely to experience mortality from bark beetles than are higher density stands. The two most 

plausible mechanisms in which stand density relates to damage are the reduction of trees that will 

attract bark beetles and/or an increase in individual tree vigor, which allows for better defense from 

attack (Tappeiner, Maguire, and Harrington 2007 and Fettig et al. 2007). 

The positive growth response of healthy young trees to density reduction is well known. In contrast, 

large old trees are usually thought to be intrinsically limited in their ability to respond to increased 

growing space; therefore, density reduction is seldom used in stands of old-growth trees. Latham and 

Tappeiner (2002) tested the null hypothesis that old-growth trees are incapable of responding with 

increased growth following density reduction. The diameter growth response of 271 Douglas-fir 

(Pseudotsuga menziesii), ponderosa pine (Pinus ponderosa) and sugar pine (Pinus lambertiana) trees in 

Oregon, USA, ranging in age from 158 to 650 years was examined 20 to 50 years after density 

reduction. Density reduction involved either light thinning with removal of less vigorous trees, or 

shelterwood treatments in which overstory trees were not removed. Ratios of basal area growth after 

treatment to basal area growth before treatment, and several other measures of growth, all indicated that 

the old trees sometimes benefited and were not harmed by density reduction. Growth increased by 10 

percent or more for 68 percent of the trees in treated stands, and nearly 30 percent of trees increased 

growth by over 50 percent. This growth response persisted for at least 20 years. During this 20-year 

period, only three trees in treated stands (1.5 percent) exhibited a rapid decrease in growth, whereas 

growth decreased in 64 percent of trees in untreated stands. The length of time before a growth 

response to density reduction occurred varied from 5 to 25 years, with the greatest growth response 

often occurring 20 to 25 years after treatment. These results have important implications both for the 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

95

basic biology of aging in woody plants as well as for silvicultural practices in forests with old-growth 

trees. 

Over all actively managed Plant Association Groups, thinning and improvement cuts would reduce 

density, increasing tree vigor and resistance to disease. Improvement cuts would reduce the chance that 

understories would be infected by mistletoe. Some individual trees within a treated stand may have an 

increased risk due to sunscald, logging damage, and wind, at least initially. This risk is relatively shortterm (2 years or less) and prescriptions are designed to maintain stand integrity at levels where trees can 

respond to more open conditions and less competition for nutrients. 

The following describes the two prescriptions employed in the action alternatives. 

Thinning (HTH) – a cultural treatment made to reduce stand density of trees primarily to improve 

growth, enhance forest health, or recover potential mortality (Helms 1998). 

Trees will be thinned to a density within the management zone with thought to future growth within the 

20 or 30 years before the next likely treatment. This will primarily be achieved by thinning from below 

– the removal of trees from the lower crown classes to favor those in the upper crown classes (Helms 

1998). After thinning, stands would average as low as 20 percent canopy cover and 50 square feet of 

basal area in lodgepole and up to 40 percent canopy cover and 180 square feet of basal area in mixed 

conifer plant associations. 

Figure 3-7. Illustration of a Stand Before Thinning (HTH) 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

96

Figure 3-8. Illustration of a Stand After Thinning (HTH)

Improvement cutting (HIM) – the removal of less desirable trees of any species in a stand of poles or 

larger trees, primarily to improve composition and quality (Helms 1998). 

Improvement cutting activities are primarily proposed in lodgepole pine stands that were impacted by 

the mountain pine beetle outbreak of the 1980s. The proportion of their overstories exhibit poor crowns 

and/or heavy mistletoe infection (generally greater than 1/3 of crown volume in mistletoe brooms) 

would be removed. These trees have poor growth rates and potential for infecting the understory with 

mistletoe is high. These stands would have fewer remaining overstory trees than in those stands that 

were thinned. The understory would contribute considerably to future growth. 

Figure 3-9. Illustration of Before Improvement Cut 
Environmental Impact Statement BLT Project 

 Chapter 3 – Forested Vegetation 

97

Figure 3-10. Illustration of After Improvement Cut 

Direct and Indirect Effects 

Alternative C 

From a vegetative health perspective, Alternative C is similar to Alternative B. It would reduce risk 

from a large disturbance (particularly from insects and wildfire) and change stands to a more 

sustainable condition on 5,771 acres versus 7,499 in Alternative B. Alternative C would commercially 

thin (HTH) on 2,643 acres and Improvement Cut (HIM) on 2,794 acres for 9.8 Million Board Feet. 

Approximately 1,764 acres of commercial harvest would also be underburned, adding to the 800 acres 

of ongoing maintenance of a frequent fire regime in ponderosa pine. 

Direct and Indirect Effects 

Alternative D 

From a vegetative health perspective, Alternative D is the least effective at changing stands to a more 

sustainable condition (total 2,616 acres versus 7,499 in Alternative B). Alternative D would 

commercially thin (HTH) on 914 acres and Improvement Cut (HIM) on 1,390 acres for 5.2 Million 

Board Feet. Approximately 1,624 acres of commercial harvest would also be underburned, adding to 

the 800 acres of ongoing maintenance of a frequent fire regime in ponderosa pine. 

Comparison of Alternatives 

Table 3-22. Acres Changed to a More Sustainable Condition 

Alternative A Alternative B Alternative C Alternative D 

0 7,499 5,771 2,616 

Table 3-23. Volume by Alternative in Million Board Feet 

Alternative A Alternative B Alternative C Alternative D 

0 12.1 9.8 5.2 

Cumulative Effects 

The 1998 Landscape Analysis considered past actions in past timber sales for Baja and Seven Buttes to 

come up with an integrated plan to achieve a balanced mix of forest structural conditions and habitat 

needs. Effects of all past and present activities associated with vegetative seral/structural stages and 

dead wood were modeled into the future. Results can be found in the sections in Wildlife titled Dead 

Wood Historical Range of Variation, Management Indicator Species, and Threatened, Endangered and 

Sensitive Species”. 
BLT Project Environmental Impact Statement 

Chapter 3 - Forested Vegetation 

98

All past and present activities (including wildfire) were accounted for using satellite data derived from 

2001 imagery updated to 2004 and the facts database up to present. This method of analysis does not 

leave to chance that an activity can be excluded and is the most informative manner for the decision 

maker and public. Foreseeable actions were overlaid onto this potential zone of influence which is the 

5th field Upper Little Deschutes Watershed. For these reasons, the analysis of past actions other than 

those listed in this section is based on current environmental conditions. 

 

Consistency with Eastside Screens 

Under Scenario A, page 9, there is no net loss of LOS and no activities occur within stages that are 

below HRV for LOS (Table 3-24). 

(1) Timber sale activities are designed to maintain or enhance LOS by reducing competition 

for scarce resources which lowers the risk of a wide-scale disturbance event. 

(2)a All remnant late and old seral and/or live structural trees 21 inches or larger would not be 

harvested. 

(2)b There is no even-aged or regeneration harvest prescribed in the action alternatives; 

therefore there is no fragmentation of stands. 

For a discussion on stand connectivity, snags, and down logs, see the Wildlife section in this chapter. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Long-term Climate Changes 

99

Table 3-24. Historic Range of Variability (HRV) for Medium and Large Trees by Plant 

Association Group and Seral Stage within the Upper Little Deschutes 5th Field Watershed 

Structural Stage Current 

(Acres) 

Range (Acres) 

Low High 

How Action Alternatives 

Respond? 

Moist Mixed Conifer 

E 5a (Early Seral Multi-Strata) 86 29 71 No Change 

E 5b (Early Seral Single-Strata) 440 114 285 Up to 10 acres Increase 

M5a (Mid Seral Multi-Strata) 150 570 1140 No Activity 

M5b (Mid Seral Single-Strata) 187 143 285 Up to 13 acres Increase 

L5a (Late Seral Multi-Strata) 188 285 570 No Activity22

L5b (Late-Seral Single-Strata) 334 0 023 Up to 31 acres increase 

Dry Mixed Conifer

E 5a 12 132 220 No Activity 

E 5b 178 528 880 No Activity 

M5a 133 110 275 Up to 10 acres into M5b 

M5b 121 440 1,100 No Activity 

L5a No L5a in the project 

L5b 443 44 88 Up to 8 acres Increase 

Mesic Ponderosa Pine 

E5a 40 0 61 Up to 2 acres into E5b 

E5b 104 0 244 Up to 2 acres Increase 

M5a 24 0 91 Up to 4 acres into M5a 

M5b 325 0 366 Up to 3 acres Increase 

L5a 27 0 122 Up to 7 acres into L5b 

L5b 62 1,524 2,011 No Activity

Dry Ponderosa Pine 

E5a 467 0 71 No Activity 

E5b 8 357 643 No Activity 

M5a 689 0 107 Up to 95 acres into M5b 

M5b 2 357 858 No Activity

L5a 237 0 286 No Activity 

L5b 1 1,072 2,574 No Activity 

Dry Lodgepole Pine 

E5a No E5a in Project 

E5b No E5b in Project 

L4a 1,382 0 15, 531 Up to 162 acres into L4b 

L4b 10,218 69 15, 531 Up to 161 acres Increase 

L5a 377 0 388 Up to 35 acres into L5b 

L5b 1,232 0 388 Up to 34 acres Increase 

Consistency with Matrix Standard and Guidelines 

At least fifteen (15) percent of each cutting unit is retained in a passive management scenario (NWFP 

Standard and Guideline, C-41). In addition, this Project Design Feature was applied to the entire BLT 

analysis area. 

Prescriptions in the BLT analysis area call for thinning (HTH) and Improvement Cuts (HIM) where 

residual live trees are retained, and no prescriptions such as regeneration harvest or clear cutting is 

employed; therefore, live tree retention is met in patches greater than 2.5 acres and greater than 70 

percent of the cutting unit (NWFP Standard and Guideline, C-41). 

 

22 Some seral stages that appear to have activity and are deficient in LOS (Scenario A) may show minor increases through: 1) 

minor values assigned to pixels where stands were assigned a more common value, and 2) activity in one strata may show 

increases in another, although no activity occurred. This would be most common with multi-strata moving to single strata. 

23 Determination of HRV did not indicate this seral stage in this PAG was present 
BLT Project Environmental Impact Statement 

Chapter 3 – Long-term Climate Changes 

100

Consistency with the Northwest Forest Plan Standard for Late-Successional Forests 

“Landscape areas where little late-successional forest persists should be managed to retain latesuccessional patches. This standard and guideline will be applied in fifth field watersheds (20 to 200 

square miles) in which federal forest lands are currently comprised of 15 percent or less latesuccessional forest (NWFP Standards and Guideline, C-44).” 

No activities planned in the BLT project would reduce LOS. Actually, LOS characteristics may be 

increased in stands classified as “mid” because the large structure would become more dominant after 

thinning. 

Long-term Climate Changes ___________________________ 

Existing Condition 

Although El Niño/Southern Oscillation and the Pacific Decadal Oscillation comprise the primary 

factors for climate variability in the Pacific Northwest (Climate Impacts Group 200624), the influence 

from global climate change is a growing concern. According to the Climate Impacts Group, based out 

of the University of Washington, climate modeling for the Pacific Northwest predicts a future rate of 

warming of approximately 0.5 degrees Fahrenheit per decade for the Pacific Northwest through at least 

2050, relative to the 1970-1999 average temperature. Temperatures are projected to increase across all 

seasons, although most models project the largest temperature increases in summer (June-August), and 

the average temperatures could increase beyond the year-to-year variability observed in the Pacific 

Northwest during the 20th century as early as the 2020s. 

 

Direct and Indirect Effects 

This project is designed with the intent of keeping portions of all of the current species and 

structures on this landscape. Whether and how increasing temperatures resulting from global 

climate change would alter predicted forest response to the proposed commercial thinning 

under any of the action alternatives would depend on specific site conditions in relation to 

temperature and soil moisture availability on tree growth. If temperature were to increase while 

precipitation changes minimally, as predicted by the Climate Impacts Group, tree 

evapotransporation would increase nonlinearly, leading to more frequent drought stress. 

Douglas-fir, in particular, is sensitive to low soil moisture (Climate Impacts Group 2004). A 

moderate density commercial thinning could decrease competition for water during the summer 

while limiting additional evaporation from the soil and transpiration from the understory in the 

summer. Such thinning could also maximize the duration of snowpack in spring by having an 

open enough canopy that more snow accumulates in the ground rather than on the forest 

canopy, yet, is still shaded from melting by the sun in the spring. The resulting increased 

available moisture, in turn, could reduce the risk of dead or drought-stressed trees created by 

increasing temperatures and changes in precipitation caused by climate change and that would 

be susceptible to fire and disease in the near-term. Late-successional and old-growth forests are 

generally thought to be more resilient to climate change. This project would not reduce stands 

classified as LOS or designated as Old Growth. Further, prescriptions are designed to promote 

these conditions and increase forest habitat connectivity, allowing species to reach new 

locations as climate change alters existing habitat (Climate Action Group 2004a). 

The range of species within the analysis area over the past few hundred years appears to have been 

similar to today, based on the variety of species of the older trees. While there is much discussion 

 

24 Intergovernmental Panel on Climate Change (IPCC). Their reports (2007) provide the authoritative scientific basis for 

subsequent Forest Service analysis of the phenomenon. Information specific to the Forest Service can be found in the latest 

Synthesis and Assessment Product 4.4.24 
Environmental Impact Statement BLT Project 

 Chapter 3 – Long-term Climate Changes 

101

among scientists about global climate change, the reality for management of existing forests is that they 

are a result of the past and present climatic influences (Shugart, et al, 2003). The current climate limits 

what can be done with forest trees at this point in time. To be able to respond to the influences of 

global climate changes, it is best to maintain the full range of native species now present on this 

analysis area. Regardless of the climatic changes, a full suite of species remaining on the analysis area 

ensures adaptability for a wide range of climatic conditions. 

Shugart et al (2003) state that the ecological responses to climate change is extremely complicated and 

understanding how ecological systems will respond to climate change remains a challenge. Hence, we 

do not know the direction, effects, and magnitude of the climatic changes of the future as they pertain to 

this analysis area, and establishing species adapted to a climate differing from the present would be 

potentially very costly in time and resources. Therefore, the most prudent approach in the context of 

this project would appear to be to “keep all of the pieces” (Leopold, 1949). 

Since the proposed management actions in this project would leave the treated stands fully stocked after 

implementation (fully capable of utilizing the available moisture, nutrients, and growing space on the 

treated sites), vegetation would continue normal respiration processes and effects to atmospheric CO2 

levels would be expected to be inestimable on a regional, national, or global scale. 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

102

Fire and Fuels Management____________________________ 

The BLT analysis area (80,000 acres) is composed of 53,537 acres (67 percent) of federal land and 

approximately 26,463 acres (33 percent) of private land. The private land is typically embedded or 

surrounded by Forest Service land. The private land mostly contains structures (homes), although there 

is a smaller amount of industrial landholders. 

Desired Condition 

“Fireproofing” the analysis area is not reasonable and is not an objective of this project. It is 

acknowledged that the desired condition for some wildlife species require some areas of high fuel 

loading and that management to retain habitat for these species results in high wildfire risk remaining 

on the landscape. However, the desired condition from a fuels standpoint is for the landscape to be as 

safe as possible for the public, including surrounding communities. This is accomplished through 

restoring fire as a disturbance process, and reducing hazard in the right areas (strategic placement of 

treatments or SPOTS). More information on SPOTS will follow. However, should fire suppression 

action be necessary, the desired condition for fire behavior would allow a safe and successful initial 

attack during the first burning period. Specific desired outcomes of actions designed to meet the 

Purpose and Need are to: 

• Improve firefighter and public safety in the event of wildfire by creating and maintaining 

conditions that allow flexibility in firefighting strategies; 

• Reduce the risk that fires that start outside of Wildland Urban Interface (WUI) areas will burn 

into the WUI. 

• Reduce the risk that fires that start inside of the WUI will burn into adjacent forested areas. 

This is achieved by actively treating the entire fuel strata at the landscape scale (Agee & Skinner, 

2005). The fuels stratum includes surface fuels, canopy base height, crown density, and fire resistant 

trees. Reducing surface fuels and breaking up continuity would lower flame lengths and reduce rates of 

spread. Raising canopy base height would reduce ladder fuels that can lead to crown fires. Reduction 

of canopy bulk density while retaining fire resistant trees would reduce the potential for initiation of 

active crown fires (Agee, 2002; Hessburg and Agee, 2003; Brown et al, 2004; Graham et al, 2004; 

Agee and Skinner, 2005; Perry et al, 2004). 

Once wildfires transition to crowns of trees, suppression actions are much less effective. As 

experienced on several large crown-driven wildfires in the region (Davis Fire, 18 fire, Link, Geneva, 

portions of B&B, Skeleton, Cache, Black Crater, and Royce Butte Fire), open stands provide 

opportunities for containing, or slowing down an advancing flaming front. Open stands tend to drop 

fires to the ground because heat transfer from crown to crown is dissipated by air flow between the tree 

canopies as seen most recently on the Royce Butte Fire. 

Strategic Placement of Treatments (SPOTS) 

The SPOTS concept contributes to an overall understanding of the spatial dynamics of fuel and related 

fire behavior through the use of a collaborative planning process and fire modeling tools that describe 

fire potential on a specific landscape. The SPOTS approach considers trade-offs between multiple 

treatment options by gaming fire scenarios with fire behavior and spread modeling software. SPOTS 

are designed not only for fire and fuel planning, but rather as a holistic land management process. 

While a “problem fire25” is the filter through which potential treatment patterns are tested, the 

 

25 Problem fires are wildfires that, because of extreme fire behavior, present a high risk to human safety and loss of forest 

resources. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

103

objectives of many planned treatments are related to timber management, forest health, wildlife, and 

watershed issues, as well as protection of assets from unwanted wildland fire. Strategically placed 

treatments have potential to add value to acres treated by affecting large fire spread and effects at the 

landscape level. Better than simply assessing fuel treatment success by “acres achieved,” the SPOTS 

approach assesses the effectiveness of treatment design by comparing the pros and cons of a variety of 

tested treatment options. 

While fuel reduction treatments have proven effective in changing fire behavior and effects at the 

individual stand level (Cumming, 1965; Deeming, 1990; Graves and Neuenschwander, 1999; Pollet and 

Omi, 2002), the more complex issue of changing landscape-scale fire behavior, fire effects, and 

suppression costs may also be addressed through fuel treatments if they are applied in a deliberate, 

strategic pattern at meaningful scales. Evidence of fuel treatment patches altering the progression of an 

extreme fire event was observed and documented during the Rodeo-Chediski fire in Arizona in 2002 

(Finney et al 2005). Areas treated by prescribed fire before the Rodeo-Chediski wildfire not only 

altered severity and fire effects within their area, but also reduced fire severity on downwind acres. 

Researchers have sought the optimum spatial pattern for disrupting large fire spread in the modeling 

environment. Various treatment patterns of the same landscape proportion (20 percent) were tested 

using FARSITE to determine their effects on over-all fire size (Finney 2001). This research revealed 

that the ultimate size and severity of an unplanned ignition may be greatly reduced if treatment units are 

placed in a staggered, overlapping pattern that is perpendicular to the prevailing wind and treatment 

prescriptions are sufficient to reduce expected rate of spread and flame length. 

http://www.nifc.gov/spots/

Locations of SPOTS were determined for the BLT analysis area using the downwind resource at risk, 

such as subdivisions recognized in the Walker Range CWPP and the National Registry of Wildland 

Urban Interface communities, while taking advantage of areas where vegetation has been previously 

altered (Figure 3-11). The goal is not only to reduce risk of a wildfire burning into a populated area, 

but also to isolate it so that it does not threaten multiple key assets. 

The BLT alternatives are compared from a spatial (i.e. how much they overlap SPOTS) and temporal 

(0-25 year) context. Essentially, areas of modified fire behavior need to be large enough to alter a 

wildfire’s pathway enough to allow suppression forces time to slow it down or stop it before it enters 

the area being protected. In the BLT analysis area, there are previously managed areas such as past 

timber harvest and ongoing maintenance underburning in fire-dependent stands that were incorporated 

into the SPOTS. 

Maintenance of SPOTS 

In order to maintain fuels at the desired level and to retain effectiveness through time, it is estimated 

thinning of small trees (6 inches diameter or smaller) with handpiling and disposal would occur every 

15-20 years. Initial limbing of trees (pruning) would remain effective as crown base heights rise each 

year with tree growth. However, smaller trees selected for retention would need to be pruned, usually 

with each thinning entry. In appropriate stands, prescribed burning as a maintenance tool would be 

needed every 8-12 years. 

Walker Range Community Wildfire Protection Plan (CWPP) 

The purpose of the Walker Range CWPP is to protect human life and reduce property loss due to 

wildland fire in the communities and surrounding areas of the Crescent, Crescent-Odell Lakes, 

Chemult, and Oregon Outback Rural Fire Protection Districts and the Walker Range Forest Protective 

Association. Reducing the threat of wildland fire is the primary objective behind this plan. Residents 

and visitors alike want healthy, fire-resilient forests that provide habitat for wildlife, recreation 

opportunities, and scenic beauty (CWPP 2005). 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

104

 

The goals of the CWPP are to increase public understanding of living in a fire-adapted ecosystem, 

instill a sense of personal responsibility for taking preventative actions regarding wildland fire, restore 

fire-adapted ecosystems, and improve the landscape’s fire resilience while protecting other social and 

ecological values. To achieve these goals, the plan includes the following objectives: 

• Assess the risk and hazard of wildland fire on all lands within the plan boundary, 

• Identify priorities for fuel reduction projects, 

• Examine emergency operations within the plan area and identify areas to improve 

community response and preparedness for wildland fire, 

• Prioritize actions to reduce hazardous fuels, 

• Enhance emergency response and, 

• Strengthen public education and prevention activities (CWPP 2005). 

The CWPP boundary includes all lands and ownerships, including portions of the BLT planning area 

(Figure 3-11, Walker Range Community Wildfire Protection Plan). Within the BLT analysis area there 

are 7 communities at risk. A community at risk is an interface community as defined in the Federal 

Register notice of January 4, 2001, or a group of homes and other structures with basic infrastructure 

and services (such as utilities and collectively maintained transportation routes) in or adjacent to federal 

land, has conditions conducive to large-scale wildland fire, faces a significant threat to human life or 

property as a result of a wildland fire (USDA Forest Service, DOI Bureau of Land Management, 2004). 

Within the Wildland Urban Interface, recent implementation of fuels reduction projects such as 5825, 

Baja, and CE97 have reduced the immediate hazard surrounding communities within the BLT analysis 

area. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

105

Figure 3-11. Walker Range Community Wildfire Protection Plan 

Table 3-25. Communities at Risk in the BLT Analysis Area 

Schoonover and Vicinity Cluster 

Cascade Estates 

Marsha Way 

Schoonover 

Tall Pines 

Crescent/Gilchrist Cluster 

Crescent 

Friendly Acres 

Gilchrist 

Fuels Conditions Current and Historic within the Analysis Area 

In the current condition, no areas designated as within a Wildland Urban Interface are at high risk 

within the BLT analysis area. 

The following are terms and definitions used in the BLT fuels analysis: 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

106

Canopy Base Height: The height above the ground of the first canopy layer where the density of the 

crown mass within the layer is high enough to support vertical movement of a fire. Low canopy base 

heights have been shown to initiate crown fire behavior (Alexander, 1988). 

Canopy Bulk Density: Canopy bulk density (CBD) describes the density of available canopy fuel in a 

stand. It is defined as the mass of available canopy fuel per canopy volume unit. Geospatial data 

describing canopy bulk density supplies information for fire behavior models, such as FARSITE

(Finney 1998), to determine the initiation and spread characteristics of crown fires across landscapes 

(VanWagner, 1977 and 1993). The Canopy Bulk Density layer is generated using a predictive modeling 

approach that relates Landsat imagery and spatially explicit biophysical gradients to calculated values 

of CBD from field training sites. Because of model requirements, these data are provided for forested 

areas only the mass of canopy fuel per unit of canopy volume. A canopy bulk density of 0.00069 

pounds per cubic foot (lb/ft3) can sustain a crown fire (Sando and Wick, 1972) in any species. 

Extended Attack: When a fire has not been contained by the initial attack resources dispatched to the 

fire, will not have been contained within the management objectives that are established for that zone or 

area, and has not been contained within the first operational period. Wildland and Prescribed Fire 

Management Policy-Implementation Procedures Reference Guide (Run Cards). 

Fuels: The term “fuels” refers to the vegetative material, both living and dead, that is capable of 

carrying a fire across a landscape. Fuels can include conifer needles, fallen limbs, and slash remaining 

after timber harvest, living trees with crowns that are close to the ground, and standing dead or fallen 

trees. The following are definitions of some terms used during discussion of fuels and suppression. 

Fuel Models: Fuel models are a tool used to standardize discussion of fuel conditions on a landscape. 

Fuel conditions, defined by quantity and arrangement, have been categorized into 40 standard 

descriptive fuel models (Scott and Burgan, 2005). Areas proposed for activity were field-verified to 

document the vegetative condition; and fuel models were assigned. 

Initial Attack: Initial attack is the fire suppression effort that takes place as soon as possible following 

a wildland fire report. Initial attack is conducted by preplanned suppression resources; the type and 

number of available resources change depending on the fire danger of the day. More information on 

initial attack resources can be found in the Wildland and Prescribed Fire Management PolicyImplementation Procedures Reference Guide (Run Cards). 

Ladder Fuels: Fuels that provide vertical continuity between the ground and tree crowns, thus creating 

a pathway for a surface fire to move into the overstory tree crowns (R8-TP-11, 1989). 

Percentile Weather: The weather conditions that can be expected of X% of the days during a fire 

season. The standard percents are Low (0%-15%), Moderate (16%-89%), High (90%-96%) and 

Extreme (97%+). So low percentile weather is the average suite of weather conditions that would occur 

less than 15% of the time.

Problem Fire: Problem fires are wildfires that, because of extreme fire behavior, present a high risk to 

human safety and loss of forest resources. 

The fire behavior on problem fires includes: 

• Rates of spread greater than 12 chains/hour (800 ft/hour) 

• Active crown fire; and 

• Flame lengths greater than 8 feet. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

107

Problem fires limit suppression strategy and tactic options because rates of spread are so high that the 

fire cannot be contained by initial attack suppression personnel. Crown fires cannot be attacked 

directly; suppression personnel must use indirect tactics with burnout operations or wait until the crown 

fire drops back to the ground and meets appropriate flame length and rate of spread criteria before 

direct attack can be initiated. Flame lengths greater than 4’ are too intense for direct attack and 

handlines cannot be relied on to hold fire. Flame lengths greater than 8’ may present serious control 

problems so that control efforts at the head of the fire will probably be ineffective. 

Other management issues associated with problem fire: 

• Problem fires pose a high risk to public and firefighter safety. 

• Problem fires have the potential to create extensive resource damage. 

• Problem fires require multiple days and/or months to contain and control and are very 

expensive to manage. 

The 2003 Davis Fire is a recent example of a problem fire on the Crescent Ranger District. Situated on 

the Crescent Ranger District it was fueled by vegetative conditions that are present over much of the 

project area. It was human-caused; the ignition location was in the West Davis Lake dispersed camping 

area, and it started relatively early in the fire season (June 28). It nearly burned into the community of 

La Pine, Oregon, and was essentially stopped by Wickiup Reservoir and actions by firefighters at the 

edge of Wickiup Acres, a small community. Suppression costs on the Davis Fire were in excess of eight 

million dollars. It is estimated that at its most extreme, the Davis Fire had flame lengths of up to 50’ 

and burned several miles in length in less than an hour. Suppression activities went on for 12 weeks 

before firefighters could contain the Davis Fire, and continued for another two weeks before control 

could be declared. The fire burned about 21,000 acres with complete mortality of vegetation over 

approximately 80% of the fire area. Table 3-29 shows a comparison of the effects of the Davis Fire on 

different timber types within the fire perimeter compared to the anticipated effects of a fire burning 

under historical conditions. While hemlock burned within historic conditions during the Davis Fire, 

ponderosa pine and Douglas-fir (typically fire-resistant species) and lodgepole pine stands in the fire 

area experienced much higher mortality than is typical under historic conditions. 

Trees per Acre: The amount of trees of a specific diameter on an acre of land. Small diameter trees 

have similar fire characteristics; therefore, species was not a consideration for trees less than 6 inches in 

diameter. 

Fire Regime 

A natural fire regime is a general classification of the role fire would play across a landscape in the 

absence of modern human mechanical intervention, but including the influence of aboriginal burning 

(Agee 1993, Brown 1995). Coarse scale definitions for natural (historical) fire regimes have been 

developed by Hardy et al. (2001) and Schmidt et al. (2002) and interpreted for fire and fuels 

management by Hann and Bunnell (2001). The five natural (historical) fire regimes are classified based 

on average number of years between fires (fire frequency) combined with the severity (amount of 

replacement) of the fire on the dominant overstory vegetation. 

These five regimes include: 

I – 0-35 year frequency and low (surface fires most common) to mixed severity; 

II – 0-35 year frequency and high (stand replacement) severity; 

III – 35-100+ year frequency and mixed severity; 

IV – 35-100+ year frequency and high (stand replacement) severity; and 

V – 200+ year frequency and high (stand replacement) severity 

Fire Regime Condition Class 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

108

Fire Regime Condition Class (FRCC) was used in the analysis area to determine reference conditions. 

Because of the controversy and simplicity of using FRCC (Morrison and Smith 2005; Veblen 2003), 

FRCC was not used as the primary basis for decision making. However, fire regimes were used as a 

reference condition to determine ecological capability reference condition. 

A Fire Regime Condition Class (FRCC) is a landscape classification that describes the amount of 

departure from the natural (historical) fire regime. They include three condition classes for each fire 

regime. This departure results in changes to one (or more) of the following ecological components: 

• Vegetation characteristics (species composition, structural stages, stand age, canopy closure, 

and mosaic pattern); 

• Fuel composition; 

• Fire frequency, severity, and pattern; and 

• Other associated disturbances (e.g. insect and disease mortality, grazing, and drought). 

All vegetation and fuel conditions or wildland fire situations fit within one of the three classes. The 

three classes are based on low (FRCC 1), moderate (FRCC 2), and high (FRCC 3) departure from the 

central tendency of the natural regime. Low departure is considered to be within the natural range of 

variability, while moderate and high departures are outside. Characteristic vegetation and fuel 

conditions are considered to be those that occurred within the natural fire regime. Uncharacteristic 

conditions are considered to be those that did not occur within the natural fire regime. Determination of 

amount of departure is based on comparison of a composite measure of fire regime attributes, as listed 

above. Table 3-26 displays the Fire Regime Condition Classes, their descriptions, and the risk potential 

associated with each condition. 

Table 3-26. Fire Regime Condition Classes 

Fire Regime 

Condition 

Class 

Description Potential Risk 

Condition 

Class 1 

Within the natural (historical) 

range of variability of vegetation 

characteristics; fuel composition; 

fire frequency, severity and 

pattern; and other associated 

disturbances. 

• Fire behavior, effects, and other associated 

disturbances are similar to those that occurred prior 

to fire exclusion (suppression) and other types of 

management that do not mimic the natural fire 

regime and associated vegetation and fuel 

characteristics. 

• Composition and structure of vegetation and fuels 

are similar to the natural (historical) regime. 

• Risk of loss of key ecosystem components (e.g. 

native species, large trees, and soil) is low. 

• Fire behavior, effects, and other associated 

disturbances are moderately departed (more or less 

severe). 

• The effects of insects and disease as well as the 

potential intensity and severity of fire are within 

historic ranges, but are increasing with length of 

current fire return interval. 

• The hydrologic functions are within normal 

historic range. 

• Vegetative composition and structure are resilient 

to disturbances from wind, insects, disease, or fire 

and do not predispose the stand or its key 

components to a high risk of loss. 

Condition 

Class 2 

Moderate departure from the 

natural (historical) regime of 

• Fire behavior, effects, and other associated 

disturbances are moderately departed (more or less 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

109

Fire Regime 

Condition 

Class 

Description Potential Risk 

vegetation characteristics; fuel 

composition; fire frequency, 

severity and pattern; and other 

associated disturbances. 

severe). 

• Composition and structure of vegetation and fuel 

are moderately altered. 

• Uncharacteristic conditions range from low to 

moderate. 

• Risk of loss of key ecosystem components is 

moderate. 

• Fire behavior, effects, and other associated 

disturbances are highly departed (more or less 

severe). 

• The effects of insects and disease as well as the 

potential intensity and severity of fire pose an 

increased threat to key components that define the 

system. 

• Riparian areas and their associated hydrologic 

functions show measurable signs of adverse 

departure from historic conditions. 

• Both the composition and structure of vegetation 

has shifted towards conditions that are less resilient 

and are therefore more at risk to loss from wind, 

insects, disease, or fire. 

Condition 

Class 3 

High departure from the natural 

(historical) regime of vegetation 

characteristics; fuel composition; 

fire frequency, severity and 

pattern; and other associated 

disturbances. 

• Composition and structure of vegetation and fuel 

are highly altered. 

• Uncharacteristic conditions range from moderate 

to high. 

• Risk of loss of key ecosystem components is high 

• The effects of insects, disease, or fire may cause 

significant or complete loss of one or more defining 

ecosystem components. 

• Hydrologic functions may be adversely altered, 

with significant increases in sedimentation potential 

and measurable reductions in streamflows. 

• The highly altered composition and structure of 

the vegetation predisposes the stand or ecosystem to 

disturbance events well outside the range of historic 

variability, potentially producing changed 

environments never before measured. 

Table 3-27. Fuel Models in the BLT Analysis Area 

Fuel Model Description 

TL3 Mixed Conifer, 

Lodgepole Pine and 

Mountain Hemlock 

The primary carrier of fire in TL3 is moderate load conifer litter, light load of 

coarse fuels. Spread rate is very low (0-2 chains per hour; flame length low (1-4 

feet). 

TL4 Lodgepole Pine 

The primary carrier of the fire is a moderate load of fine litter and small diameter 

downed logs. Spread rate is low (2-5 chains per hour); flame length low (1-4 

feet). 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

110

Fuel Model Description 

TL5 Mixed Conifer 

The primary carrier of fire in TU5 is high load conifer litter; light slash or 

mortality fuel. Spread rate is low (2-5 chains per hour); flame length low (1-4 

feet).

TL8 Ponderosa Pine The primary carrier of fire in TL6 is moderate load broadleaf litter. Spread rate is 

moderate (5-20 chains per hour; flame length low (1-4 feet). 

TU5 Mixed Conifer and 

Lodgepole 

The primary carrier of fire in TU5 is high load conifer litter; light slash or 

mortality fuel. Spread rate is low (2-5 chains per hour); flame length low (1-4 

feet). 

TL9 Ponderosa Pine 

The primary carrier of fire in TL9 is very high load, fluffy broadleaf litter. TL9 

can also be used to represent heavy needle-drape. Spread rate is moderate (5-20 

chains per hour); flame length moderate (4 – 8 feet).

Table 3-27 displays a summary of the existing forest structure within the BLT analysis area. For a 

detailed description of the species and plant association groups present in the BLT analysis area, refer 

to the “Forested Vegetation” section of this EIS. 

The following is a description of forest vegetation, fuels, and fire behavior found within the BLT 

analysis area: 

Ponderosa Pine, 16,055 acres (20 percent) 

Fire Regime I Condition Class II 

Important changes have occurred in central Oregon forests since 1900, due to interruption of frequent 

burning. Nonlethal fire has decreased while lethal fire has increased. Reduced fire began in the late 

1800s as a result of (1) relocation of Native Americans and disruption of their traditional burning 

practices; (2) fuel removal by heavy and extensive livestock grazing; (3) disruption of fuel continuity 

on the landscape due to irrigation, cultivation, and development; and (4) adoption of “fire exclusion” as 

a management policy. The general result has been development of dense conifer understories, 

commonly adding 200 to 2,000 small trees per acre beneath old growth stands or thickets of 2,000 to 

10,000 small trees per acre where the overstory was removed. Densely overstocked conditions have 

resulted in slow growth and poor vigor of most trees in a large proportion of the ponderosa pine type 

where adequate density reduction has not occurred. Stand stagnation is accompanied by a sparse 

representation of non-flowering herbs and shrubs, which reflects a loss of natural biodiversity and of 

forage for wildlife (Arno et al., 1995a). Growth stagnation renders even the dominant trees highly 

vulnerable to mortality in epidemics of bark beetles, defoliating insects, diseases such as dwarf 

mistletoe, and various root rots (Biondi, 1996; Byler and Zimmer-Grove, 1991; Cochran and Barrett, 

1998). For example, in the 1980s about a million acres of ponderosa pine-fir forests in the Blue 

Mountains of eastern Oregon suffered heavy mortality from the above agents as a result of overstocking 

and growth stagnation related to fire exclusion (Mutch et al., 1993). On sites where ponderosa pine is 

seral, there has been a compositional shift to the shade-tolerant species. These successional changes 

have resulted in a buildup of understory or ladder fuels that now allow wildfires to burn as standreplacing crown fires. A combination of heavy forest floor fuels and dense sapling thickets acting as 

ladder fuels, coupled with the normally dry climate and frequent lightning- and human-caused ignitions, 

has resulted in a dramatic increase of severe wildfires in the ponderosa pine type in recent decades 

(Arno, 1996; Williams, 1995), for example, approximately 1 million acres (405,000 ha), largely in this 

type, burned in severe wildfires in central in Idaho between 1986 and 1996 (Barbouletos et al., 1998). 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

111

Prior to 1900, ponderosa pine communities experienced frequent fires as a result of highly combustible 

leaf litter, an abundance of cured herbaceous vegetation, and a long season of favorable burning 

weather. Stands had an open, park like appearance, dominated by large old, fire-resistant trees. Shrubs, 

understory trees, and downed logs were sparse, as testified to by dozens of historical photographs and 

narrative accounts (Cooper, 1960; Leiberg, 1899; Wickman, 1992). 

The most comprehensive fire history for the Pacific Northwest ponderosa pine series is based on data 

from the vicinity of Bend, Oregon (Bork, 1985). Fire historically reduced dwarf mistletoe infection by 

pruning dead branches and consuming individual tree crowns that had low-hanging witches’ brooms 

(Harrington and Hawksworth, 1990; Koonce and Roth, 1980). Non-sprouting shrubs such as 

bitterbrush that used to be much more limited in cover because of frequent underburning are now 

widespread. Although bitterbrush can sprout after light spring burning (Martin and Driver, 1983), fire 

often kills it. Frequent light burning allowed bunchgrasses and most forbs to recover rapidly (Wright et 

al., 1979), so herbaceous vegetation dominated the understory. The natural landscape pattern of 

ponderosa pine forests was seemingly unbroken parkland of widely spaced tree clumps and continuous 

herbaceous understory (Agee, 1994; Gruell et al., 1982). In most stands, duff depth probably averaged 

only about half an inch (Keane et al., 1990). 

It is commonly recognized that wildfires are a natural and desirable characteristic of forested 

landscapes, especially on the east slope of the Cascade Range (Agee, 1994). Fires in ponderosa pine 

and dry, mixed-conifer forests historically burned fine fuels (e.g. grasses and litter on the forest floor) at 

regular intervals. These surface fires rarely killed large, fire resistant trees, but did kill smaller trees of 

all species, thereby helping to maintain sparse, open stands (Noss et al., 2006, pg 482 citing Veblen et 

al. 2000; Eyerdahl et al., 2001; Stephens and Collins, 2004). 

Currently, the Crescent Ranger District is in a “maintenance schedule” where a regular interval of 

prescribed fire is applied to ponderosa pine stands on approximately 9,000 acres of 34,766 acres 

available. Eight hundred (800) acres are within the BLT analysis area. 

Lodgepole Pine, 39,000 acres (49 percent) 

Fire Regime III Condition Class II 

Lodgepole pine is fire sensitive (Atzet et al., 1990; Rundel et al., 1977). After stand-replacing fire, it 

typically establishes from wind-dispersed seed. Agee (1981) reported that establishment of Sierra 

lodgepole pine in Crater Lake National Monument, Oregon, was favored by fires of moderate to high 

severity. Fire-return intervals in Sierra lodgepole pine forests vary. On the eastern slope where drier 

conditions prevail, such fires may occur at intervals of less than 20 years (Atzet et al., 1990). Standreplacing fires are related to insect attacks, particularly by pine mountain beetle, and declining vigor 

and high fuel loading in older stands (Atzet et al., 1990; Dickman and Cook, 1989; Heinrichs, 1983). 

In this moderate severity fire regime, a typical disturbance scenario includes selective removal of about 

a third of the stands every 60 years, either by insects, fire, or a combination of the two (Agee, 1994). 

Stuart (1984) documented a 60-year fire return interval on the Fremont National Forest, Agee (1981) 

also found a 60-year interval at Crater Lake National Park, and Chappell (1991) found a 40-year fire 

return interval in a California red fir (Abies magnifica A. Murr.) forest directly adjacent to a lodgepole 

pine flat. The magnitude of natural fires ranges from crown fires to “cigarette burns,” where fires 

slowly burn along jackstrawed log corridors composed of beetle-killed trees (Agee, 1994). 

Douglas-fir, (Mixed-conifer) 12,305 acres (16 percent) 

Fire Regime III Condition Class II 

In the pole and sapling stages Douglas-fir is susceptible to fire damage as bark is thin, photosynthetic, 

and resin-filled (Crane, 1982). Mature trees can survive moderately severe surface fires because the 

lower bole is covered by thick, corky bark that insulates the cambium from heat damage (A. D. Revill 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

112

Associates, 1978; Agee, 1993; Fischer et al., 1987). Fire scars are characterized by resin deposits that 

may increase the size of the scar in subsequent fires (Bradley et al., 1992). Douglas-fir usually forms 

obvious fire scars and can survive several centuries after injury, making the history of understory fire 

easily studied (Arno et al., 1983). Douglas-fir is killed by crown damage; fine twigs and buds are 

particularly susceptible (Kalabokidis et al., 1992). Fire resistance offered by thick bark is often offset 

by low-growing branches which may be retained even when shaded out and no longer green (Crane, 

1982; Lotan et al., 1981). Trees that host Douglas-fir dwarf mistletoe (Arceuthobium douglasii) often 

accumulate dense brooms that increase likelihood of charring of the bole or torching (Wicker and 

Leaphart, 1976). 

Mature Douglas-fir is generally more fire resistant than spruces, true firs, lodgepole pine, western 

hemlock, western red cedar, and western white pine and slightly less fire resistant than ponderosa pine 

and western larch (Harrington, 1991; Wellner, 1970). Douglas-fir is, however, slower growing and 

much less fire resistant than ponderosa pine or western larch in sapling and pole stages (Kalabokidis et 

al., 1992; Ryker and Losensky, 1983; Weaver, 1968). High fire frequency reduces the dominance of 

Douglas-fir relative to western larch and ponderosa pine because of the species' differential rates of 

growth and susceptibility to fire (Arno, 1980; Fischer and Bradley, 1987; Loope and Gruell, 1973). 

During pre-settlement times frequent fire often maintained ponderosa pine rather than Douglas-fir on 

drier sites, as Douglas-fir did not reach fire resistant size before the next fire (Arno and Gruell, 1983). 

Douglas-fir relies on wind-dispersed seeds to colonize burned areas where trees have been killed. 

Mineral soil exposed by burning provides a good seedbed. Seedling establishment begins a few years 

after fire and is restricted to within a few hundred yards of seed trees adjacent to the fire or relatively 

undamaged by the fire (Shearer, 1981). 

Where Pacific ponderosa pine is a major associate, fires at 10-year intervals were common (Lotan et al., 

1981). These frequent surface fires maintained relatively open stands of Douglas-fir or, more 

frequently, seral stands of Pacific ponderosa pine since ponderosa pine saplings are more fire-resistant 

than Douglas-fir saplings (Arno, 1980; Fischer and Bradley, 1987; Loope and Gruell, 1973). Fire 

suppression has resulted in long fire-free periods that have allowed Douglas-fir to establish. In some 

areas, dense Douglas-fir thickets have formed, providing continuous ladder fuels to the crown of 

overstory trees. Thus, fire exclusion has increased the potential for severe, stand-replacing fires. Fire 

maintains ponderosa pine on drier sites. 

The effects of fire on Douglas-fir vary with fire severity and tree size. Seedlings are most susceptible to 

fire damage but can live through 122 degrees Fahrenheit (50 °C) for 1 hour, 140 degrees Fahrenheit (60 

°C) for 1 minute, and 158 degrees Fahrenheit (70 °C) for 1 second (Ryan, 1982; Ryan, 1982a). Saplings 

are often killed by surface fires because their thin bark offers little protection from damage (Agee, 

1996; Wellner, 1970). Photosynthetically active bark, resin blisters, closely spaced flammable needles, 

and thin twigs and bud scales are additional characteristics that make saplings more vulnerable to all 

fires (Bradley et al., 1992; Fischer and Bradley, 1987; Harrington, 1991). Surface fires intense enough 

to kill saplings by girdling them often also scorch the entire crown (Wyant et al., 1986). Chance of 

survival generally increases with tree size (Agee, 1996, Harrington, 1991). Because larger trees have 

thicker bark and larger crowns, they can withstand proportionally greater bole and crown damage than 

small trees. Following a low- to moderate-severity surface fire in an open mixed-conifer stand in 

Colorado, 64 out of 103 Douglas-fir trees died within 2 years. Live trees averaged 9.5 inches (24 cm) 

in diameter and 32 feet (9.8 m) in height, while fire-killed trees averaged 5.6 inches (14.3 cm) in 

diameter and 22.6 feet (6.9 m) in height (Wyant et al., 1986). Fire resistant bark develops by about age 

40, but branching habit and stand density can offset this fire resistance. If branches grow (or are dead 

and retained) along the entire bole, as is common when the tree is open-grown, fire can climb into the 

crown (Bradley et al., 1992; Harrington, 1991). If regeneration is dense and crowns overlap, the 

potential for canopy fire is even greater (Harrington, 1991). 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

113

Mountain Hemlock, 7220 acres (9 percent) 

Fire Regime V Condition Class I 

Mountain hemlock commonly occurs as a dominant or codominant in high-elevation alpine or 

subalpine forests. In western Washington and Oregon, the mountain hemlock zone is the highest 

forested zone (Griffin and Critchfield, 1972). Mountain hemlock is often codominant with Pacific 

silver fir (Abies amabilis) (Agee and Kertis, 1987; Douglas, 1972). One of the most widespread 

mountain hemlock communities is the mountain hemlock-Pacific silver fir/big huckleberry (Vaccinium 

membranaceum) type found in British Columbia and the Oregon and Washington Cascades. 

Mountain hemlock is very susceptible to laminated root rot (Phellinus weiri) (Dickman and Cook, 

1989; Means, 1990). In the high Cascades of central Oregon mountain hemlock is the most susceptible 

tree. This fungus spreads from centers of infection along tree roots so that all trees are killed in circular 

areas that expand radially. Laminated root rot moves faster through a nearly pure stand of mountain 

hemlock than through a more heterogeneous conifer stand. Growth and coalescence of laminated rot 

root pockets in mountain hemlock have produced infected areas of more than 100 acres (40 ha). 

Seedlings are not susceptible to reinfection by laminated root rot for 80 to 120 years. This may be due 

to greater vigor caused by higher levels of available nitrogen, higher temperatures, and more growingseason moisture in this regrowth zone (Means, 1990). 

Mountain hemlock is not well adapted to fire (Fischer and Bradley, 1987). Fire resistance of mountain 

hemlock has been rated as low (Spalt and Reifsnyder, 1962). Its relatively thick bark provides some 

protection, but low-hanging branches, highly flammable foliage, and a tendency to grow in dense 

groups make it very susceptible to fire injury (Fischer and Bradley, 1987). 

Mountain hemlock sites are typically moist with average precipitation over 50 inches (127 cm), making 

fire occurrence low (400-800 years) (Atzet and Wheeler, 1982; Booth, 1991; Habeck, 1985). Fuel 

loading in these sites is often low (Atzet and Wheeler, 1982). In the Pacific Northwest, the estimated 

prelogging fire regime in mountain hemlock forest types is 611 years (Booth, 1991). Fires in these cool 

wet forest types generally occur as infrequent crown fires. When fires do occur in mountain hemlock 

forests, they are often severe stand-replacing fires (Fischer and Bradley, 1987). 

Riparian, Alpine meadow, Marsh, 3,200 acres (4 percent) 

The role of fire on the structure and composition of wetland plant communities is not well understood. 

Wetland plant communities probably burned periodically when the frequent fires that historically 

burned through the surrounding ponderosa and lodgepole pine forest spread out onto the marsh. Even 

though the effects of fire on these plant communities are unknown, it is assumed to be beneficial since 

it is part of the natural disturbance regime (Elseroad et al., 2005). 

Rock, Lava, Road, Subdivisions, 2,220 acres (2 percent) 

Current Conditions 

Current patterns of dry forest landscapes primarily support mixed and high-severity fires, and these 

fires are occurring over much broader landscapes than was formerly the case. For example, patches of 

isolated stand replacement fire were common in historical dry forest landscapes, but today, entire 

landscapes are claimed by severe fires. Furthermore, present day large wildfires synchronize 

landscapes by creating very large patches with corresponding forest regeneration, species composition, 

structure, fuel beds, and size and age class distribution, thereby facilitating very large future 

wildfires.(Hessburg et al., 2005). 

Dry forests of the present-day no longer appear or function as they once did. Current patterns of forest 

structure and composition do not resemble even recent historical conditions, neither do they represent 

what we would expect to see under or more natural or characteristic disturbance regimes and the current 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

114

climate. There is little evidence that current patterns are sustainable and this has important ecological 

consequences (Hessburg et al., 2005). 

Table 3-28 displays fuel models found within the BLT analysis area. 

Table 3-28. Summary of Existing Forest Structure within the BLT Analysis Area 

Ponderosa 

Pine Lodgepole Pine Mixed Conifer Mountain Hemlock 

Total Acres 16,044 39,928 13,079 7,251 

Fuel Model TL9 TL4 TL5 TL3 

Canopy Bulk 

Density (CBD) .00624 lb/ft3 .00250 lb/ft3 .00499 lb/ft3 .00562 lb/ft3 

Fire Regime 

Condition Class I/2 III/2 IV/2 V/1 

Fire Characteristics Active Crown Active Crown Active Crown Active Crown? 

Canopy Base Height 1 foot (60%) 

6 foot (40%) 

1 foot (80%) 

3 foot (20%) 

1 foot (60%) 

6 foot (40%) 

1 foot (90%) 

3 foot (10%) 

Trees Per Acre <6” 

DBH(average) 600 2100 1400 350 

The current condition of eastside forests, including the BLT analysis area, is markedly different from 

the historic condition of the landscape. Recent wildfires, such as the Davis Fire in an adjoining 

watershed, are showing an increasing tendency to become “problem fires” (e.g. wildfires that exhibit 

extreme fire behavior, present a high risk to human safety and loss of forest resources). Stands that 

once had frequent fire of low intensity are now more likely stand-replacement events when the 

environmental conditions are favorable. 

Table 3-29. Percent of a Wildfire Area Resulting in Stand Replacement; Comparison of 

Historical Conditions and Problem Fire Conditions (represented by Davis Fire, 2003) 

Vegetation Type Historical Fire Stand 

Replacement % 

Davis Fire Stand 

Replacement % 

Ponderosa pine 10%-24% 63% 

Douglas-fir 5-30% 59% 

Hemlock 85% 15% 

Lodgepole 25% 76% 

Table 3-30. Existing Stand Characteristic by Plant Association Groups Proposed for Activity 

within the BLT Analysis Area 

Ponderosa pine 

group 

Mixed conifer 

group 

Lodgepole 

pine group 

Current Tons per Acre 19.9 25.8 19 

Current Trees per acre < 6” DBH 600 1400 2100 

Current Bulk Density .00624 lb/ft3 .00250 lb/ft3 .00499 lb/ft3 

Current Canopy base height 1 foot (60%) 

6 foot (40%) 

1 foot (80%) 

3 foot (20%) 

1 foot (60%) 

6 foot (40%) 

Current Fuel Model TL9 TL5 TL4 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

115

Historic Fire Weather and Fire Occurrence 

Analysis was conducted using FireFamily Plus computer model. FireFamily Plus is a software system 

for summarizing and analyzing historical daily fire weather observations and computing fire danger 

indices based on the National Fire Danger Rating System (NFDRS). Historic weather observations and 

wildland fire data were obtained for 1991 to 2004 for the Deschutes NF. All data inputs were collected 

from the analysis area. 

Fire Danger Rating 

Historical Fire Danger is based on weather conditions and probability analysis using the National 

Fire Danger Rating System (NFDRS) fuel model G, (Short Needle Pine, Heavy Dead) with standard 

model fuel loadings. The primary carriers of a fire in this fuel type are the heavy ground fuels. The fire 

season for the National Forest in Oregon has historically been from May 1 to October 31. The fire 

seasons from 1991 to 2004 were analyzed and the Energy Release Component was calculated as 

follows in Table 3-31: 

Table 3-31. National Fire Danger Rating for the BLT Area 

Fire Danger Rating Percentage of Days in Fire Season 

(May 1-October 31) 

Low 14% 

Moderate 37% 

High 34% 

Extreme 15% 

Fire Size 

The following table shows the majority of fires in the analysis area are relatively small in size. The 

information is obtained using ArcMap. Large fire information was available from 1908 through 2008 

and small fire information is from 1980 through 2007. “A” fires are 0 to .25 acres in size, “B” fires are 

.26 to 9.9 acres, “C” fires are 10 to 99.9 acres, and “D” fires are 100 to 299.9 acres. 

Table 3-32. Size and Number of Fires within the Analysis Area 

Class Number of Fires Acres Consumed 

A 97 10 

B 23 31 

C 2 85 

D 1 108 

Fire Cause 

Lightning is the leading cause of fire and was associated 51 percent of fire starts within the analysis 

area. The following graph displays the statistical cause of fires from 1987 to 2007. 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

116

Figure 3-12. Fire by Statistical Cause in the BLT Area 

Predicting Fire Behavior 

FlamMap 3 is a wildfire scenario modeling system that can use site-specific weather and fuels 

conditions to predict wildfire behavior. Its output can be interpreted to describe the following 

scenarios: 

• 1-Surface fire is carried primarily by surface fuels and remains on the ground 

• 2-Passive crown fire that can torch individual or small groups of trees, but is driven by 

a surface fire 

• 3-Active crown fire that produces a solid flaming front in the crowns of trees but can 

be independent of a surface fire. 

Given information on fuel models and weather conditions, fire behavior can be predicted. If the canopy 

base height is 1 foot or lower, the assumption is flame lengths of 1 foot or greater from surface fire will 

initiate crown fire. Table 3-33 displays predicted fire behavior in the fuel models found in the BLT 

analysis area in the three weather conditions described. 

Table 3-33. Predicted Fire Behavior Associated with Fuel Models and Weather Typical of the 

BLT Analysis Area 

Fuel 

Model 16 - 89th Percentile Weather 90- 97th Percentile Weather 98th Percentile (Problem Fire) Weather 

Flame 

Length 

(ft)

Rate of 

Spread 

(chains/hour)

Fire 

Type

Flame 

Length 

(ft)

Rate of 

Spread 

(chains/hr)

Fire 

Type

Flame 

Length 

(ft)

Rate of 

Spread 

(chains/hour)

Fire 

Type

TL3 1.1 1.2 Surface 1.1 1.2 Surface 3.3 12.2 Active 

Crown 

TL4 1.3 1.5 Surface 1.4 1.6 Surface 4.5 20.9 Active 

Crown 

TL5 2.0 2.6 Passive 

Crown 2.1 2.8 Passive 

Crown 7.4 42.9 Active 

Crown 

TL8 3.0 3.3 Active 

Crown 3.1 3.6 Active 

Crown 10.7 52.8 Active 

Crown 

TL9 4.3 4.9 Active 

Crown 4.5 5.3 Active Crown 15.4 77.7 Active Crown 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

117

Minimum Travel Time Mapping 

Fire modeling was accomplished using FlamMap, Version 3. It is a fire behavior mapping and analysis 

program that computes potential fire behavior characteristics (spread rate, flame length, fireline 

intensity, etc.) over an entire FARSITE landscape (developed by Finney) for constant weather and fuel 

moisture conditions. It is an ideal tool to compare relative fire behavior changes resulting from fuel 

modifications. It was used to simulate fire travel pathways to predict wildfire minimum travel times 

(MTT) and major flow paths. 

Using site-specific conditions for the Davis Fire, a recent wildfire on the Crescent Ranger District in 

similar environmental conditions defined as a “problem fire”, a wildfire scenario was modeled for the 

BLT analysis area with similar size and timing in the FARSITE landscape. Ignition points were chosen 

in key locations, such as adjacent private ownership, to display potential effect on fire behavior. The 

model was run for 12 hours post-implementation and into the future (Figures 3-13 through 3-16) 

without suppression action, to display a “real time” scenario when multiple ignitions are common and 

detection and suppression action may be delayed. This is an effective way to visualize if treatments 

were effective, by alternative. It also displays whether a fire has potential to exceed initial suppression 

actions and where the likely burn path is located. 

Direct and Indirect Effects 

Alternative A 

Under the No Action alternative, current management plans would continue to guide management of 

the analysis area. Ongoing maintenance of stands classified as Fire Regime 1 (frequent fire interval) 

would continue on 800 acres within the analysis area, of 8,145 available. Response to environmental 

emergencies, such as suppression response to a wildfire, would continue. This alternative foregoes a 

long-term strategy to create and maintain Strategic Placement of Treatments. 

 

Current fire behavior in the analysis area by weather and fuel model is displayed in Table 3-34. Note a 

direct attack (4 feet and under flame length) can be performed under the most typical fire weather. 

Table 3-34. Alternative A Fire Behavior by Weather and Fuel Model 

16%-89% Weather 90%-97% Weather 98%-Problem Fire 

Weather 

TL4 

LP 

TL5 

MC 

TL9 

PP 

TL4 

LP 

TL5 

MC 

TL9 

PP 

TL4 

LP 

TL5 

MC 

TL9 

PP 

Flame Length 1’ 1’ 3’ 1’ 2’ 4’ 3’ 6’ 14’ 

Rate of Spread 

(Chains26 per 

Hour) 

0.9 1.6 3.4 1.1 2.0 4.1 11.9 35.4 69.1 

Fire 

Characteristic Surface Surface Active Crown Active 

Crown 

Tree Mortality 67% 41% 40% 67% 42% 44% 83% 80% 97% 

It is estimated that the next entry into the Upper Little Deschutes Watershed would be necessary in 25 

years when overall stand density and fuel accumulations are once again at an elevated risk to a wide-

 

26 A chain is a standard measurement for displaying rate of spread 
BLT Project Environmental Impact Statement 

Chapter 3 - Fire and Fuels 

118

scale disturbance. Although spots are maintained more frequently through time and provide a level of 

protection that remains static, their efficacy is also dependent upon how much of the spots have been 

placed in the maintenance category. To illustrate this concept, Figure 3-13 displays the minimum travel 

time for a wildfire in 25 years, which would be the worst case scenario if no further action beyond 

ongoing maintenance was implemented under this alternative. 

In Figure 3-13 for Alternative A, with no overlap of activity onto strategic areas, fire size is the greatest 

and fire pathways are the least inhibited. The most visible difference is in the Odell Pasture area where 

modeled wildfire would likely burn through the area and into the town of Crescent, as well as the 

subdivisions of Cascade Estates, Schoonover, and Tall Pines. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

119

Legend

contour

Roads

alternative A mtt

Ownership

<all other values>

OWNERSHIP

FS

PVT

BLT boundary

alternative A mtt

BLT Alternative A mtt

Figure 3-13. Alternative A Minimum Travel Time 25 Years 
BLT Project Environmental Impact Statement 

Chapter 3 – Fire and Fuels 

120

Activities Common to All Action Alternatives 

Timing of Slash Cleanup 

In general, harvest and temporary road building operations break up the continuity of fuels strata, so 

fire severity is usually reduced. However, there may be an elevated level of fine fuels (one year or less) 

in the short-term between harvest operations and post-sale activities. The risk would be from a humancaused ignition. Typically, during the summer months, contract operations are suspended during the 

times of highest industrial fire precaution levels, or mitigated through additional equipment on site, shut 

down times, and fire patrol. Historical records have shown that risk of a fire ignition as a result of 

harvest operations is much lower than from the recreating public, and should a fire result, a successful 

suppression is much more likely due to equipment and personnel on site. This risk was accounted for in 

the modeling; specifically the human-caused ignitions. 

Thinned stands of trees can have a shortened time lag for drying fuels and potential increases in surface 

winds relative to more closed stands. This effect becomes less of a factor for fire behavior as 

summertime weather progresses. Although closed stands take longer to reach low fuel moistures than 

open sites, as less moisture recovery occurs in July, August and September, fuel moistures in closed 

stands reach equilibrium with open sites relatively quickly. When this occurs, crown-driven wildfires 

are much easier initiated. The closed sites have more available flammable fuel due to higher levels of 

biomass across the fuels strata and live tree fuel moisture at its lowest level. 

Alternative B would have activity on 7,499 acres. Of that, 2,312 acres would have prescribed burning 

applied in appropriate stands, and 413 acres of fuels reduction outside harvest units. The following 

table displays fire behavior within activity units post implementation by weather and fuels model, with 

the Alternative A effects in parenthesis to illustrate the differences. 

Direct and Indirect Effects 

Alternative B 

The following is a summary of the fuel reduction activities that would occur for all action alternatives: 

Ground-based and Advanced Systems 

Harvesting would be accomplished with yarding with top attached to the top log or the entire tree. In 

some units, unmerchantable trees up to 8 inch would be felled. Unmerchantable tree felling is proposed 

to reduce ladder fuels and lower canopy bulk density. 

Pruning is proposed to reduce ladder fuels and increase crown base height of all trees to a height of 8 

feet or one third the crown. It is anticipated that pruning would be applied to about 80 percent of each 

unit. 

Following the harvest, unmerchantable tree felling, and pruning, prescribed fire is planned for 

appropriate areas (Table 2-2, Unit Prescriptions). In general, all dead and down logs greater than 9 

inches would be retained above minimum stands displayed in Chapter 2, Project Design Features. 

Minimum Standard and Guidelines for down logs would only apply where units overlap a Strategic 

Placement of Treatment (SPOT) to be maintained through time. 

Prescribed fire would also be applied to fire dependent ecosystems through underburning to reduce 

dead and down material and reintroduce fire into fire dependent ecosystems. It is anticipated that 

prescribed fire would be applied to about 80 percent of each unit to retain vegetative diversity. 

Utilization of special forest products would occur in those units specified in Table 2-2. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

121

Fuels Activities Unique to Ground-based Systems 

Grapple piling is prescribed for most ground-based harvest units. Grapple piling machines would be 

confined to existing skid trails, so that soil effects are confined to that already used in the harvest 

operation. The amount of area unreachable by grapple depends on the skid trail spacing but it is 

estimated that 30 to 40 percent of each unit would not be reachable. 

Fuel Activities Unique to Skyline and Helicopter Systems

No mechanical fuels reduction activities would occur. Handpiling and disposal would be accomplished 

by hand. Retrieval of special forest products would be limited to where the activity does not increase 

detrimental soil conditions. 

“Fuels Only” Activity Units Outside Harvest Units

Fuels reduction activities would also occur outside of harvest units. These areas would have the 

following prescription: 

• Thin trees 8 inches in diameter or less with 18 foot spacing. This prescription totals 135 trees 

per acre and reduces canopy bulk density and ladder fuels. 

• Prune remaining trees to maximum 8 feet canopy base height and/or retaining at least a third of 

the crown. 

• All material would be available for special forest products utilization (i.e. post and pole, 

firewood and biomass. 

• Prescribed underburn appropriate areas (Table 2-2, Unit Prescriptions). 

• Hand piling and brushing 

Lop and scatter activity slash in units deficient in Coarse Woody Material. Distributed material should 

not contribute to an increase in fire behavior. 

Table 3-35. Alternative B Fire Behavior within Activity Units Compared to Alternative A27

16%-89% weather 90%-97% weather 98%-problem fire 

Weather 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

Flame Length 

1’ 

(1’) 

1’ 

(1’) 

2’ 

(3’) 

1’ 

(1’) 

1’ 

(2’) 

2’ 

(4’) 

2’ 

(3’) 

2’ 

(6) 

8’ 

(14’) 

Rate of 

Spread 

(Chains Per 

Hour) 

0.7 

(0.9) 

0.7 

(1.6) 

2.0 

(3.4) 

0.8 

(1.1) 

0.8 

(2.0) 

2.5 

(4.1) 

6.4 

(11.9) 

6.4 

(35.4) 

47.1 

(69.1) 

Fire 

Characteristic Surface Surface Surface Active 

Crown 

Tree 

Mortality 

67% 

(67%) 

41% 

(41%) 

30% 

(40%) 

67% 

(67%) 

41% 

(42%) 

30% 

(44%) 

69% 

(83%) 

41% 

(80%) 

67% 

(97%) 

Acres 4,415 994 2,077 7,832 994 2,077 4,415 994 2,077 

 

27 Alternative A in parenthesis ( ) 
BLT Project Environmental Impact Statement 

Chapter 3 – Fire and Fuels 

122

Alternative B would increase maintenance of stands classified as Fire Regime 1 (frequent fire interval) 

from 800 to 3,112 acres within the analysis area, of 8,145 available. 

Alternative B would implement activities that are designed to reduce the extent of a wide scale 

disturbance from an insect or disease event on 7,499 acres. It would also modify fire behavior in 

activity units by changing the fuel model, raising the canopy base height, and reducing canopy bulk 

density. These activities in turn would lower the Condition Class. These activities are consistent with 

recommendations found in an assessment on the efficacy of fuel treatments on three large fires in 2007 

by the USDA Forest Service, State of Oregon, and USDI Bureau of Land Management. 

http://166.6.6.25/library/fuels_management/papers/pnw%20fuels%20effectiveness%20final.doc 

Activities proposed in Alternative B would reduce the severity of fire behavior within the activity units, 

and also may lower the fire behavior in another 5 to 15 percent of the area downwind of activity units 

due to a downwind shading effect. If an ignition occurs outside an activity unit, and is not contained 

within the unit, predicted fire effects would be similar to those displayed in Table 3-34, Alternative A 

Fire Behavior. 

Alternative B would overlap 2,017 of acres identified for Strategic Placement of Treatments (Figure 3-

14). The overlap of activity units provides the most strategic effectiveness for a potential wildfire. 

Figure 3-14 shows this alternative has the smallest fire size due to altering the fire pathway. 

Specifically, it shows the least likelihood of a wildfire burning into the town of Crescent as well as the 

subdivisions of Cascade Estates, Schoonover, and Tall Pines. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

123

Figure 3-14. Alternative B Minimum Travel Time 25 years 

Legend

contour

Roads

Ownership

<all other values>

OWNERSHIP

FS

PVT

BLT boundary

altb mtt

alt b unit and SPOT

BLT Alternative B mtt
BLT Project Environmental Impact Statement 

Chapter 3 – Fire and Fuels 

124

Alternative C 

Alternative C would have activity similar to Alternative B to a lesser extent on 5,771 acres. Of that, 

2,304 acres would have prescribed burning applied in appropriate stands, and 334 acres of fuels 

reduction outside harvest units. The following Table 3-36 displays fire behavior within activity units 

post implementation by weather and fuels model, with the Alternative A effects in parenthesis to 

illustrate the differences. 

Table 3-36. Alternative C Fire Behavior within Activity Units Compared to Alternative A28 

16%-89% weather 90%-97% weather 98%-problem fire 

Weather 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

Flame Length 

1’ 

(1’) 

1’ 

(1’) 

2’ 

(3’) 

1’ 

(1’) 

1’ 

(2’) 

2’ 

(4’) 

2’ 

(3’) 

2’ 

(6) 

8’ 

(14’) 

Rate of 

Spread 

(Chains Per 

Hour) 

0.7 

(0.9) 

0.7 

(1.6) 

2.0 

(3.4) 

0.8 

(1.1) 

0.8 

(2.0) 

2.5 

(4.1) 

6.4 

(11.9) 

6.4 

(35.4) 

47.1 

(69.1) 

Fire 

Characteristic Surface Surface Surface Active 

Crown 

Tree 

Mortality 

67% 

(67%) 

41% 

(41%) 

30% 

(40%) 

67% 

(67%) 

41% 

(42%) 

30% 

(44%) 

69% 

(83%) 

41% 

(80%) 

67% 

(97%) 

Acres 3,266 857 1,635 3,266 857 2077 3,266 857 1,635 

Alternative C would increase maintenance of stands classified as Fire Regime 1 (frequent fire interval) 

from 800 to 2,564 acres within the analysis area, of 8,145 available. 

Alternative C would modify fire behavior in activity units and associated shading effect as discussed in 

Alternative B by changing the fuel model, raising the canopy base height, and reducing canopy bulk 

density. 

Alternative C would overlap 1,490 acres identified for Strategic Placement of Treatments (Figure 3-15). 

Alternative C maintains the same effectiveness for stopping a wildfire near the town of Crescent as in 

Alternative B, however Alternative C shows an increase in wildfire spread over Alternative B across 

the remaining landscape. Fire has spread into the subdivision of Tall Pines. 

 

28 Alternative A in parenthesis ( ) 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

125

Figure 3-15. Alternative C Minimum Travel Time 25 years 

Legend

contour

Roads

Ownership

<all other values>

OWNERSHIP

FS

PVT

BLT boundary

altc_mtt

alt c unit and SPOT

BLT Alternative C mtt

Alternative D 

Alternative D would have activity similar to Alternative B and C to the least extent on 2,304 acres. Of 

that, 824 acres would have prescribed burning applied in appropriate stands, and 312 acres of fuels 
BLT Project Environmental Impact Statement 

Chapter 3 – Fire and Fuels 

126

reduction outside harvest units. The following, Table 3-37, displays fire behavior within activity units 

post implementation by weather and fuels model, with the Alternative A effects in parenthesis to 

illustrate the differences. 

Table 3-37. Alternative D Fire Behavior within Activity Units Compared to Alternative A29 

16%-89% Weather 90%-97% Weather 98%-Problem Fire 

Weather 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

TL3 

LP 

TL3 

MC 

TL6 

PP 

Flame Length 

1’ 

(1’) 

1’ 

(1’) 

2’ 

(3’) 

1’ 

(1’) 

1’ 

(2’) 

2’ 

(4’) 

2’ 

(3’) 

2’ 

(6) 

8’ 

(14’) 

Rate of 

Spread 

(Chains Per 

Hour) 

0.7 

(0.9) 

0.7 

(1.6) 

2.0 

(3.4) 

0.8 

(1.1) 

0.8 

(2.0) 

2.5 

(4.1) 

6.4 

(11.9) 

6.4 

(35.4) 

47.1 

(69.1) 

Fire 

Characteristic Surface Surface Surface Active 

Crown 

Tree 

Mortality 

67% 

(67%) 

41% 

(41%) 

30% 

(40%) 

67% 

(67%) 

41% 

(42%) 

30% 

(44%) 

69% 

(83%) 

41% 

(80%) 

67% 

(97%) 

Acres 1,698 211 694 1,698 211 694 1,611 211 694 

Alternative D would increase maintenance of stands classified as Fire Regime 1 (frequent fire interval) 

from 800 to 1,624 acres within the analysis area, of 8,145 available. 

Alternative D would modify fire behavior in activity units and associated shading effect as discussed in 

Alternative B by changing the fuel model, raising the canopy base height, and reducing canopy bulk 

density. 

Alternative D would overlap the least amount of acres (425) identified for Strategic Placement of 

Treatments (Figure 3-16). This alternative displays very little difference from Alternative A in 

modifying a wildfire pathway. Particularly, potential wildfire spread is most noticeable on the western 

edge of the town of Crescent. 

 

29 Alternative A in parenthesis ( ) 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fire and Fuels 

127

Figure 3-16. Alternative D Minimum Travel Time 25 years 

Legend

contour

Roads

Ownership

<all other values>

OWNERSHIP

FS

PVT

BLT boundary

alt d unit and spot

alt d mtt

BLT Alternative D mtt
BLT Project Environmental Impact Statement 

Chapter 3 – Fire and Fuels 

128

Mushrooms and Fuels Activities 

The goal is to reduce fuels hazard while creating the least amount of soil disturbance associated with 

effects to ectomycorrhizal fungi. In timber harvest units, where matsutake mushrooms are or have been 

found, fuels activities to minimize soil disturbance would include piling on existing skid trails, hauling 

slash to landings with top attached to the log, and techniques that lop and scatter. 

 

For a disclosure of the effects of fire on fungi, reference “Special Concern Plants” under the Botany 

section in Chapter 3. 

Cumulative Effects and Modeling 

The modeling and related discussions under the direct and indirect effects section included data 

imputed for private land ownership and all past and present activities. Modeling included all past and 

present activities up to 2008, using the District activity layers in the Forest Activity Tracking System 

(FACTS). The zone of influence is characterized as the Upper Little Deschutes Watershed because it 

originates near the crest of the Cascade Mountains and terminates on private land surrounding the 

communities of Gilchrist and Crescent and simulates the most logical path for a wildfire that could 

potentially threaten communities within the BLT area. It is assumed there are no other communities 

which potentially could be affected down wind and/or adjacent of the BLT project. All foreseeable 

actions listed in Table 3-1, such as small diameter thinning were reviewed and it was determined that 

their affect to landscape scale processes was small enough to be dismissed. Therefore, there are no 

additive effects from past, present, or foreseeable actions to discuss. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - Modeling 

129

Wildlife _____________________________________________ 

• Modeling Methodology 

• Deadwood Historical Range of Variability (HRV) 

• Management Indicator Species 

• Threatened and Endangered Species 

• Regional Forester’s Sensitive Species 

• Birds of Conservation Concern 

• Deer and Elk Habitat 

Modeling Methodology 

Habitat for the various wildlife species was determined using district occurrence data, habitat 

descriptions found in scientific literature, various data sets, and professional experience. The Viable 

Ecosystem Model (Viable) was used to determine the live tree component of habitat and formed the 

basis of acres of existing habitat (Viable Ecosystems Management Guide, 1994). For selected species, 

such as the black-backed woodpecker and American marten, the snag and down wood components of 

habitat were determined using a variety of sources including GNN data and DecAID, as well as Viable. 

Because of Forest Plan standards for cover and thermal cover requiring trees per acre and height, deer 

and elk habitat was determined using GNN data. 

This section describes each model and/or data set and how they were used separately or in combination 

with others. While modeling habitats or components generally match conditions known to occur on the 

ground, modeling does not necessarily match a specific point. It gives conditions that may occur given 

the assumptions of the model. Since it was used identically, for all alternatives, it provides a basis for 

comparison. 

Viable 

Viable stratifies the environment along a gradient of size, structure, species composition and relative 

tree density. The various classifications are linked to wildlife habitat requirements. For example, the 

classification with a value of 56152 is white fir (56), early seral (1), medium/large structure (5), low 

density (2) and would typically have a single story (low density) dominated by ponderosa pine (early 

seral in white fir) 21 inches in diameter or greater (medium/large structure). This mixed conifer value 

provides nesting habitat for white-headed woodpeckers. Where the value 56351 of white fir (56), late 

seral (3), medium/large (5), high density (1), it would be a multi-storied stand dominated by white fir 21 

inches in diameter or greater and provide habitat for pileated woodpeckers. All values that provide 

habitat for species were used. Using the white-headed woodpecker example, in addition to the mixed 

conifer value 56152, any seral stage dominated with ponderosa pine, medium/large structure, low 

density would provide similar open ponderosa pine habitat and was used in determining amounts of 

white-headed woodpecker habitat within the planning area. 

The September 2004 satellite imagery layer was used to develop the Viable Map. Data is mapped on 

25 meter pixel grid. This means the map is divided up on a 25 meter grid and that every 25 meter 

square (pixel) is assigned a value (e.g. 56322) that relates to a stratum of size, structure, species 

composition and relative tree density. 

Vegetation change was modeled over time. Results of thinning activities generally moved an individual 

pixel’s value within the actual area of treatment to a lower density and/or single structure value. 

Modeling in the Out-year, it moves each pixel to the next condition (value) within the gradient matrix 

based on the probability of the pixel to move that direction. 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – Modeling 

130

GNN 

GNN maps consist of 30 meter pixel (grid) maps with associated data (tree size, density, snag density, 

canopy cover, percent down wood cover, etc.). The maps used for this analysis were developed by the 

Landscape Ecology, Modeling, Mapping, and Analysis (LEMMA) team as part of the GNNPAC Pacific 

States Forest Vegetation Mapping project. This project involves developing detailed maps of existing 

forest vegetation across all land ownerships in the Pacific Coast States (Oregon, Washington, and parts 

of California). It is being conducted by the LEMMA team (PNW Research Station and Oregon State 

University) at the Corvallis Lab, in close collaboration with the Western Wildlands Environmental 

Threats Assessment Center, the Interagency Mapping and Assessment Project (IMAP), Northwest 

Forest Plan Effectiveness Monitoring, the Remote Sensing Applications Center, and Forest Inventory 

and Analysis at the PNW Research Station. 

The process to create the maps involves using gradient imputation (Gradient Nearest Neighbor, or 

GNN). GNN uses many variables on a gradient along with satellite imagery to assign data from known 

field plots to pixels with no data that have the same satellite imagery signature (i.e. it “looks” the same 

to the computer). The species-size GNN model was used in the BLT analysis. This model uses species 

composition and stand structure as components for developing maps. Accuracy of the modeling 

depends on how “like” the pixels match up based on numerous variables. Generally speaking, forest 

types that had more samples like white-fir, were more accurate than those with fewer samples like 

mountain mahogany (Ohman et al 2008). Information on GNN accuracy, the LEMMA group and the 

GNNPac project is available at the project website: http://www.fsl.orst.edu/lemma/gnnpac. 

DecAID 

DecAID is a web-based dataset, it is not a model. It is a synthesis of all of the best available research 

on dead wood. DecAID does not provide information on all life needs of a given species. It integrates 

current research/studies on wildlife use of dead wood (snags, down wood, dead portions of live trees) in 

various habitat types. From this, tolerance levels are generated. 

Tolerance level (t.l.) is the percent of the studied population that would use a density of snags or down 

wood. For example, the following table shows the tolerance levels for white-headed woodpeckers. For 

a population of 100 individual white-headed woodpeckers, at the 80% t.l., 80 of them would use habitat 

with at least 3.7 snags per acre greater than or equal to10 inches dbh. Basically the higher the tolerance 

level, the more assurance that you are providing habitat to meet the needs of more individuals in the 

population (Mellen et al 2006). 

 

Tolerance intervals were used to determine habitat levels in the planning area. A tolerance interval 

includes the range of snag density between tolerance levels. Using the example below, the 30-50 

percent tolerance interval would be habitat with at least 0.3 snags per acre and less than 1.7 snags per 

acre. 

Table 3-38. Example Table from DecAID 

Minimum DBH 10" 20" 

Habitat type and 

Table used from 

DecAID 

Species 

30% t.l. 

Snag 

Density 

(#/acre) 

50% t.l. 

Snag 

Density 

(#/acre) 

80% t.l. 

Snag 

Density 

(#/acre) 

30% t.l. 

Snag 

Density 

(#/acre) 

50% t.l. 

Snag 

Density 

(#/acre) 

80% t.l. 

Snag 

Density 

(#/acre) 

Table 

PPDF_S/L.sp-22 

Whiteheaded 

woodpecker 0.3 1.7 3.7 0.5 1.8 3.8 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - Modeling 

131

Example of Tolerance Interval Developed from DecAID Information 

Minimum DBH 10" 20" 

Snag Density (#/acre) Snag Density (#/acre) 

Habitat type and 

Table used from 

DecAID 

Species 30-50% 

t.i. 

50 -80% 

 t.i. 

80%+ 

t.i. 

30-50% 

t.i. 

50 -80% 

t.i. 

80% + 

t.i. 

Table 

PPDF_S/L.sp-22 

White-headed 

woodpecker 0.3-1.7 1.7-3.7 3.7+ 0.5-1.8 1.8-3.8 3.8+ 

Often times, DecAID only had one study available to base its tolerance levels on. While applying 

findings from a single research site to another area is not always wholly applicable, DecAID provides 

the best available science to determine effects to a species at this time. Used as a comparison for effects 

across all alternatives, it can be a useful tool. Tolerance levels do not equate to population potential, nor 

imply viability, but they are assumed to indicate habitat at varying snag densities. 

Besides data from wildlife studies, DecAID also uses vegetation data. DecAID uses vegetation 

inventory plots to approximate “natural” or “historic” levels of dead wood. This data is used to develop 

snag density Historical Range of Variation (HRV) for the planning area and then compare trends over 

time relative to HRV. Because the DecAID data is from the larger landscape, the general rule-of-thumb 

suggested for using this data is at least 12,800 acres. The planning area is approximately 80,000 acres. 

However, not all habitat types utilized reach the minimum. Since there is no active management 

proposed in montane mixed conifer, it is not included in the HRV analysis. Mixed conifer 

approximates the minimum suggested acreage. Given snag and down wood retention are part of the 

Project Design Features for all alternatives and the same values are used for comparison in all 

alternatives, the size of the analysis area was not increased for eastside mixed conifer habitat. 

Table 3-39. Habitat Types by Acreage within the Planning Area 

Habitat Acres in 

Planning Area 

Lodgepole Pine 39,000 

Mixed Conifer 12,305 

Montane Mixed conifer 7,220 

Ponderosa Pine/Douglas-Fir 16,055 

More information on DecAID can be found on the website at: 

www.fs.fed.us/wildecology/decaid/decaid_background/decaid_home.htm

Deer and Elk Habitat 

The Deschutes Forest Plan defines suitable deer hiding cover as one of the following: 

a) six acres or larger capable of hiding 90 percent of a standing adult deer from view of a human 

at a distance of 200 feet, or 

b) six acres or larger with an average height of 6 feet and which has not been thinned in 15 years, 

or 

c) residual clumps of one half acre or larger stands within units with advanced regeneration (trees 

including small trees with poor vigor up to 7 inches in diameter) and at least 12 greater than 7 

inch trees per acre remaining after harvest (DLRMP WL-54). 

Suitable elk hiding cover is similar: 

a) being six acres or larger capable of hiding 90 percent of a standing adult elk from view of a 

human at a distance of 200 feet, or 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – Modeling 

132

b) six acres or larger with an average height of 10 feet and which has not been thinned in 20 years, 

or 

c) residual clumps of two acres or larger stands within units with advanced regeneration (trees 

including small trees with poor vigor up to 7 inches in diameter) and at least 12 greater than 7 

inch trees per acre remaining after harvest (DLRMP WL-47). 

Elk thermal cover must be in blocks at least 10 acres in size and have an average height of at least 40 

feet with a minimum canopy cover of 40 percent (DLRMP WL-50). 

To be conservative, hiding cover for both species was modeled using GNN with the criteria of hiding 

90 percent of a standing adult elk from view of a human at a distance of 200 feet. This condition was 

modeled using trees with a density of at least 469 trees per hectare (190 trees per acre or a tree every 15 

feet) with a diameter of 3-25 centimeters (1-10 inches) and at least 2 meters (7 feet) tall across the 

80,000 acre planning area. Fields containing this data in GNN and the definitions from the data 

dictionary include: 

• TPH_3_25 – Density of live trees 2.5-25 centimeters in diameter in trees per hectare. 

• STNDHGT – Stand height, computed as average of heights of all dominant and codominant 

trees in meters. 

Thermal cover for the key elk area was modeled using GNN with the criteria of at least 40 percent 

canopy cover and tree height of at least 12.2 meters (40 feet) across the planning area and clipped to the 

key elk area. Fields containing this data in GNN and the definitions from the data dictionary include: 

• CANCOV – Canopy cover of all live trees; calculated using methods in the Forest Vegetation 

simulator 

• STNDHGT – Stand height, computed as average of heights of all dominant and codominant 

trees. 

LEMMA Data Dictionary: http://www.fsl.orst.edu/lemma/common/dataDictionary.php 

Snag and Down Wood 

Viable (25 meter grid) and GNN (30 meter grid) maps were broken down to a 5 meter grid size in order 

to merge them. This resulted in over a million combinations. Those combinations that represented less 

than an acre, or had null values were dropped. The remaining data was not averaged or summarized to 

maintain the diversity of conditions that could exist. Therefore, the strata 56322 may have 20 various 

densities of snags and down wood associated with it. This information was summarized in densities of 

snags/acre by either tolerance interval from DecAID for the species habitat analysis, or distribution of 

snags across the landscape for Historic Range of Variability (HRV) analysis. 

Snags densities were determined utilizing the following GNN fields: 

• STPH_GE_25 – Density of snags greater than or equal to 25 centimeters in diameter and 

greater than or equal to 2 meters tall and measured as trees per hectare. 

• STPH_GE_50 – Density of snags greater than or equal to 50 centimeters in diameter and 

greater than or equal to 2 meters tall and measured as trees per hectare. 

Down wood percent cover was determined utilizing the following GNN fields: 

• DCOV_GE_12 – Cover of down wood greater than or equal to 12.5 centimeters in diameter at 

intercept and greater than or equal to 1 meter long as percent cover. 

• DCOV_GE_50 – Cover of down wood greater than or equal to 50 centimeters in diameter at 

intercept and greater than or equal to 1 meter long as percent cover. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - Modeling 

133

The data from this merge was then used in the HRV and the species analyses. Utilizing the merged data 

assumes a given vegetative condition has a set of snag and down wood densities based on current 

condition. Through time, as the stands move from one point in the matrix to the next, snag densities are 

associated and move with the vegetative condition. This would tend to underestimate snag densities, as 

past management practices (that lead to the current existing condition) did not necessarily retain snags 

or down wood. Also, this merge underestimates snag densities over time because it does not take into 

account current management practices and the retention levels built into the Project Design Features, 

nor the leave areas that would include higher tree densities. However, it is the most complete data set 

available for the planning area, and was utilized the same for all alternatives. 

HRV 

HRV was determined by combining structure classes using a weighted average based on the DecAID 

vegetation data for snags, plots managed in a passive managed scenario and HRV from Viable 

Ecosystem. Data from passively managed stands provides a reference condition in the various habitat 

types for distribution of snag and down wood size and densities across a large landscape. This data was 

used along with historical range of variability (HRV) information from Viable to develop the local 

HRV of snag densities across a habitat type, with all structural stages lumped. Table 3-40 is an 

example of the HRV developed for the distribution of snags greater than or equal to 20 inches diameter 

breast height (dbh). It shows that historically, very little of the landscape had snags at densities greater 

than 18 snags per acre and most of the landscape in the ponderosa pine/Douglas-fir habitat type had no 

snags. This does not mean the project manages for “0” or low snag levels; it is a way to evaluate the 

conditions relative to what is thought to have been there historically. Retention of snags and down 

wood is built into the Project Design Features and a part of the analysis. 

Table 3-40. HRV Developed for Each Habitat Type 

HRV Density Distribution of snags ≥20" (50 cm) dbh 

Habitat Type Snags/Acre 

(snags/ha) 

0 

(0) 

0-2 

(0-5) 

2-4 

(5-10) 

4-6 

(10-15)

6-10 

(15-25) 

10-18 

(25-45) 

18+ 

(45+) 

EMC 31-40 14-20 14-18 10-13 10-15 5-7 1-2 

LP 25-79 4-9 4-10 1-4 1-2 0-1 0 

PP/DF 

% of landscape 

65-77 15-19 6-12 0-2 1-2 0-1 0 

Information from DecAID tables (unharvested plots for snags ≥20" (50cm) dbh) 

PP/DF_O.Inv-15, PP/DF_S.Inv-15, PP/DF_L.Inv-15, EMC_ECB_O.Inv-15., 

EMC_ECB_S.Inv-15, EMC_ECB_L.Inv-15, LP_O.Inv-15, LP_S.Inv-15, MMC_O.Inv15, MMC_S.Inv-15, MMC_L.Inv-15, and modified with HRV information from Viable 

HRV was then compared to the existing condition to determine if it is within historic ranges. 

Comparing alternatives overtime with HRV utilized the meshed GNN and Viable Ecosystem dataset. 

All habitat structural stages and sizes were lumped for this portion of the analysis and all 

habitat/deadwood combinations were maintained. 

Managing within HRV should provide for those species that survived to the present with those 

densities. Fire ecosystems have been altered due to fire exclusion policies over the years. Mellen et al. 

(2006) states dead wood levels may be above historical conditions due to fire exclusion policy and 

increased mortality, and may be depleted below historical levels locally due to areas burned by intense 

wildfire and/or management actions that salvaged wood after the beetle infestation in the 1990s and 

also cutting of firewood. The DecAID vegetation data was used for this analysis understanding that the 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – Modeling 

134

information from passively-managed plots may not accurately reflect “natural conditions.” They are 

comparable to historic dead wood densities in recent research (comparison of Harrod et al. 1998; Agee, 

2002; Ohmann and Waddell, 2002 in DecAID 2.0 narratives). Until new information becomes 

accessible, DecAID vegetation data provides the most current, empirical data available for dead wood 

evaluations. 

For more information on the development of the HRV condition for the planning area, reference 

Appendix B. 

Species Analysis 

Specific species analysis utilized information from district records, scientific literature, professional 

judgment, DecAID, Viable Ecosystem modeling and GNN data. The habitat components consist of 

Viable Ecosystem modeling for the green tree component and the merged Viable-GNN data to 

determine the snag and/or down wood component within the defined habitat. DecAID tolerance levels 

were used to determine the level of assurance of providing sufficient dead wood components for 

individuals of the population. For key species, the analysis includes changes over time by alternative. 

The same information and methods are utilized for each alternative. 

The analysis describes the habitat of each species, how it provides for varying densities of individuals 

across that habitat based on snag and/or down wood densities, and how that changes overtime based on 

active management. Generally, the higher the tolerance level, the more individuals in the population 

are likely to utilize that habitat. 

Dead Wood Historical Range of Variation (HRV) 

Introduction 

Dead wood (standing or down) plays an important role in overall ecosystem health, soil productivity 

and numerous species’ habitat. It is crucial in the continuation of species that depend on snags for all or 

parts of their life cycle (Laudenslayer 2002). Bird and mammal species rely on the structure for dens, 

nests, resting, roosting, and/or feeding on the animals and organisms that use dead wood for all or parts 

of their life cycle. Snags come in all sizes and go through breakdown and decay processes that change 

them from standing hard to soft, then on the ground to continue decaying into soil nutrients. Not every 

stage of the snag’s demise is utilized by the same species, but rather a whole array of species at various 

stages or conditions (Rose et al 2001). 

The Deschutes National Forest Plan, as amended, specify standards and guidelines for snags and down 

wood. Across the forest, snags are to be managed at 100 percent of Maximum Population Potential for 

primary cavity excavators (MPP). The forest determined guidelines for meeting this standard and 

documented them in the Deschutes National Forest Wildlife Tree and Log Implementation Strategy 

(USDA 1994). This strategy estimates the number of hard snags per acre by vegetative series and 

species. The following tables are summaries of Forest plan Standards and Guidelines for snag and 

down wood levels within the range of the northern spotted owl (west) and outside that range (east). 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - HRV 

135

Table 3-41. Deschutes National Forest Plan Standards for Snags 

Snag 

Standards for 

100% MPP 

West of the NSO range line East of the NSO range line 

Vegetative 

Series 

Minimum 

Snag 

dbh (in) 

Snags 

per 100 

acres 

Snags 

per 

Acre 

Minimum 

Snag 

dbh (in) 

Snags 

per 100 

acres 

Snags 

per 

Acre 

>20" 6 0.06 >20" 14 0.14 

>12" 129 1.29 >15" 211 2.11 Ponderosa Pine 

(PP) >10" 252 2.52 combined 10' and 12" into 15" 

PP Total Snags 387 3.87 225 2.25 

>20" 6 0.06 >20" 14 0.14 

>12" 135 1.35 >15" 211 2.11 Mixed Conifer 

(EMC) >10" 252 2.52 combined 10' and 12" into 15" 

EMC Total Snags 393 3.93 225 2.25 

>20" 6 0.06 

>12" 87 0.87 White (Grand) 

Fir (MMC) >10" 192 1.92 

MMC Total Snags 285 2.85 

Vegetative Series not found 

East of the NSO range line 

Lodgepole Pine >12" 66 0.66 >12" 59 0.59 

(LP) >10" 192 1.92 >10" 121 1.21 

LP Total Snags 258 2.58 180 1.8 

Table 3-42. Deschutes National Forest Plan Standards for Down Wood. 

Down 

Wood 

Standards 

West of the NSO range line 

 

East of the NSO range line 

(Eastside Screens) 

Vegetative 

Series Pieces per Acre 

Diameter 

small 

end 

Piece Length 

and Total 

lineal length 

Vegetative 

Series 

Pieces 

per 

Acre 

Diameter 

small 

end 

Piece Length and 

Total lineal length 

 PP 3-6 12" >6 ft. 20-40 ft. 

16" 16 ft 120 ft. 

 MC 15-20 12" >6 ft. 100-140 ft. 

All 

Vegetative 

Series 

 3 cull logs/acre + 

3 logs/acre in more 

advanced stages of 

decomposition 

(LRMP WL-72) (NWFP C-40) LP 15-20 8" >8 ft. 120-160 ft. 

Project Design Features (Chapter 2) meet or exceed the Deschutes National Forest (as amended) 

standards and move toward managing dead wood habitat across the landscape at higher levels than in 

the past. By retaining all existing snags and down wood except those that must be removed under 

limited circumstances, the analysis area is on a pathway to shift closer to the Historical Range of 

Variability (HRV). Retention of down wood in activity units where fire behavior modification is 

maintained through time or areas of potential firewood use (Table 3-42, Minimum Down Wood Levels 

Regardless of Location) also meet or exceed the Forest Plan standard. This management strategy 

recognizes the need of high densities of dead wood for wildlife, and the varying densities historically 

present. Managing within HRV would provide for those species that survived to the present with those 

densities, provide for risk reduction on a landscape level, meet the need to provide the local public with 

fuel wood to heat their homes, and other wood products from the forest. 

Fire ecosystems have been altered due to fire suppression over the years. Mellen et al. (2006) states 

dead wood levels may be above historical conditions due to fire suppression and increased mortality, 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – HRV 

136

and may be depleted below historical levels locally due to areas burned by intense fire or salvage 

following the 1990 beetle epidemic and firewood cutting. The DecAID Vegetation data was used for 

this analysis, mindful that the information from passively managed plots may not accurately reflect 

“natural conditions”. They are comparable to historic dead wood densities in recent research 

(comparison of Harrod et al. 1998, Agee 2002, Ohmann and Waddell 2002 in DecAID 2.0 narratives 

Mellen et al 2006). Until new information becomes accessible, the DecAID vegetation data provides 

the most current, empirical data available for dead wood evaluations. 

The purpose of this analysis is to look at the broad scale of effects as a result of the alternatives on dead 

wood densities across the landscape. 

Existing Condition 

There is a variable range of conditions across the planning area as a result of disturbance processes and 

management practices. The following Table 3-43 displays a simplified condition by habitat type where 

EMC represents all the mixed conifer plant association groups, PPDF for ponderosa pine, LP for 

lodgepole pine and MMC for the higher elevation mountain hemlock plant association groups. 

Table 3-43. Structural Condition by Habitat Type in BLT 

HABITAT 

TYPE EMC PPDF LP MMC 

HRV Range 

(from Viable)

Early 

 0-16% 

Mid 

0-32% 

Late 

0-20% 

Early 

0-25% 

Mid 

0-36% 

Late 

0-66% 

Early 

0-60%

Mid 

0-40%

Late 

0-1% 

Early 

0-15% 

Mid 

0-36%

Late 

0-20%

Existing 14% 66% 19% 22% 66% 12% 31% 64% 4% 1% 66% 33% 

Early = grass/forb, seedling/sapling (<4.9"dbh), Viable Structure 1 & 2, Mid = >4.9" dbh and <20.9, Viable Structure 3 & 4, 

Late = >20.9"dbh, Viable Structure 5

Table 3-43 displays in spite of salvage operations following the 1990 beetle epidemic and other 

management practices, sufficient live legacy structure was kept to maintain each habitat type within 

HRV for the Late Structure. There tends to be an over abundance in the mid-structural stages. 

While sufficient live legacy was retained, snag and down wood levels were not. Salvage of beetlekilled lodgepole pine included small material. Large snags of all species were greatly reduced across 

the landscape; especially ponderosa pine which was prized for firewood and thought to be a lightning 

rod and potential source of ignition. Table 3-44 illustrates those practices that resulted in a reduction of 

large snags. Snag densities are outside HRV in both size classes. It is accentuated in snags greater than 

20 inches in diameter, as the densities are lower than what could have historically occurred. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - HRV 

137

Table 3-44. Comparison of Existing Snag Densities with HRV 

Habitat 

Type

 snag/acre 

(snags/ha)

0 

(0)

0 - 6 

 (0-15)

6 - 12

(15-30)

12 - 24 

(30-60)

24 - 36 

(60-90)

36+ 

(90+)

Habitat 

Type

snag/acre 

(snags/ha)

0 

 (0)

 0-2 

 (0-5)

 2-4 

(5-10)

4-6 

 (10-15)

6-10 

 (15-25)

10-18 

(25-45)

18+ 

(45+)

HRV % 18-25 31-37 15-17 15-23 7-10 8-5 HRV % 31-40 14-20 14-18 10-13 10-15 5-7 1-2

% of 

Existing 

Landscape

27.6% 41.4% 11.8% 14.7% 2.9% 1.6%

% of 

Existing 

Landscape

46.9% 36.7% 12.0% 2.7% 1.3% 0.2% 0.1%

HRV % 9-33 5-18 8-20 6-15 4-10 4-9 HRV % 25-79 4-9 4-10 1-4 1-2 0-1 0

% of 

Existing 

Landscape

58.2% 32.0% 7.5% 1.5% 0.3% 0.5%

% of 

Existing 

Landscape

86.3% 10.6% 1.7% 1.3% 0.1% 0.0% 0.0%

 * snag/acre 

(snags/ha)

0 

(0)

0 - 4 

(0-10)

4 - 12 

(10-30)

12 - 24 

(30-60)

24 - 36 

(60-90)

36+ 

(90+)

HRV % 54-62 17-27 11-16 3-5 0-1 0-1

% of 

Existing 

Landscape

62.2% 25.5% 11.0% 0.9% 0.3% 0.1%

% of 

Existing 

Landscape

84.8% 12.4% 2.1% 0.7% 0.0% 0.0% 0.0%

LP

 Distribution of snags 10"+ (24.5cm) dbh 

Information from DecAID tables (unharvested plots for snags =10" (24.5cm) 

dbh) PP/DF_O.Inv-14, PP/DF_S.Inv-14, PP/DF_L.Inv-14, EMC_ECB_O.Inv14., EMC_ECB_S.Inv-14, EMC_ECB_L.Inv-14, LP_O.Inv-14, LP_S.Inv14,with HRV based on Viable HRV and weighted by structure.

* Density categories differ in PP/DF due to the PP/DF categories in DecAID, 

they couldn't be condensed in the same way as the other habitat types. 

EMC

LP

Comparison of HRV 

and Existing Condition

0

PP/DF

Information from DecAID tables (unharvested plots for snags =20" (50cm) dbh) 

PP/DF_O.Inv-15, PP/DF_S.Inv-15, PP/DF_L.Inv-15, EMC_ECB_O.Inv-15., 

EMC_ECB_S.Inv-15, EMC_ECB_L.Inv-15, LP_O.Inv-15, LP_S.Inv-15, with HRV 

based on Viable HRV and weighted by structure.

PP/DF

1-2

Comparison of HRV 

and Existing Condition Distribution of snags 20"+ (50cm) dbh 

EMC

HRV % 67-77 14-20 6-10 0-2 0

Table 3-45 displays the same deficiencies in the larger size classes for down wood. As small snags 

begin to fall, densities of down wood at the lower densities begin to increase. Down woody material 

greater than 20 inches in diameter is outside of HRV, even below 4-8 percent down wood cover for 

moderate densities. 

Table 3-45. Comparison of Existing Down Wood Densities with HRV 

Habitat 

Type

% down wood 

cover 0 0-4 4-8 8-10 >10 Habitat Type

% down wood 

cover 0 0-4 4-8 8-10 >10

(ton/acre) (0) (0-22) (22-44) (44-54) >(54) (ton/acre) (0) (0-22) (22-44) (44-54) >(54)

HRV % 22-30 53-54 13-19 2-3 1-3 HRV % 61-71 27-36 1-2 1-2 0

% of Existing 

Landscape 5% 76% 16% 4% 1% % of Existing Landscape 78% 21% 1% 0% 0%

(ton/acre) (0) (0-13) (13-26) (26-40) >(40) (ton/acre) (0) (0-13) (13-26) (26-40) (40-53)

HRV % 4-14 18-54 7-22 3-7 1-7 HRV % 27-84 6-16 1-2 0 0

% of Existing 

Landscape 9% 80% 9% 1% 1% % of Existing Landscape 89% 11% 0% 0% 0%

(ton/acre) (0) (0-21) (21-42) (42- 52) >(52) (ton/acre) (0) (0-21) (21-42) (42- 52) >(52)

HRV % 37-46 51-60 2-3 0 0 HRV % 69-80 19-30 0 0 0

% of Existing 

Landscape 10% 83% 5% 1% 1% % of Existing 

Landscape 85% 15% 0% 0% 0%

PP/DF PP/DF

Information from DecAID tables (unharvested plots for down wood 5"+ 

(12.5cm) dbh) PP/DF_O.Inv-16, PP/DF_S.Inv-16, PP/DF_L.Inv-16, 

EMC_ECB_O.Inv-16., EMC_ECB_S.Inv-16, EMC_ECB_L.Inv-16, LP_O.Inv16, LP_S.Inv-16. Combined with HRV information from Viable and weighted 

by structure. 

Information from DecAID tables (unharvested plots for down wood 20"+ 

(50cm) dbh) PP/DF_O.Inv-17, PP/DF_S.Inv-17, PP/DF_L.Inv-17, 

EMC_ECB_O.Inv-17, EMC_ECB_S.Inv-17, EMC_ECB_L.Inv-17, LP_O.Inv17, LP_S.Inv-17. Combined with HRV information from Viable and weighted 

by structure. 

EMC EMC

LP LP

Comparison of HRV and 

Existing Condition Distribution of down wood 5"+ (12.5cm) dbh Comparison of HRV and 

Existing Condition Distrbution of down wood 20"+ (50cm) dbh 

Direct, Indirect, and Cumulative Effects 

All activities that had potential to affect down wood in the past and present (including timber sales and 

wildfires) were incorporated into the modeling up to 2004. Since that time, very little activity has 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – HRV 

138

occurred and the following discussion reflects the dead wood conditions as of 2008. Because of the 

small percentage of active management in each habitat type, there is no difference in levels of dead 

wood across the landscape (Figures 3-17, 3-19, and 3-20 Changes in Snag Densities over Time). 

Thinning increases growth rates within activity units ultimately providing larger snags in the future on 

that site. These snags, in turn, become down wood. As observed on the Crescent Ranger District, 

fuels-related activities tend to create more snags than they consume, and can be used as a basic tool for 

creating additional snags, where there is a shortage. However, these activities tend to decrease the 

number of potential small snags (future small down wood) in the short-term. Due to retention of all 

existing snags and down wood except those that must be removed under limited circumstances (Project 

Design Features, Chapter 2), plus 15 percent of each activity unit retained in a passively-managed 

scenario, a decrease in snags on a landscape level due to management activities would be so small, it 

cannot be detected. For these reasons, the analysis of past actions other than those listed in this section 

is based on current environmental conditions. 

Due to the best available science and awareness for greater densities of dead wood in the right places on 

the landscape, it is assumed there would be a gradual increase in both snags and down wood in the 

future. 

Alternative B proposes the most active management of all the alternatives. Table 3-46 displays that the 

amount of treatment compared to the landscape is very small, varying from 8 to 13 percent by habitat 

type. 

Table 3-46. Alternative B Acres of Activity by Habitat Type 

Habitat 

Type 

Acres in 

Planning Area 

Acres in Treatment 

Units of Alternative B 

% of Habitat 

Type Treated 

LP 40,400 4429 11 

PP/DF 16,055 2083 13 

EMC 12,305 975 8 

Modeling over time shows there is no difference in alternatives. The following are examples of the 

analysis completed. Figures 3-17 through 3-20 display changes in distribution of snag densities over 

time by habitat type. The “X” axis shows current distribution by size at increments of 10, 20, and 50 

years. The figure also shows how it moves toward HRV, with marginally less percentage of the 

landscape showing 0 snags per acre (bottom segment) and increasing in the 0-6, 6-12 and 12-24 snags 

per acre categories (top 3 visible segments). 

Acquiring snags over 20 inches in diameter takes more time than the 50 years modeled, with little 

gained over that time frame (Figure 3-19 in the ponderosa pine habitat type). The greater gain in Figure 

3-20, is due to the more productive EMC habitat. 

Changes in down wood densities are similar, with no differences between alternatives. Lodgepole pine 

was used as the example in Figure HRV4. Even with the majority of activities taking place in 

lodgepole pine habitat in Alternative B, the table displays no differences between that and the no action 

alternative. Results of analysis in all habitats can be found in Appendix B. 

There are no foreseeable actions with potential to change dead wood levels that would be additive to the 

effects discussed for this project. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife - HRV 

139

Figure 3-17. Changes in Distribution of Snag Densities for Lodgepole Pine Habitat over Time 

Changes in Distribution of Snags ≥10" dbh in LP Habitat 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

current

Min

Max

102050102050102050102050

Existing ALT A ALT B ALTC ALT D

% of Landscape

36+ 

24-36 

12-24

6-12

0-6 

0

Figure 3-18. Changes in Distribution of Down Wood over Time in LP Habitat. 

Distribution of Down Wood > 5"dbh in LP Habitat

(% down wood cover)

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

current

Min. HRV

Max. HRV

YRS

102050102050102050102050

Existing ALT A ALT B ALT C ALT D

% of Landscape

>10

8-10

4-8

0 - 4 

0
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – HRV 

140

Figure 3-19. Changes in Distribution of Snag Densities in Ponderosa Pine Habitat over Time 

Distribution of Snags ≥20" dbh In PP Habitat

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

current

Min.

Max.

102050102050102050102050

Existing ALT A ALT B ALT C ALT D

% of Landscape

18+

10-18

6-10

4-6

2-4

0-2

0

Figure 3-20. Changes in Distribution of Snag Densities in Mixed Conifer Habitat over Time 

Distribution of Snags ≥20" dbh in EMC Habitat

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

current

Miin. 

Max.

102050102050102050102050

Existing ALT A ALT B ALT C ALT D

% of Landscape

18+

10-18

6-10

4-6

2-4

0-2

0
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

141

Management Indicator Species (MIS) 

During the preparation of the Deschutes National Forest Land and Resource Management Plan (USDA 

1990), a group of wildlife species were identified as Management Indicator Species (MIS). These 

species were selected because their welfare could be used as an indicator of other species dependent 

upon similar habitat conditions. Indicator species can be used to assess the impacts of management 

actions on a wide range of other wildlife with similar habitat requirements. The species listed in Table 

3-47 were selected for the Deschutes National Forest. 

Table 3-47. Deschutes National Forest Management Indicator Species 

Deschutes National Forest Management 

Indicator Species 

Presence Within The Analysis 

Area 

Three-Toed Woodpecker Yes 

American Marten Yes 

Northern Goshawk Yes 

Osprey Yes 

Northern Bald Eagle Yes 

Northern Spotted Owl Not Documented 

Mule Deer Yes 

Elk Yes 

Woodpecker Guild Yes 

Great Blue Heron Yes 

Great Gray Owl Yes 

Peregrine Falcon Not Documented 

Wolverine Not Documented 

Townsend’s Big-eared Bat Not Documented 

Waterfowl Yes 

Golden Eagle Yes 

Red-tail Hawk Yes 

Cooper’s Hawk Yes 

Sharp-shin Hawk Yes 

Effects to mule deer and elk are disclosed under the big game section in Chapter 3. Effects to the 

northern spotted owl, northern bald eagle, Townsend’s big-eared bat, peregrine falcon and wolverine 

are discussed in the Proposed, Endangered, Threatened, and Sensitive Species section, also in Chapter 

3. Potential effects to the remaining species are discussed here. 

Project activities would primarily focus on understory tree thinning and result in a reduction of tree 

stem density and overall canopy cover within activity units. As a result, the quality, effectiveness, and 

distribution of avian wildlife habitat available to some management indicator species in the planning 

area may be altered. Because of their potential to be most affected by actions within the analysis area 

the following three species were selected. They are: northern goshawk, three-toed woodpecker and 

black-backed woodpecker. Disclosure of effects to the remaining MIS species follows this section. 

Northern Goshawk

Ecology 

The northern goshawk is the largest member of the accipiter family and is distributed across most of 

Canada, the northern and western United States, and into Mexico. Reynolds and Wight (1978) located 

goshawk nests in Oregon from 580 meters elevation on the west slopes of the Cascades to 1,860 meters 

elevation in the Gearhart Mountains in eastern Oregon. Goshawks require trees with large limbs to 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

142

support their large nests, and not surprisingly, tend to place their nest in one of the larger trees on their 

nest site. Reynolds et al. (1992) stated preferred nest stands have a minimum of 40 percent canopy 

cover and the nest sites within these stands have greater than 60 percent canopy cover. Greenwald et 

al. (2005) reviewed goshawk nesting data and found that a majority of studies found a selection for 

stands with greater than 40 percent canopy as suitable goshawk nesting habitat. Vegetation plot data 

collected from Deschutes National Forest goshawk nest sites showed canopy cover ranging from 49-94 

percent (USDA 1993). Foraging areas are typically 4,900-5,900 acres; comprised of a forest mosaic 

that must support a wide range of suitable prey including ground dwellers or those occurring near the 

forest floor (Marshall et al. 2003). 

Sauer et al. (1996 cited in Wisdom et al. 2000) determined that breeding bird survey data for goshawk 

was insufficient to determine population trends for any state or physiographic region within the Interior 

Columbia River Basin because of low detection rates. However, sufficient data was available to 

indicate a stable trend in numbers between the years 1966-1995 for western North America. 

Breeding bird surveys provided insufficient data to determine population trends within any state or 

physiographic province in the Interior Columbia Basin. However, it is anticipated that goshawk 

populations on the Deschutes National Forest would decline in response to the loss of habitat due to 

wildfires over the last 6-8 years. The Oregon Natural Heritage Information Center maintains a list of 

the most current information available on the distribution and abundance of animals native to Oregon. 

They rank the northern goshawk population as demonstrably wide-spread, abundant, and secure. 

Existing Condition 

The Viable Ecosystem model was used to determine an estimated acreage of potentially suitable nesting 

habitat (Figure 3-21). The GIS datasets used for canopy closure class, stand structure class, plant 

association (group), and species are datasets from 2004. All timber sales, fuel reduction activities, 

natural disturbance events, such as wildfire, and vegetation activities on private lands within the BLT 

analysis area were included in this information. All activities that occurred after 2004, and their 

potential incremental effects within the BLT area, are discussed further in the cumulative effects 

section. The nesting definition used was lodgepole pine, ponderosa pine, white fir, Shasta red fir, and 

mountain hemlock Plant Association Groups (PAGs), with tree diameters greater than 10-15 inches in 

diameter, and having a closed canopy (greater than 25-55 percent depending on PAG type). This 

resulted in an estimated 14,211 acres of potentially suitable nesting habitat. Generally, this habitat is 

well distributed across the analysis area and includes some stands on private lands at the north end of 

the analysis area. 

The district wildlife sighting database has nineteen documented observations of goshawks in the 

analysis area, including four nest sites. Observation points seem to be concentrated in the Upper Little 

Deschutes canyon, Bunny Butte, south of Odell Butte, and south of Crescent, Oregon. Goshawk 

surveys using recorded adult alarm calls and wailing calls have occurred in the BLT analysis area since 

2001 with the exception of 2002. Since 2003, the surveys have focused on previous years’ sightings 

and audio responses to document pair occupancy and location of active nests. Of the four known nests, 

one is located west of the Hemlock Creek/Spruce Creek meadow complex and the remaining three are 

located in the upper Little Deschutes River canyon. The Hemlock/Spruce nest site is the only one 

within lands under the Regional Forester’s Amendment #2 direction; and a 400 acre Post-Fledgling 

Area (PFA) has been designated. This site was first located as active in 2003 and in 2005 goshawks 

were present although a nest was not located. Two of the three nests located west of the NWFP line 

were discovered in 1993 and 1996. The third does not have a discovery date listed. Two are located 

within the Mt. Thielsen Wilderness and the third is in the Oregon Cascades Recreation Area. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

143

Figure 3-21. Potential Northern Goshawk Nesting Habitat Based on the Viable Ecosystem Model 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

144

Table 3-48. Acres of Potential Goshawk Nesting Habitat within the BLT Analysis Area 

Nesting Habitat Acres 

Alternative Pre-Treatment Acres Treated Acres 

Remaining 

A 14,211 0 14,211 (100%) 

B 14,211 1,270 (9%) 12,941 (91%) 

C 14,211 1,016 (7%) 13,195 (93%) 

D 14,211 378 (3%) 13,833 (97%) 

Environmental Consequences: 

Alternative A 

Direct and Indirect Effects 

Implementation of this alternative would have no immediate effect on northern goshawks. In the shortterm, the existing territories would likely continue to be occupied by nesting pairs. Undiscovered pairs 

(if present) would also be unaffected by vegetation management actions. This alternative would have 

the greatest risk of future loss of goshawk habitat due to a wide-scale disturbance event. In the 

absence of disturbance events, the Viable program estimates there would be an increase in acres of 

suitable nesting habitat based on projections of stand growth advancing into later successional stages, 

with the appropriate level of canopy cover and tree diameters. 

Table 3-49 displays projections of suitable nesting habitat by alternative over time. Acreage amounts 

increase over time as a result of expected increase in tree vigor from thinning and the probability of 

advancing to the next successional stages. 

Table 3-49. Viable Ecosystem Modeling Projections of Goshawk Nesting Habitat over Time 

Alt. Existing Nesting 

Acres 

10 Year Projection 

of Nesting Acres 

20 year Projection 

of Nesting Acres 

50 Year Projection 

of Nesting Acres 

A 14,211 19,243 23,741 35,068 

B 14,211 19,743 24,615 36,882 

C 14,211 19,650 24,461 36,557 

D 14,211 19,430 24,052 35,685 

Alternative B 

Direct and Indirect Effects 

The selection of this alternative would result in the thinning of 1,270 acres (9 percent) of potentially 

suitable goshawk nesting habitat in the analysis area. Active management is designed to reduce stem 

densities, particularly in the understory layer. It would mostly remove trees less than 21 inches in 

diameter. There would be no removal of trees greater than 21 inches in diameter east of the Northwest 

Forest Plan boundary and only very limited cutting of trees greater than 21 inches within. Based on the 

size class of trees from similar timber sales such as Seven Buttes and Seven Buttes Return (USDA 1996 

and 2001), less than 5 percent of the total trees removed would be greater than 21 inches in diameter. 

Post-sale activities would include non-commercial thinning, slash removal, and application of 

prescribed fire within ponderosa pine dominated PAGs. This combination of activities would likely 

preclude use of these stands for nesting habitat due to the reduction of canopy cover. Post-harvest 

canopy cover is estimated to range from 20-25 percent in lodgepole pine and 30-35 percent in the 

ponderosa pine and mixed conifer. Jim Stone (personal communication, USDA, 2007) estimated 

canopy cover would increase 5 percent per decade in the ponderosa pine and mixed conifer PAGS. 

While the reduction in canopy cover may preclude nesting for several decades, the change in cover 

types may enhance the quality of goshawk foraging habitat. Hargis et al. (1994 cited by Wisdom 2000) 

stated goshawk foraging occurs in various cover types and structural stages, and the juxtaposition of 

several habitats may enhance the quality of foraging habitat around nest sites. However, Greenwald et 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

145

al. (2005) stated that goshawks foraged in similar stands used for nesting in the majority of the studies 

they reviewed. Within harvest units, snags would not be removed except those that must be removed 

under limited circumstances. This would provide sufficient dead wood standing and down for prey 

base habitat, where it occurs. 

For all alternatives, no activity would occur within a designated 400-acre Post Fledgling Area 

established for the Hemlock/Spruce Creek nest territory. There are also no activities planned within 

one mile of the other three known nest sites. 

Current forest structure in the analysis area is (at least partially) the result of decades of fire exclusion. 

This has resulted in an increase in stands with closed canopies with a dense conifer understory. These 

stands may not be as valuable for goshawks as the more open stands they replaced. A high density of 

small diameter trees may be detrimental to foraging and nesting aspects of goshawk ecology in at least 

three ways: (1) by obstructing flight corridors used by goshawks to obtain forest-associated prey; (2) by 

suppressing tree growth needed to produce large diameter trees for nest sites; and (3) by reducing the 

growth of an herbaceous understory that supports potential prey species (Reynolds et al. 1992, cited in 

Wisdom 2000). 

Wisdom et al. (2000) listed several issues, strategies, and management practices pertaining to northern 

goshawks in the Interior Columbia Basin assessment. Due to a fire exclusion policy in the West, there 

have been large transitions from shade-intolerant to shade-tolerant tree species, leading to possible 

unsustainable conditions of older forests. This has resulted in an increased susceptibility to standreplacing wildfires. Wisdom also stated that long-term maintenance of foraging areas is as important 

for successful reproduction as protection of the immediate nest stand. To address these issues, Wisdom 

recommends a variety of cover types and structural stages within the home range of each active nest. 

Management practices that would assist in habitat risk reduction, include prescribed fire and thinning to 

reduce fuel loading and to encourage the development of forest and shrub openings, and shadeintolerant and fire-, insect-, and disease-resistant tree species. The active management proposed for the 

BLT project is consistent with these recommendations. 

The removal of 9 percent of the potential nesting habitat would likely have little long-term effect to 

goshawks. Nesting habitat would remain well distributed across the analysis area. As displayed in 

Table 3-49, this alternative shows the greatest increase in suitable nesting habitat over all projected 

decades, including the no-action alternative. Within activity units, a minimum of 15 percent would be 

retained in a passive management scenario and capable of providing a potential goshawk nest stand, 

where appropriate structure exists. Because well distributed nesting habitat is available to function as 

future replacement, there would be no reduction in the numbers of goshawk home ranges that can be 

supported across the analysis area. In addition, there would be no loss of Late and Old Structured 

habitat, because the largest trees would be retained. Within younger-aged stands, reduced competition 

for scarce resources as a result of thinning would allow the residual trees to increase their size potential. 

Alternative C 

Direct and Indirect Effects 

This alternative would result in the commercial thinning of 1,016 acres (7 percent) of the current 

potentially suitable goshawk nesting habitat in the analysis area. As described in Alternative B, 

thinning prescriptions are designed to remove competition from mostly the smallest size classes. They 

are also designed to allow careful reintroduction of a frequent fire regime into appropriate stands. All 

dead and standing trees would remain except for occupational safety, clearing for log landings, and 

temporary road construction. 

The expected reduction in canopy cover below that typically selected by nesting goshawks would be 

similar to that described for Alternative B, except on 254 fewer acres. Retention of additional nesting 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

146

habitat would occur east of Bunny Butte and north of Highway 58 and east of the Upper Little 

Deschutes River. Within the mixed conifer and ponderosa pine PAGs selected for commercial 

thinning, increasing canopy cover may allow these stands (in several decades) to return to a level 

suitable for nesting (greater than 40 percent). 

As described for Alternative B, the vegetation activities proposed are consistent with recommendations 

by Reynolds et al. (1992) to reduce small tree densities to improve foraging habitat and increase the 

growth of residual trees. However, Greenwald et al. (2005) stated that goshawks foraged in similar 

stands used for nesting in the majority of the studies they reviewed. Also, effects of fuels reduction 

activities outside of harvest units and construction of temporary roads are as discussed in Alternative B. 

As displayed in Table 3-49, this alternative shows the second greatest amount of suitable nesting habitat 

over all projected decades including the no-action alternative. Over 93 percent of the potentially 

suitable nesting habitat would be maintained in its current condition, in addition to the 15 percent areas 

within units managed in a passive scenario. Because of the well distributed existing and future nest 

habitat, there would be no reduction in the numbers of goshawk home ranges that can be supported 

across the analysis area. 

Alternative D 

Direct and Indirect Effects 

As displayed in Table 3-49, this alternative displays an increase in suitable nesting habitat over all 

projected decades, exceeding the no-action alternative. It would thin 378 acres (3 percent) of 

potentially suitable goshawk nesting habitat in the analysis area, retaining the most short-term nesting 

habitat of the action alternatives. It also thins the least amount of habitat recommended by Reynolds to 

enhance foraging adjacent to nest stands. As described for Alternatives B and C, prescriptions are 

designed to retain the largest trees and there would be no loss of Late and Old-Structured forests. For 

thinned stands to return to the canopy densities needed for suitable nesting habitat, it is estimated it 

would be at a rate of 5 percent per decade. Sufficient snags and down wood would be available for 

goshawk prey base habitat where they occur in harvest areas. 

Activities planned with the BLT project are consistent with the recommendations from Wisdom et al. in 

that forests are in an unsustainable condition, and long term maintenance of foraging stands adjacent to 

nesting areas is important. The removal of 3 percent of the potential nesting habitat would likely have 

little long-term effect on goshawk populations. However, Greenwald et al. (2005) stated that goshawks 

foraged in similar stands used for nesting in the majority of the studies they reviewed. Also, effects of 

fuels reduction activities outside of harvest units and construction of temporary roads are as discussed 

in Alternative B. 

Because Alternative D proposes treatment on 638 fewer acres than Alternative C and 892 fewer acres 

of nesting habitat than Alternative B, more acreage would be maintained with greater canopy cover 

available for nesting goshawks. 

Over 97 percent of the potentially suitable nesting habitat would be maintained in its current condition, 

in addition to the 15 percent areas within units managed in a passive scenario. Because of the well 

distributed existing and future nest habitat, there would be no reduction in the numbers of goshawk 

home ranges that can be supported across the analysis area. 

Cumulative Effects 

Table 3-1 was reviewed for past and current vegetation management projects with potential for additive 

effects that would overlap in space and time with those of the BLT project. The zone of influence is 

defined as the Crescent Ranger District because it is a large enough area to support multiple home 

ranges. The following activities have reduced acres of goshawk nesting habitat: 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

147

• Baja 58 project thinned 2,878 acres of the understory. Baja overlaps the BLT planning area 

and most was accounted for in the existing condition up to September 2004. 

• Crescent Lake Hazardous Fuels Reduction Wildland Urban Interface Project thinned 1,951 

acres of the understory. 

• Seven Buttes thinned 2,328 acres of the understory. 

• Within the next 2 years, Five Buttes project would thin 4,499 acres of the understory. 

• Seven Buttes Return project thinned approximately 5,000 acres. 

• The Davis Fire lost 17,000 acres due to stand replacement. 

Of the 2,878 acres of thinning, 1,310 acres of sales since September 2004 is assumed to alter habitat. It 

would result in 11,631 acres (82 percent) of suitable habitat remaining for Alternative B. This would be 

followed by 11,885 (84 percent) in Alternative C and 12, 523 acres (88 percent) in Alternative D. Also, 

these totals are conservative as not all acres that are harvested are likely to alter habitat for the northern 

goshawk. 

These additional acres of habitat altered from the Baja timber sales since 2004 do not change the 

conclusions disclosed under direct and indirect effects. Nesting habitat would remain well distributed 

across the analysis area. In addition to modeled habitat for all species, 15 percent of each activity unit 

is managed in a passive scenario and was not included in the total. With the combination of past and 

present actions, well distributed nest habitat is available to function as future replacement and there 

would be no reduction in the numbers of goshawk home ranges that can be supported across the 

analysis area. For these reasons, the analysis of past actions other than those listed in this section is 

based on current environmental conditions. 

 

Of the most recent projects, the greatest reduction to goshawk nesting habitat was the approximate 

17,000 acres lost to stand replacement in the Davis Fire in 2003. This resulted in the complete loss of 

both nesting and foraging habitat for approximately 3-4 pairs of goshawks. 

It should be noted the Davis Fire overlapped the Seven Buttes and Seven Buttes Return projects. 

Therefore, some of the acres displayed are duplicated and the actual acreage of reduced nesting habitat 

is less. The Five Buttes, Crescent Lake, and Baja 58 projects combined would have 68,848 acres of 

potential goshawk nesting remaining after implementation is complete. 

While thinning has resulted in reduced canopy cover likely precluding treated stands from functioning 

as nesting habitat, all thinned acres may remain functional as foraging habitat. Greenwald et al. (2005) 

reviewed recent studies on goshawk telemetry research and concluded most studies indicated goshawks 

use foraging habitat that is similar to nesting habitat. This would indicate that thinned stands being used 

as foraging habitat is inconclusive at this time. Passive management retention areas of a minimum 15 

percent regardless of management allocation within each activity unit have been incorporated into the 

design of each past harvest unit across the district. These areas provide additional patches of nesting 

structure capable of supporting goshawk pairs. 

Most of the private lands in the analysis area have been industrial forest timberlands with extensive 

timber harvest in the last 5-6 years. The Viable model indicates some nesting capability is present on 

private lands in the analysis area although, there is no assurance these stands would be managed as such 

in the short- or long-term. 

Project implementation is not expected to lead to a loss in pair territories in the analysis area or across 

the Crescent Ranger District. 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

148

Consistency with Eastside Screens 

Project Design Features in Chapter 2 have been incorporated into the action alternatives to prohibit 

disturbance to nesting pairs if located in the analysis area. The Eastside Screens (USDA 1994) 

provided the following standards and guidelines for goshawks: (1) protect every known active and 

historical nest-site (previous 5 years) from disturbance; (2) protect 30 acres of the most suitable nesting 

habitat surrounding all active and historical nest tree(s) and defer from harvest; and (3) a 400 acre 

“post-fledgling” (PFA) will be established around every known active nest site. While harvest 

activities can occur within this area, retain the LOS stands and enhance younger aged stands towards 

LOS conditions, as possible. There would be no activity conducted within known goshawk nest stands 

or post-fledgling areas based on current knowledge of nest locations. 

Black-backed and Three-toed Woodpeckers

Ecology 

Habitat use by both woodpeckers show some similarities and some differences in stands selected for 

nesting, roosting, and foraging. Marshall et al. (2003) described the center of abundance for blackbacked woodpeckers in Oregon as the lodgepole pine forest east of the Cascade Crest between Bend 

and Klamath Falls. For the three-toed woodpecker, Marshall et al. (2003), describes the species as rare 

and local reports come sparingly from both slopes of the Cascades and the Blue Mountains. Habitats 

for both species include lodgepole pine forests, mixed conifer, and mountain hemlock, although forest 

type may not be as important as the presence of bark beetles (Marshall et al. 2003). 

Goggans et al. (1989) conducted a study on the Deschutes National Forest during a mountain pine 

beetle epidemic, including a portion of the Crescent Ranger District, on both species showing nesting, 

roosting, and foraging preferences. Both species nest in stands with bark beetles, disease, and heart rot. 

The Goggans study concluded that lodgepole pine trees with heart rot were used exclusively for nesting 

by three-toed woodpeckers with 75 percent of the nests in snags. For black-backed woodpeckers, 89 

percent of the nest trees were in lodgepole pine with heart rot with 65 percent of the nests in live trees. 

In the study, mean nest tree diameter for each species was 11 inches in diameter although in the Blue 

Mountains of Oregon; average nest tree diameter was 14.6 inches (Bull et al. cited by Wisdom et al. 

2000). Goggans et al. (1989) also concluded that the three-toed woodpeckers selected for nest stands at 

a slightly higher elevation, 4500-5600 feet, as compared to black-backs at 4350-5400 feet elevation. 

Neither species prefers to roost in logged forests. Both avoided cut areas for foraging. Other 

differences included three-toed woodpeckers selected nesting stands undisturbed by logging at a higher 

rate than black-backs (75 to 49 percent of total nests located) and that three-toed woodpeckers selected 

mountain hemlock stands for roosting while black-backs selected lodgepole pine, mixed conifer with 

lodgepole pine, or mountain hemlock with lodgepole pine. 

Estimated summer home ranges for three individual black-backed woodpeckers in a bark beetle 

outbreak varied from 178 to 810 acres, with home ranges decreasing in size as the proportion of 

unlogged and mature acres of forest increased (Goggans et al. 1989). However, the same study of radio 

telemetry data of three banded three-toed woodpecker males showed estimated summer home ranges 

varied from 131 to 751 acres. Home range acreage was not related to the amount of unlogged area or 

the amount of mature and immature forest present. 

The Oregon State Heritage Program lists both species ranking as S3, Vulnerable (NatureServe 2008). 

This is due to each species’ association with forest disturbances and large home ranges making it 

sensitive to logging and forest fragmentation. Both species show an affinity for burned forests and 

there is good evidence that bark-beetle killed forests are important habitats in Oregon and the species 

also occurs sparingly in unburned, mature forests (Marshal et al. 2003). However, stand-replacing fires 

produce habitats that briefly contain abundant food resources for woodpeckers (McCullough et al. 1998 

cited in Marshall et al. 2003). After 3-5 years, the majority of the insects inhabiting the dead wood 

emerge as adults and do not re-colonize the dead trees, resulting in a decrease in food availability and 
Environmental Impact Statement BLT Project 

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149

hence habitat suitability for woodpeckers. Wisdom et al. (2000) reported that results from breeding 

bird surveys (BBS) indicate black-backed trends from 1966-1995 as stable in North America. 

However, trend data generated by BBS may be inadequate for monitoring due to this species 

uncommon status and its difficulty to detect. For the three-toed woodpecker, Wisdom et al. (2000) 

reported from 14 BBS routes, trend data showed an annual 0.7 percent decline between 1966 and 1995. 

Wisdom et al. (2000) stated there are several factors affecting these species. Silvicultural practices (tree 

harvest before susceptibility to beetle attack) and fire management policies (salvage logging) have 

altered natural patterns of beetle outbreaks. Also, increasing road densities have allowed greater human 

access into forested regions for snag removal as firewood. Usurpation of black-backed nest cavities by 

hairy woodpeckers and Lewis’ woodpeckers (Goggans et al. and Saab and Dudley 1995 cited by 

Wisdom et al. 2000) may potentially reduce their reproductive success. 

Figure 3-22 displays black-backed and three-toed woodpecker nesting habitat, down wood, and snag 

densities across the BLT analysis area. As described in Modeling and Methodology at the start of this 

section, there were basically two models used: Viable Ecosystem which modeled the live component 

and is labeled “Viable” on the legend and Gradient Nearest Neighbor (GNN) which modeled the snags 

and down wood component. “Snags” meet criteria of greater than or equal to 10 inches in diameter and 

greater than 2.5 snags/acre. This figure displays where there is no habitat for either species, where the 

Viable model shows habitat present, where snags and down wood meet the 30 percent tolerance 

interval, where Viable and snags overlap, where Viable snags and down wood at the 30 percent 

tolerance interval overlap, and finally where snags and down wood only overlap at the 30 percent 

tolerance interval. 

The GIS datasets used for canopy closure class, stand structure class, plant association (group), and 

species are datasets from 2004. All timber sales, fuel reduction activities, natural disturbance events 

such as wildfire, and vegetation activities on private lands within the BLT analysis area were included 

in this information. All activities that occurred after 2004 and their potential incremental effects within 

the BLT area are discussed further in the cumulative effects section. 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

150

Figure 3-22. Black-Backed and Three-Toed Woodpeckers Nesting Habitat, Down Wood, and 

Snag Densities as Modeled by Viable Ecosystem
Environmental Impact Statement BLT Project 

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151

Existing Condition 

Because of apparent similarities in selection of nest stands, the Viable Ecosystem model used a similar 

nesting habitat for each species. All lodgepole pine or mixed conifer and mountain hemlock PAGs with 

lodgepole pine with trees greater than 5-10 inches diameter above 4,500 feet (minimum Crescent 

District elevation) was used to estimate acres of potentially suitable nesting habitat in the analysis area. 

This size range was used because the Goggans et al. study (1989) showed nest tree diameters ranged 

from 7-17 inches. Using this definition, modeling indicated approximately 57,107 acres of nesting 

habitat or 71 percent of the analysis area (Figure 3-22). This includes acreage found on private 

industrial forestlands in the analysis area. Potential nesting habitat is widely distributed across the 

entire planning area. 

District observational records show 10 reports of black-backed woodpeckers including a cluster of sites 

west of the Two Rivers subdivision, lower Hemlock Creek drainage, and near the Upper Little 

Deschutes Fire west of the community of Crescent, Oregon. Only one black-backed nest has ever been 

reported which was located east of Swamp Creek. There are no records of three-toed woodpeckers in 

the analysis area. 

Table 3-50. Projected Changes to Black-Backed and Three-Toed Woodpecker Nesting Habitat 

Alternative 

Acres of 

Reduced Nesting 

Habitat 

Acres of Remaining 

Nesting Habitat 

Post-Treatment Use 

by 

Black-Backed 

Post-Treatment Use by

Three-Toed 

A 0 57,107 (100%) 

Remains 

Functional Nesting 

Habitat 

Remains 

Functional Nesting 

Habitat 

B 6,547 (12%) 50,560 (88%) 

Potential for Nesting; 

Stand Avoidance As 

Roosting and 

Foraging 

Less Likely To Nest Stand 

Avoidance As Roosting 

and Foraging 

C 4,989 (9%) 52,118 (91%) 

Potential for Nesting; 

Stand Avoidance As 

Roosting and 

Foraging 

Less Likely To Nest Stand 

Avoidance As Roosting 

and Foraging 

D 2,247 (4%) 54,860 (96%) 

Potential for Nesting; 

Stand Avoidance As 

Roosting and 

Foraging 

Less Likely To Nest 

Stand Avoidance As 

Roosting and Foraging 

Alternative A 

Direct and Indirect Effects 

The selection of this alternative would have no immediate effect on three-toed and black-backed 

woodpeckers or their habitat. It is assumed that suitable lands would continue to be occupied by both 

species regardless of disturbance events resulting in tree mortality. While both species will utilize and 

selectively seek fire-killed lodgepole and mixed conifer stands to feed on insects, this is a relatively 

short-term situation lasting 5-7 years. This is also the period when snag fall intensifies, particularly in 

lodgepole pine forests. 

This alternative has the greatest level of risk from a wide-scale disturbance event and the tradeoff 

would be short versus long-term habitat. An event of a large magnitude would alter habitat for many 

decades and would not contribute to suitable habitat conditions over the long-term, however, there 

would be a short-term foraging boon for 5-7 years. 
BLT Project Environmental Impact Statement 

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152

Effects Common to All Action Alternatives 

Table 3-51. Tolerance Intervals for Black-Backed Woodpeckers and Snag Use 

Black-back 

Woodpecker 

57,107 Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 50% 50-80% 80%+

Density 

(#/hectare)* 00-6.2 6.2-33.6 33.6-72.1 72.1+ 0.0-3.5 3.5-14.1 14.1+

Density (#/acre)* 0-2.5 2.5-13.6 13.6-29.3 29.2+ 0.0-1.4 1.4-5.7 5.7+

% of Habitat 62.6% 26.4% 7.9% 3.1% 84.8% 10.0% 5.2%

Acres 35,744 15,057 4,534 1,773 48,408 5,725 2,974

Density of Snags = 20" dbh 

by tolerance interval

Density of Snags = 10" dbh

 by tolerance interval

*From DecAID 2.0 Tables EMC_S/L.sp-22 and PPDF_S/L.sp-22. Information synthesized from various 

studies. Species utilizing high snag densities are generally utilizing clumps of snags.

The Viable Ecosystem Model estimated there are 57,107 acres of nesting habitat available for the 

black-backed and three-toed woodpeckers (Table 3-50). This is based on tree size classes and 

appropriate PAGs typically selected for nesting by black-backed woodpeckers. Table 3-51 displays the 

range of tolerance interval based on snag levels taken from DecAID. Essentially, a tolerance level 

below 30 percent (0-2.5 snags per acre greater than 10 inches in diameter) is habitat that is less suitable 

for species use than acreage that supports higher levels of snag densities. The same table shows that 

62.6 percent of the current acres described by Viable Ecosystem as suitable nesting contains snag 

densities less than 2.5 per acre. This is likely the result of past regeneration timber harvests and salvage 

harvest as a result of the bark beetle epidemic in the 1990s in lodgepole pine stands. However, looking 

at historical conditions, 14-56 percent of the suitable PAG acreages had snag levels of less than 6.2 

snags per acre greater than 10 inches in diameter. For more information on Historical Range of 

Variability, reference Forested Vegetation section in Chapter 3. 

Table 3-52. Tolerance Intervals for Black-Backed Woodpecker and Down Wood Use 

Black-back 

Woodpecker 

57,107 Acres

Tolerance Interval below 30% 30-50% 50-80% 80%+

% Down wood Cover* <4.7 4.7-13 13-25.1 25.1+

% of Habitat 86.0% 13.6% 0.4% 0%

Acres 49,025 7,820 262 0

Distribution of down wood <= 5" (12cm) 

Developed from DecAID 2.0 Tables EMC_L.sp-24, EMC_S.sp-24, and LP_S/L.sp24. Synthesized data from various studies. Caution on use of data from DecAID that 

these data were collected during a mountain pine beetle outbreak and thus dead 

wood levels were elevated.
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

153

Table 3-53. Tolerance Intervals for Three-Toed Woodpecker and Down Wood Use30

Three-toed 

Woodpecker 

57,107 Acres

Tolerance Interval below 30% 30-50% 50-80% 80%+

% Down wood Cover* <6.5 6.5-17 17-32 32+

% of Habitat 92% 8% 0% 0%

Acres 52,538 4,569 0 0

Developed from DecAID 2.0 Tables EMC_L.sp-24, EMC_S.sp-24, LP_S/L.sp-24, 

MMC_L.sp-24 and MMC_S.sp-24. Synthesized data from various studies. Caution 

on use of data from DecAID that these data were collected during a mountain pine 

beetle outbreak and thus dead wood levels were elevated.

Distribution of down wood <= 5" (12cm) 

Tables 3-52 and 3-53 display levels of down wood used by black-backed and three-toed woodpeckers. 

As indicated from the tables, 86-92 percent of the existing suitable nesting habitat defined by Viable 

Ecosystem has down wood at less than the 30 percent tolerance interval, meaning the habitat is less 

suitable than acreage with higher levels of down wood. This is likely the result of past regeneration 

timber harvest and salvage harvest as a result of the bark beetle epidemic in the 1990s in lodgepole pine 

stands. However, looking at historical conditions, 4 -54 percent of the suitable PAG acreages had down 

wood levels of less than 4 percent down wood cover greater than 5 inches in diameter. For more 

discussion on Historical Range of Variability, reference the Forested Vegetation section in Chapter 3. 

All action alternatives would prescribe thinning and post-sale activities such as non-commercial 

thinning, piling of slash, firewood removal, and careful reintroduction of prescribed fire in ponderosa 

pine dominated PAGs. These actions would reduce canopy cover and lessen vertical vegetation 

diversity. Existing snag habitat, which is especially important to three-toed woodpeckers for nesting, 

would generally remain in its current state. Thinning activities would lessen the risk of future largescale bark beetle outbreak, but endemic levels of beetles would remain present and result in much lower 

levels of future tree mortality. These would be distributed in individual trees or clumpy patches. While 

all snags are intended to remain, some incidental loss may occur during the construction of temporary 

roads, placement of landings where the logs are stacked and processed, or for occupational safety. Loss 

of hard snags along designated haul routes has not been monitored; however, professional judgment 

estimates these numbers to be relatively small and within levels that are routinely felled for public 

safety along Highway Safety Act roads. Monitoring by harvest inspectors show approximately 1 

percent of snags are lost through harvest. The development of prescribed burning plans incorporates 

Project Design Features (Chapter 2) for the protection of snags. These features have proven to be 

effective in numerous projects such as Seven Buttes Return and Baja 58 timber sales where over 90 

percent of all snags were retained (personal communication with Jeff Bishop, Assistant Fire 

Management Officer, 2008). 

Personal use and/or commercial firewood is proposed within units 80, 270, 295, 435, 575, 690, 940, 

1190, 1200, 1205, 1235, and 1300 to provide a product for people in communities that depend on wood 

for home heating. These are the only treatment units where dead and down wood may be removed. As 

displayed in Figure 3-22, the heaviest concentrations of dead and down wood that provide the highest 

quality habitat for both species is located in the Mt. Thielsen Wilderness and Oregon Cascades 

Recreation Area (OCRA) where timber harvest would not occur. Where firewood removal would 

occur, Project Design Features have been incorporated to specify minimum levels in addition to 

Strategic Placement of Treatments (SPOTS) where the fuels strata are maintained through time 

regardless of the PAG. The tonnage per acre to be retained would range from 7-42 in lodgepole pine 

 

30 DecAID snag tables are not available for the three-toed woodpecker 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

154

which equates to 2-12 percent down wood cover and 11-42 in the montane mixed conifer stands 

(mountain hemlock) which equates to 2-8 percent down wood cover. Monitoring of the woodcutting 

areas is standard practice on the District and would determine when these levels have been reached. 

When this occurs, woodcutting areas would be closed down. 

Data from Historical Range of Variability (HRV) conditions indicate that for lodgepole pine, 18-54 

percent of the landscape had 0-4 percent down wood cover greater than 5 inches in diameter and 

currently approximately 80 percent of the lodgepole pine PAG has 0-4 percent down wood cover. At 

the 4-8 percent down wood cover level HRV indicates the range from 7-22 percent of the lodgepole 

PAG. Currently it is at approximately 9 percent within the HRV. In the montane mixed conifer PAGs, 

HRV conditions indicate 26-41 percent of the PAGs acreage was in the 0-4 percent down wood cover 

level greater than 5 percent in diameter. Currently it is at 49 percent. At the 4-8 percent down wood 

cover level, HRV shows a range of 3-17 percent. Currently there is an estimated 31 percent which is 

substantially above HRV. This shows the best habitat is in OCRA and Mt. Thielsen Wilderness, 

providing more suitable acreage than occurred historically. 

For the three-toed woodpecker, all thinning prescriptions in suitable nesting habitat are likely to result 

in a reduced use of activity areas for nesting purposes (Goggans et al. 1989). In addition, three-toed 

woodpeckers avoid harvested stands for roosting and foraging, which would require them to acquire 

these habitat components elsewhere within their home ranges - although the home range is not expected 

to increase in size. For black-backed woodpeckers, the Goggans study showed this species is more 

tolerant in using harvested stands for nesting with half of the nests located within stands disturbed by 

harvesting. However, she also found, similar to three-toed woodpeckers, black-backed woodpeckers 

preferred passively managed stands for foraging; and all roosting occurred in stands that have not been 

harvested. Telemetry data confirms black-backed woodpeckers avoid harvested stands for roosting and 

foraging, causing home range size to increase as the amount of passively managed areas and mature 

forest decrease. 

The Viable Ecosystem Model projected suitable habitat into the future. Table 3-54 displays projections 

of suitable nesting habitat by alternative over time. Acreage amounts increase over time as a result of 

expected increase in tree vigor from thinning and the probability of advancing to the next successional 

stages. All action alternatives show an increase in nesting habitat greater than the no-action alternative 

(A) over all listed decades, although the differences only amount to several hundred acres. 

Table 3-54. Viable Ecosystem Modeling Projections of Black-Backed and Three-Toed 

Woodpecker Nesting Habitat over Time 

Alternative Existing Nesting 

Acres 

10 Year 

Projection of 

Nesting Acres 

20 year 

Projection of 

Nesting Acres 

50 Year 

Projection of 

Nesting Acres 

A 57,107 60,568 63,774 70,520 

B 57,107 60,853 64,100 70,924 

C 57,107 60,843 64,083 70,897 

D 57,107 60,825 64,051 70,837 

Figure 3-22 shows black-backed and three-toed nesting habitat in BLT estimated at 57,107 acres or 71 

percent of the project area. Included in this amount are tracts greater than 1,000 acres in size consistent 

with Altman’s (2000) Landbird Conservation Strategy. 

Alternative B 

Direct and Indirect Effects 

The selection of this alternative would result in the thinning and post sale activities on 6,547 acres or 12 

percent of the total existing nesting habitat for both species. Eighty eight (88) percent nesting habitat 

would remain. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

155

Because snags would be retained except for reasons characterized as incidental, they would be available 

for nesting use by either species. The selection of this alternative would likely result in an increase of 

home range size for black-backed woodpeckers, although this is not likely to occur for individual threetoed woodpeckers. Because neither species uses harvested areas for foraging or roosting, this habitat 

use would be avoided on the 6,547 acres proposed for thinning. 

Because the black-backed woodpecker’s home range size would increase, it would result in fewer 

individuals the analysis area could support in the very short-term (less than 10 years). Table 3-54 

shows an increasing trend in suitable nesting acres beginning 10 years after project implementation. 

This would result in an increase in the number of pairs the analysis area could support. With an 

increase in the amount of nesting habitat projected, an associated risk of a disturbance event would be 

elevated. However, contrary to the risk expressed in Alternative A, it would be less wide-scale and 

endemic as stands approach biological capabilities. 

For three-toed woodpeckers, there would not be an expected change in home range size or a reduction 

in the number of individuals that could be supported in the analysis area. 

Alternative C 

Direct and Indirect Effects 

This alternative would result in thinning and post-sale activities on 4,989 acres, or 9 percent of the total 

existing nesting habitat for both species. Compared to Alternative B, it would retain 1,558 acres of 

additional nesting habitat. These areas are located along the Little Deschutes River, south of Odell 

Butte and east of Highway 58, and near Bunny Butte. 

The selection of this alternative would also likely result in an increase of home range size for blackbacked woodpeckers as described for Alternative B. This is not likely to occur for individual three-toed 

woodpeckers. Because neither species uses harvested areas for foraging or roosting, this habitat use 

would be avoided on the 4,989 acres proposed for thinning. 

Ninety one (91) percent of the existing nesting habitat would remain in a passively managed scenario, 

retaining mature stands where black-backed and three-toed woodpeckers prefer to nest. Similar to 

Alternative B, there would be an increasing trend in suitable nesting acres 10 years after project 

implementation (Table 3-54) and a correlated increase in the number of pairs the analysis area could 

support. As this habitat becomes available, the risk of loss from disturbance would also be 

characterized as endemic. 

For three-toed woodpeckers, there would not be an expected change in home range size or a reduction 

in the number of individuals that could be supported in the analysis area. 

Alternative D 

Direct and Indirect Effects 

This alternative would result in the thinning and post-sale activities on 2,247 acres, or 4 percent of the 

total existing nesting habitat for both species. An additional 4,300 acres or 2,742 acres of suitable 

nesting habitat would remain unmanaged as compared Alternatives B and C (respectively). Compared 

to the other action alternatives, unmanaged nesting habitat would be maintained along the Little 

Deschutes River, south of Odell Butte and east of Highway 58, near Bunny Butte, Two Rivers 

subdivision, upper Hemlock Creek, Spruce Creek, Rabbit Creek and Basin Creek, along the western 

analysis area boundary, and along the Little Odell Creek drainage. Although Alternative D actively 

manages less than 1/3 of the stands in Alternative B, it would result in similar effects where those 

activities take place. 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

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Similar to Alternatives B and C, this alternative would likely result in an increase of home range size 

for black-backed woodpeckers. Because neither species uses harvested areas for foraging or roosting, 

this habitat use would be avoided on the 2,247 acres proposed for active management. 

This alternative would retain approximately 96 percent of the existing nesting habitat across the 

analysis area, and it would be well distributed. It is likely to affect fewer individual black-backed and 

three-toed woodpecker home ranges as compared to Alternatives B and C, since there are several 

thousand fewer nesting acres being proposed for thinning. 

This alternative also shows an increasing trend in suitable nesting acres 10 years after project 

implementation (Table 3-54). This should result in an increasing number of pairs the analysis area 

could support. 

For three-toed woodpeckers, there would not be an expected change in home range size or a reduction 

in the number of individuals that could be supported in the analysis area. 

Cumulative Effects 

Table 3-1 was reviewed for activities that overlap the zone of influence in time and space and have 

potential to incrementally affect the three-toed and black-backed woodpeckers. The zone of influence 

is identified as the 80,000-acre Upper Little Deschutes Watershed because it is large enough to include 

several home ranges for both species. 

The potential for additive effects would be the Baja 58 timber sales conducted 2,878 acres of understory 

commercial thinning in areas that overlap with BLT, however, Viable Ecosystems modeling has 

accounted for all active management that has occurred prior to September 2004. Since that time, Baja 

West, Critter, and the Lower timber sales from Baja 58 EA and Finding of No Significant Impact have 

been completed (1,310 acres). It is assumed that the ongoing 800 acres of prescribed burning does not 

have additive effects for these species. For these reasons, the analysis of past actions other than those 

listed in this section is based on current environmental conditions. 

Vegetative prescriptions for the BLT project are very similar to those implemented in the Baja 58 

project and timber sales. It is assumed the majority of the 1,310 acres of activities within Baja 58 

overlap acres altered suitable black-backed and three-toed woodpecker nesting habitat, although this 

estimate is very conservative because the entire activity probably did not have the necessary stand 

characteristics on every acre prior to implementation. The reduction in canopy cover likely altered 

habitat and while black-backed woodpeckers may still use the stands for nesting, three-toed 

woodpeckers would not. As described in the direct and indirect effects for both species, the additional 

1,310 acres from the Baja 58 project likely resulted in harvested stands that would be avoided for 

foraging and roosting by both species. 

Using an estimated 1,310 acres of overlap from the Baja timber sales and subtracting from the 

September 2004 modeled suitable habitat of 57,107 acres, approximately 49,457 acres (87 percent) 

remains suitable habitat for both woodpecker species in Alternative B. This is followed by 51,015 

acres (90 percent) in Alternative C and 53, 757 (94 percent) in Alternative D. The totals do not include 

the 15 percent of each activity unit that is managed in a passive scenario. For both woodpecker species, 

the additional 1,310 acres of overlap does not change the effects disclosed under direct and indirect 

effects. For three-toed woodpeckers, there would not be an expected change in home range size or a 

reduction in the number of individuals that could be supported in the analysis area. Because blackbacked woodpecker’s home range size would increase, it would result in fewer individuals the analysis 

area could support in the very short-term (less than 10 years). 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

157

The bulk of the modeled habitat is on Federal lands. However, a small portion includes surrounding 

private lands (Figure 3-22). The lands have been managed for timber production. From 2000 through 

2003, extensive harvest occurred as ownership changed from Crown Pacific Limited to Interfor Pacific. 

Although these lands are currently managed for timber production, it is unknown how these lands 

would be managed in the future. 

There are no foreseeable actions that have potential to reduce suitable habitat either woodpecker. When 

past, present, and foreseeable actions are combined, the amount of suitable habitat nesting habitat 

present in the analysis area would not result in a long-term decreasing trend for either woodpecker 

species. The amount of additive actions with potential to alter habitat in the 5th field watershed, since 

September 2004, is relatively minor compared to the suitable habitat that remains. Therefore, the 

disclosure for direct and indirect effects for the two woodpecker species does not appreciably change. 

American Marten

Ecology 

The American marten is associated with mixed conifer and high elevation hemlock/lodgepole pine 

late-successional forests. Raphael and Jones (1997), in a study of lodgepole pine forests on the 

Winema National Forest, determined that marten denning sites averaged 30 percent canopy cover. 

They also concluded that martens tend to select rest sites with greater canopy cover (mean 36 

percent) when snow cover is present as compared to snow-free times (mean 27 percent canopy 

cover). Raphael and Jones (1997) found that martens use snags and logs with intermediate levels 

of decay, with greatest use in the larger (30 inches in diameter or larger) size classes when 

available. Especially significant, are riparian areas, ridge tops, and areas where high 

concentrations of down logs and snags occur (Ruggiero et al. 1994). Martens eat mostly forest 

rodent species (e.g. squirrels) or riparian rodent species (e.g. voles). Complex physical structure, 

especially near the ground, helps provide foraging/hunting areas and shelter from weather and 

predators (Buskirk and Powell 1994 as cited in Ruggiero et al. 1994). Raphael and Jones (1997) 

estimated male marten home ranges averaged 4,272 acres and female home ranges averaged 1,392 

acres. 

Existing Condition

The Viable Ecosystem model was used to map potential denning habitat in the analysis area 

(Figure 3-23). The definition used to define denning habitat was lodgepole pine forests with 

diameters 5-10 inches or greater with dense canopy equal to greater than 40 percent and white fir, 

Shasta fir, and mountain hemlock stands with diameters greater than 10-15 inches and a dense 

canopy equal to or greater than 55 percent. This resulted in an estimated 15,003 acres of 

potentially suitable denning habitat, or 19 percent of the total analysis area. It is likely the program 

underestimated acres of denning habitat, because marten will use denning sites with canopy cover 

levels down to 30 percent (Raphael and Jones 1997), but the Viable Ecosystems model only uses 

one canopy cover number per Plant Association Group. For lodgepole pine, 40 percent is the break 

between open or dense stands, for mixed conifer and hemlock the break is 55 percent, and for dry 

ponderosa pine the break between defining stands as open or dense is considered 25 percent. 

Denning habitat is scattered across the entire analysis area including private lands, but the greatest 

concentration of denning habitat is within the Mt. Thielsen Wilderness and Oregon Cascades 

Recreation Area mixed conifer stands at the southern end of the planning area. 

District observation records list over 40 reports of marten in the analysis area, mostly concentrated 

along the Little Deschutes River corridor and south of Highway 58. The Crescent District 

conducted carnivore surveys on selected areas from 1993-1996 and again in 1998, using bait 

stations and Trailmaster cameras. Numerous photographs of marten were recorded from these 

surveys. The Oregon Natural Heritage program lists the American marten in Oregon as S3S4 

vulnerable to apparently secure (NatureServe 2008). 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

158

Figure 3-23 displays Viable Ecosystems modeled habitat that meets live tree structure, species and 

density requirements for the marten. Snags meet criteria of greater than or equal to 10 inches in 

diameter and greater than 11.8 snags per acre for greater than a 30 percent tolerance interval. Down 

wood criteria consists of down wood greater than or equal to 5 inches in diameter and greater than 8.1 

percent cover to meet a greater than 50 percent tolerance interval. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

159

Figure 3-23. Potential American Marten Habitat Modeled by Viable Ecosystem Model 
BLT Project Environmental Impact Statement 

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Alternative A 

Direct and Indirect Effects 

This alternative would have no immediate direct effect on the American marten. In the short-term, it is 

assumed existing habitat would continue to be occupied by marten. Because this species tends to select 

forested stands that have a dense canopy, this characteristic also would indicate a greater susceptibility 

to beetle attacks and competition related mortality. Over time, there is a greater potential for some of 

these forested areas to lose their desired denning and resting character from reduced canopy cover. 

Conversely, younger-aged stands that have resulted from past management such as regeneration harvest 

or those that were thinned have the future capability to develop into suitable denning and resting 

habitat. 

Effects Common to All Action Alternatives 

The Viable Ecosystem Model estimated there are 15,003 acres of marten denning habitat in the project 

area. This is based on tree size classes and appropriate Plant Association Groups typically used for 

denning. Table 3-55 displays the range of tolerance intervals based on snag levels taken from DecAID. 

For snags 10 inches in diameter and greater, 56 percent of the Viable Ecosystems model defined habitat 

is less likely to support denning females (less than 30 percent tolerance interval) while 44 percent of the 

denning habitat is more likely to support denning females (30-80 percent and greater tolerance interval). 

For snags greater than 20 inches in diameter and greater 77 percent of the denning habitat does not have 

the snag densities per acre equal to the 30 percent tolerance interval while 23 percent of the denning 

habitat does have snag densities of 3.7 – 4.5 or greater per acre that equal the 30-80 percent and greater 

tolerance interval. This is likely the result of the dominance of lodgepole pine stands in the project area 

where achieving snag diameters equal to greater than 20 inches in diameter is very uncommon. 

All action alternatives propose a combination of commercial thinning harvest, non-commercial 

thinning and post-sale activities that may include grapple piling of slash, pile burning, 

underburning, and commercial and/or personal use firewood removal within stands currently 

defined as marten denning habitat. It is assumed that following completion of timber harvest and 

associated post-sale work, canopy cover would probably be below the levels described as denning 

habitat for this species. Within the lodgepole pine Plant Association Group, post-harvest canopy 

cover is estimated to be 20-25 percent and 30-35 percent in the mixed conifer and mountain 

hemlock Plant Association Group. Raphael and Jones (1997) study in lodgepole pine forests 

concluded that denning sites averaged 30 percent canopy cover. This level of canopy cover is not 

expected to be achieved post-harvest in lodgepole pine for approximately 2-3 decades, but may be 

reached within the mixed conifer PAG - although the Raphael et al. study did not include mixed 

conifer stands in Oregon. In the longer-term, reduction of competition would accelerate tree 

growth and allow multiple canopies to become fuller, providing structure that would benefit 

marten. 

Regardless of the Plant Association Group being affected, there would be a reduction in canopy cover, 

resulting in less physical structure near the ground that contributes to protection from avian predation. 

In addition, where firewood removal may occur (units 80, 270, 295, 435, 575, 690, 940, 1190, 1200, 

1205, 1235, and 1300) and that overlaps with marten denning habitat, there would be changes in the 

amount and likely distribution of down wood. This would reduce cover habitat for marten prey species 

such as squirrels, chipmunks, and voles and a corresponding decrease in prey densities. It would also 

reduce the likelihood these stands would be used as a denning or resting site. Bull and Blumton (1999) 

conducted a study in the Blue Mountains of Oregon of fuels reduction on marten and their prey within 

lodgepole pine and mixed conifer stands. With the prescriptions that were applied for harvest and 

retention of live trees, standing dead, and down wood removal, they concluded it resulted in a reduction 

in densities of red-backed voles and snowshoe hares. It also increased chipmunk populations, although 

chipmunks hibernate in winter and represented less than 3 percent of marten diets in this study area. 

Bull and Blumton also determined there was no change in squirrel numbers in mixed conifer harvest 
Environmental Impact Statement BLT Project 

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161

where one-acre islands are retained in a passive management scenario. This indicates these types of 

activities continue to provide suitable habitat. They also placed radio collars on martens in the area. 

The martens avoided all stands with less than 50 percent canopy, contrary to the Raphael and Jones 

study on an adjoining forest that determined marten will use denning sites with canopy cover levels 

down to 30 percent. Bull and Blumton also found that the radio-collared marten did not use any stands 

that had been harvested with the following caveat: “The harvested stands, however, comprised such a 

small proportion of the marten’s home range that this behavior could not be construed as an avoidance 

of harvested stands.” Bull and Blumton recommend extrapolating the data beyond this study area 

because of the numbers of animals captured was low and the sampling period was short. To partially 

lessen the effect of thinning live trees and removal of down wood (firewood) in harvest areas, down 

wood would be retained to the levels described in the Project Design Features specified in Chapter 2. 

In addition, snags would be retained except where felled for occupational safety, log landings and 

where temporary roads would be located. These measures, in addition to the 15 percent of each harvest 

unit retained in a passive management scenario, would continue to provide a prey base for martens 

within units of activity. 
BLT Project Environmental Impact Statement 

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Table 3-55. American Marten Tolerance Intervals and Snag Use 

American Marten 

15,003 Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 

30% 30-50% 50-80% 80%+

Density (#/hectare)* 0-29.1 29.1-31.6 31.6-35.6 35.6 0-9.1 9.1-9.9 9.9-11.1 11.1+

Density (#/acre)* 0-11.8 11.8-12.8 12.8-14.4 14.4+ 0-3.7 3.7-4.1 4.1-4.5 4.5+

% of Habitat 55.8% 8.0% 7.3% 28.9% 77.2% 0.0% 1.9% 20.9%

Acres 8,370 1,193 1,097 4,342 11,585 2 281 3,134

Density of Snags = 10" dbh

 by tolerance interval

Density of Snags = 20" dbh 

by tolerance interval

* From DecAID Tables EMC_S/L sp-22, LP_S.sp-22 and MMC_S/L sp-22 Sythesized data from various studies.

Table 3-56 displays the range of tolerance intervals based on down wood densities taken from DecAID. 

Three hundred twelve (312) to 334 acres of fuels activities outside of harvest units (less than 8 inches in 

diameter and 18 foot spacing) would also contribute to a reduction in habitat suitability for marten by 

reducing canopy cover and physical structure near the ground levels. For down wood greater than 5 

inches in diameter, 93 percent of the denning habitat is less likely to support denning females (greater 

than 50 percent tolerance interval) while 7 percent of the habitat is more likely to support denning 

females because of increased levels of down wood cover. 

Table 3-56. American Marten Tolerance Intervals and Down Wood Use 

American Marten

 15,003 Acres

Tolerance Interval below 50% above 50%

% Down wood Cover* 0-8.1 8.1+

% of Habitat 93% 7%

Acres 13,953 1,050

Distribution of down wood 

 >= 5" (12cm) 

* Developed from DecAid 2.0 Table MMC_S.sp-24. 

Information is synthesized data from various studies

Planned temporary roads (9.7 miles Alt B., 8.7 miles Alt. C, and 4.7 miles Alt. D) to provide access to 

harvest units would potentially facilitate an increase in marten trapping into the analysis area. These 

roads, in addition to the currently closed Maintenance Level 1 roads opened for unit access may result 

in some higher level of marten mortality from trapping. 

Outyear modeling showed that all three action alternatives would result in an increase of suitable 

denning habitat over each decade modeled (10 years, 20 years, and 50 years) as compared to the noaction alternative. At the 50 year time frame, Alternative A showed 39,580 acres of denning habitat, 

Alternative B showed 44,143 acres, Alternative C showed 42,757 acres, and Alternative D showed 

40,891 acres. These future acreages of denning habitat were based on the BLT unit prescriptions, 

expected increase in tree vigor from thinning, and the probability of advancing to the next successional 

stages. 

 

Alternative B 

Direct and Indirect Effects 

This alternative would result in thinning and post-sale activities, including slash disposal and/or 

firewood removal on a total 811 acres, or 5 percent of the total acres currently defined as suitable 

denning habitat. It is assumed the reduction in canopy cover would render these acres as unsuitable 

for denning purposes, particularly in the lodgepole pine Plant Association Group, where canopy 

cover is expected to drop into the 20-25 percent canopy range post-harvest, and where firewood 
Environmental Impact Statement BLT Project 

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163

removal would be allowed. This condition may last several decades or more until canopy cover 

increases and existing snags fall, increasing the amount of coarse woody debris. 

This alternative would allow construction of 9.7 miles of temporary road and re-open 22 miles of 

currently un-maintained (closed) Maintenance Level 1 roads needed to facilitate efficient harvest. 

This would allow a temporary increase in area available for trappers to pursue furbearers, including 

marten during the regulated fall and winter trapping season. 

Based on the habitat definition used, 95 percent of the currently defined denning habitat in the 

analysis area would remain unmanaged and available for utilization by marten. 

Alternative C 

Direct and Indirect Effects 

This alternative would result in similar activities prescribed in Alternative B on 581 acres or 4 

percent of the total acres currently defined as suitable denning habitat. Alternative C would 

conduct vegetation manipulation on 230 fewer acres of marten denning habitat as compared to 

Alternative B. The additional passively-managed acres would be retained in the Little Odell Creek 

drainage and the Little Deschutes River corridor south of Highway 58. 

This alternative would construct 8.7 miles of temporary road and re-open 17 miles of currently unmaintained (closed) roads needed to access harvest units. This would allow a temporary increase 

in area available for trappers to pursue furbearers including marten during the regulated fall and 

winter trapping season, although reduced access by Maintenance Level 1 roads is needed (5 miles 

less) and temporary roads (1.7 miles) compared to Alternative B. 

Alternative D 

Direct and Indirect Effects 

This alternative would result in similar activities prescribed in Alternatives B and C on a total 251 

acres, or 2 percent of the total acres currently defined as suitable denning habitat. Alternative D 

would conduct vegetation manipulation on 560 fewer acres of marten denning habitat as compared 

Alternative B, and 330 fewer acres as compared to Alternative C. 

This alternative would need the least access of all action alternatives, with 4.8 miles of temporary 

road construction and re-open only 11 miles of currently un-maintained (closed) roads needed to 

access harvest units. As disclosed for Alternatives B and C, this would increase temporary access 

into the area for trappers to pursue marten and other furbearers, but the potential would be 

considerably reduced. 

Cumulative Effects 

Table 3-1 was reviewed for projects that have the capability to overlap in time and space within the 

same zone of influence. The zone of influence was defined as the 80,000 acre BLT project area (5th

field watershed) because it is large enough to encompass multiple female marten home ranges based on 

home range data from Raphael and Jones (1997). 

The potential for additive effects would be the Baja 58 timber sales that conducted 2,878 acres of 

understory commercial thinning in areas that overlap with BLT, however, Viable Modeling has 

accounted for all active management that has occurred prior to September 2004. Since that time the 

Baja West, Critter, and Lower timber sales from Baja 58 EA have been completed, totaling 1,310 acres 

although it is unlikely all of these acres were defined as marten denning habitat. It is assumed that the 

ongoing 800 acres of prescribed burning would not be considered marten denning habitat because the 

burning would occur in unsuitable habitats (Ponderosa Pine Plant Association Group). Therefore, no 
BLT Project Environmental Impact Statement 

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additive effects would result from prescribed underburning. For these reasons, the analysis of past 

actions other than those listed in this section is based on current environmental conditions. 

In spite of the habitat modifications proposed for the BLT project and the recently completed Baja 58 

sales, no short- or long-term marten population decrease is would occur. This determination is based 

on the temporary effects from reduction of canopy cover, the retention of snags and down wood 

(Project Design Features and Mitigation Measures, Chapter 2), and the 15 percent of each harvest unit 

retained in a passive management scenario which potentially provides suitable denning habitat. In 

addition, district records show over 40 observations of marten in this project area, which indicates the 

species is relatively common. 

Even if it is assumed the entire 1,310 acres from the Baja 58 sales were suitable denning habitat, when 

combined with the 251 acres to 811 acres potentially affected from the BLT project, 86-90 percent of 

the suitable denning habitat in the project area would remain available for the species. 

While temporary roads would be required to implement BLT, these roads would be closed to vehicular 

traffic after the completion of all timber sale and post-sale activities (estimated 2-3 years) and allowed 

to re-vegetate with native species. In addition, the Travel Management Rule (a foreseeable action) 

would prohibit off road travel and restrict users to designated routes only, perhaps as early as 2009. 

This would reduce the amount of open roads available for motorized travel across central Oregon 

National Forests. This would also likely reduce the numbers of marten taken during the furbearer 

season. Data on the numbers of animals annually taken is not available. 

The Viable Model did not show any suitable denning habitat on private lands (housing subdivisions and 

industrial forestlands) in the analysis area. The amount of timber harvest that has occurred over the last 

5-6 years has likely resulted in animals on private lands shifting their home ranges onto National Forest 

system lands of the analysis area. It is uncertain how private lands would be managed in the future and 

no assurance marten would find suitable denning habitat on these lands. 

Based on the existing knowledge of species, habitat conditions available, and the factors disclosed in 

this section, project implementation would not lead to a reduction in marten populations across the 

analysis area. 

Woodpecker Guild

Effects to the white-headed and Lewis’ woodpeckers have been disclosed in the Threatened, 

Endangered, and Sensitive section of Chapter 3. Effects to the red-naped sapsucker have been 

disclosed in the Birds of Conservation Concern section also in Chapter 3. Effects to the three-toed, 

black-backed, pileated, hairy, and downy woodpeckers and the Williamson sapsucker, and the common 

flicker are discussed here. 

Ecology 

The hairy and downy woodpeckers, the common flicker and the Williamson sapsucker are described as 

a common inhabitant of Oregon and the pileated woodpecker is an uncommon species in Oregon 

limited attitudinally by habitat availability (Marshall et al. 2003). This guild of species is dependent 

upon snags and/or live trees with internal rot for nesting or roosting cavities and as a forage substrate. 

However, there are differences in their selection of preferred habitats. The common flicker is generally 

most abundant in open forests and forest edges. The Williamson sapsucker prefers mid- to high 

elevation mature or old-structured forests with fairly open canopy cover. The downy woodpecker 

prefers riparian areas with hardwoods. The hairy utilizes mixed-conifer forests and ponderosa pine as 

well as adjacent deciduous stands, while the pileated occurs primarily in dense mixed conifer forests in 

late seral stages or in deciduous trees stands in valley bottoms (Marshall et al. 2003). Population trends 

in Oregon have been reported as stable (Williamson sapsuckers) or a non-significant decline ranging 
Environmental Impact Statement BLT Project 

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165

from 0.4-0.6 percent per year based on Breeding Bird Surveys 1966-2000 as reported by Marshall et al. 

(2003) for the remaining species. 

Existing Condition 

The Viable Ecosystem model was used to map potential nesting habitat in the analysis area. For the 

common flicker, lodgepole pine, ponderosa pine, and white fir stands with trees greater than 10-15 

inches in diameter in an open canopy condition was used to determine estimated 19, 276 nesting 

habitat. For the pileated woodpecker, ponderosa pine stands with white, white fir, mountain hemlock, 

and Shasta red fir with greater than 15-20 inch in diameter trees and a dense canopy condition was used 

to define potential 4,076 acres of nesting habitat. For the Williamson sapsucker, the nesting habitat 

definition was ponderosa pine and white fir stands where the ponderosa pine present was greater than 

15-20 inches in diameter in an open canopy condition (2,243 acres). Individual modeling for the hairy 

and downy woodpeckers was not conducted, although the hairy is a habitat generalist and the acres 

modeled for the flicker could be considered similar to that for the hairy. Riparian habitat was not 

modeled for the downy woodpecker. There have not been specific surveys conducted for any of these 

species, although district observational records show one Williamson sapsucker sighting west of 

Crescent, Oregon and south of the Little Deschutes River. One pileated woodpecker sighting has also 

been documented in the same area. The remaining species are assumed to occur within the analysis 

area. 

Alternative A 

Direct and Indirect Effects 

This alternative would have no immediate effect on any of the species in this woodpecker guild. It is 

assumed, that in the short-term, endemic levels of insects and density related mortality to existing 

stands would continue to provide snag habitat for all species in this guild. Over time, increased canopy 

layering and tree density would subject these stands to increased levels of risk of loss due to fire, insect, 

and disease. This could result in a temporary increase in high density snag conditions favorable to 

these species. 

Effects Common to All Action Alternatives 

The Viable Ecosystem Model estimated there are 4,076 acres of nesting habitat for the pileated 

woodpecker based on suitable PAGs and tree diameters typically selected for nesting. Table 3-57 

displays the range of tolerance interval based on snag levels taken from DecAID. Essentially, a 

tolerance level below 30 percent (0-14.9 snags per acre greater than 10 inches in diameter) is 

habitat that is less suitable than acres with higher snag densities. Fifty-one percent (2,091 acres) of 

the current suitable acres according to Viable have less than 14.9 snags per acre greater than 10 

inches in diameter. There are also 1,985 acres (49 percent) with snag densities exceeding 14.9 

snags per acre which equals to the 30-80 percent or greater tolerance intervals. 

For snags greater than 20 in diameter, 59 percent (2,413 acres) of the defined Viable nesting acres 

have less than 3.5 snags per acre greater than 20 inches in diameter, though 41 percent (1,663 

acres) of the nesting acres have snag densities greater than 3.5 snags per acre, which equates to a 

tolerance interval of 30-80 percent or greater. 
BLT Project Environmental Impact Statement 

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Table 3-57. Pileated Woodpecker Tolerance Intervals and Snag Use 

Pileated 

Woodpecker 4,076 

Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 

30% 30-50% 50-80% 80%+

Density 

(#/hectare)* 0-36.8 36.8-74.3 74.3-121.8 121.8+ 0-8.6 8.6-19.3 19.3-45.4 45.4+

Density (#/acre)* 0-14.9 14.9-30.1 30.1-49.3 49.3+ 0-3.5 3.5-7.8 7.8-18.4 18.4

% of Habitat 51.3% 30.6% 10.8% 7.3% 59.2% 19.2% 5.6% 15.9%

Acres 2,091 1,248 441 296 2,413 784 230 649

Density of Snags = 10" dbh

 by tolerance interval

Density of Snags = 20" dbh 

by tolerance interval

*From DecAID 2.0 Tables EMC_S/L.sp-22 and PPDF_S/L.sp-22 Information synthesized from various studies. 

Species utilizing high snag densities are generally utilizing clumps of snags.

Table 3-58 (down wood) displays the range of tolerance intervals based on down wood densities 

taken from DecAID. For down wood greater than 5 inches in diameter, 56 percent (2,282 acres) of 

the suitable acres of pileated habitat has less than 4 percent down wood cover while 44 percent 

(1,794 acres) has 4-5.1 percent or greater down wood cover, which equates to 30-80 percent or 

greater tolerance interval. A total of 1,508 acres (37 percent) of the pileated habitat has a high 

level of down wood, meeting or exceeding the 80 percent tolerance interval. 

 

Table 3-58. Pileated Woodpecker Tolerance Intervals and Down Wood Use 

Pileated Woodpecker 

4,076 Acres

Tolerance Interval* below 30% 30-50% 50-80% 80%+

% Down wood Cover* <4 4-4.5 4.5-5 5.1+

% of Habitat 56% 5% 2% 37%

Acres 2,282 204 82 1,508

Distribution of down wood >= 5" (12cm) 

* Developed from DecAid 2.0 Tables EMC_S.sp-24 and EMC_L.sp-24 Information is 

synthesized data from various studies

The Viable Ecosystem Model estimated there are 2,243 acres of nesting habitat for the Williamson 

sapsucker based on suitable PAGs and tree diameters typically selected for nesting. Table 3-59 

displays the range of tolerance intervals based on snag levels taken from DecAID. Essentially, a 

tolerance level below 30 percent (0-14 snags per acre greater than 10 inches in diameter) is less 

suitable for Williamson sapsuckers than acres with higher snag densities. Currently 89 percent 

(1,987 acres) of the Viable Ecosystem-defined nesting acres have less than 14 snags per acre 

greater than 10 inches in diameter. There are also 242 acres (13 percent) of suitable nesting acres 

with greater than 14 snags per acre which equates to 30-80 percent or greater tolerance interval. 

For snags greater than 20 inches in diameter, 95 percent (2,129 acres) of the defined Viable 

Ecosystem nesting acres have less than 3.3 snags per acre greater than 20 inches in diameter and 5 

percent (115 acres) of the nesting acres have snag densities greater than 3.3 snags per acre which 

equates to a tolerance interval of 30-80 percent or greater. 
Environmental Impact Statement BLT Project 

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Table 3-59. Williamson Sapsucker Tolerance Intervals and Snag Use. 

Williamson 

Sapsucker 2,243 

Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 30% 30-50% 50-80% 80%+

Density 

(#/hectare)* 0-34.6 34.6-70.1 70.1-122.8 122.8+ 0-8.2 8.2-21.2 21.2-41 41+

Density (#/acre)* 0-14 14-28.4 28.4-49.7 49.7+ 0-3.3 3.3-8.6 8.6-16.6 16.6+

% of Habitat 88.6% 9.9% 0.9% 0.6% 94.9% 4.4% 0.5% 0.2%

Acres 1,987 221 20 14 2,129 99 12 4

Density of Snags = 10" dbh

 by tolerance interval

Density of Snags = 20" dbh 

by tolerance interval

*From DecAID 2.0 Tables EMC_S/L.sp-22 and PPDF_S/L.sp-22 Information synthesized from various studies. 

Species utilizing high snag densities are generally utilizing clumps of snags.

All three action alternatives propose a combination of commercial thinning followed by post-sale 

actions that may include small tree thinning, slash treatments, underburning in ponderosa pine stands, 

and activities related to “fuels only” prescriptions that would remove live trees less than 8 inches 

diameter to approximate 18-foot spacing. In addition, there is personal and/or commercial firewood 

removal proposed in a limited number of harvest units. While the total acres of treatments vary 

between alternatives the effects would be similar. 

The felling of snags would not occur except those that must be removed under limited circumstances 

such as clearing for temporary road construction (9.7 miles Alternative B, 8.7 miles Alternative C, and 

4.7 miles Alternative D) , where the placement of log landings would occur and for occupational safety 

(Project Design Features, Chapter 2). Prescribed underburning would include “burn plans” which 

include methods to protect snags and down logs, such as building handline to exclude fire. Districtwide post-burn monitoring has determined these measures are generally effective in preventing the 

snags and down logs from charring. On occasion, new snags are created from underburning operations 

in areas where snag densities are low. This is determined on each and every activity unit before 

prescribed burning prescriptions are written in a site-specific way during the Crescent District post-dale 

monitoring review. 

Commercial thinning of live trees would likely affect future snag recruitment that likely would have 

succumbed to competition from stress-related mortality (e.g. competition for scarce site resources). 

However, the increased tree growth of residual trees as a result of thinning would facilitate/accelerate 

attainment of large diameter trees, of which would be available as larger diameter snags in the future. 

High density snag patches and concentrations of down wood would be available in the 15 percent 

unmanaged retention areas of each harvest activity unit and within the OCRA and Mt. Thielsen 

Wilderness. In addition, because of limited activity in riparian buffers, dense concentrations of 

standing dead and down wood would remain intact, providing habitat for all dependent species, 

including the downy woodpecker - which is closely associated with riparian areas. 

Pileated woodpecker effects: The Viable Ecosystem program determined 4,076 acres of suitable 

pileated woodpecker habitat in the analysis area. All three action alternatives propose a relative small 

amount of overlap with harvest activities. One hundred fifteen (115) acres (3 percent) would occur in 

Alternative B, 104 acres or 3 percent in Alternative C, and 31 acres or 1 percent in Alternative D. The 

majority of the suitable habitat is within the OCRA and Mt. Thielsen Wilderness areas. Planned 

activities would likely reduce canopy cover to the 30-35 percent range post-harvest and not have the 

dense conditions preferred by this species. However, the tree species that have potential to achieve the 

largest diameters (ponderosa pine and Douglas-fir) would be favored tree species for retention as they 

are more fire tolerant. This would benefit the species within several decades as canopy cover returns, 

returning stands to nesting and foraging habitat. Modeling for all action alternatives showed an 

increase in tree growth and vigor over projected 10-year, 20-year, and 50-year modeled timeframes, 
BLT Project Environmental Impact Statement 

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168

contributing to improved habitat with larger diameter snags and down logs available than under a 

passive management scenario. Viable Ecosystem modeling determines an increase in pileated 

woodpecker habitat in all alternatives. Alternative A increased from an existing 4,076 acres to 21,967 

acres in 50 years. Alternative B increased to 22,863 acres, Alternative C (22,813 acres), and 

Alternative D (22,318 acres). While project activities may result in some short-term disturbance during 

implementation (several, up to 5 years) that may result in some pairs being temporarily relocated, the 

long-term (50 years) habitat trend would indicate an increase in suitable habitat that could support a 

population increase. 

Williamson sapsucker and common flicker effects: Because each species is more closely associated 

with open canopied forests, proposed activities such as commercial thinning and underburning would 

promote more favorable overall habitat conditions. All three action alternatives propose limited 

amounts of overlapping commercial thinning and post-sale activities in Viable Ecosystem-defined 

nesting habitats. Alternative B would overlap 202 acres (9 percent) of nesting habitat for the 

Williamson sapsucker and 1,947 acres or 10 percent of the common flicker. This is followed by 

Alternative C, 188 acres (8 percent) and 1,550 acres (8 percent) and Alternative D, 51 acres (2 percent) 

and 743 acres (4 percent), respectively. All existing snags would remain except for temporary road 

construction, log landings, and occupational safety. 

The Viable model also predicted an increasing trend in suitable habitat acres over each decade modeled. 

For the Williamson sapsucker, modeling determined an increase in the amount of nesting acreage for 

each alternative greater than the no-action alternative. Because Alternative B proposes the greatest 

number of acres of commercial thinning, this alternative also showed the greatest suitable nesting acres 

over each decade, which was generally a 300-400 acre increase above the other alternatives. For the 

common flicker, all alternatives, including Alternative A, were virtually identical to each other. Over 

each decade, an increase of 3,500 acres of additional nesting habitat was common 50 years out. Based 

on the habitat modeling, there would be habitat to support an increase in population for the flicker and 

William sapsucker, regardless of the alternative selected for implementation. 

Altman (2000) in the Landbird Conservation Strategies for the East-Slope Cascades recommended the 

retention of at least 1 snag/acre at least 12 inches dbh in mixed-conifer stands or at least 18 inches dbh 

in ponderosa pine stands for Williamson sapsuckers. The PDCs and mitigation measures in Chapter 2 

prescribe even higher levels. The BLT project is consistent with Altman’s recommendations. 

Hairy woodpecker and downy woodpecker effects: Viable Ecosystem modeling was not conducted 

for the hairy or downy woodpeckers. There would no adverse effects to the downy woodpecker 

because of their close association with riparian habitats and there is only one activity planned within the 

riparian zone. Unit 1061 is small scale, and the objective is to restore riparian function and improve 

vigor of riparian-associated vegetation. For the hairy woodpecker which utilizes mixed conifer, 

deciduous, and ponderosa pine forests there would be no short- or long-term effects to the species with 

the exception of the temporary disturbance to nesting pairs that may occur during the breeding season 

from harvest operations and prescribed underburning. This disturbance is considered small scale 

compared to nesting habitat available in the entire 80,000 watershed and the intensity is also considered 

low because not all activities would occur at the same time and it would last from 1-5 years in duration. 

Retention of snags and down logs is specified in the Project Design Features in Chapter 2. 

Marshall et al. (2003) reported findings on population trends for the hairy woodpecker, common flicker, 

pileated woodpecker, and the downy woodpecker. They have experienced non-significant declines 

over the last several decades based on Breeding Bird Surveys. Marshall et al. also reported that the 

Williamson sapsucker population was stable as reported in most of the studies they reviewed. BLT 

implementation should not result in any short- or long-term decline in populations to any of these 

species. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

169

Cumulative Effects 

The projects in Table 3-1 were reviewed for actions that have a similar zone of influence and overlap in 

time and space as the BLT project. The zone of influence for this group of woodpeckers is defined as 

the BLT analysis area, which encompasses the 80,000 acre 5th field watershed, which is large enough to 

provide multiple pair home ranges for each of the woodpecker species. 

Viable Ecosystem modeling has accounted for all active management that has occurred in the BLT 

areas (Upper Little Deschutes River watershed) up to September 2004. Since that time, Baja West, 

Critter, and the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No 

Significant Impact have been completed (totaling 1,310 acres). These sales are characterized as 

understory thinning in mixed conifer habitats with the retention of the largest diameter trees, although it 

is assumed not all of the acres thinned provided suitable nesting habitat for each of the five species, 

particularly for the pileated woodpecker. It is assumed most of the habitat available is on Federal lands. 

The remaining projects from Table 3-1 listed as “completed” no longer have any effects that are 

quantifiable. The Maintenance Burn CE, Prescribed Underburning and Mowing Project CE and the 

Rosedell CE all overlap in time and space with the BLT project and could occur within habitats used by 

the hairy and downy woodpeckers, Williamson sapsuckers, common flickers and the pileated 

woodpecker. The approximate 800 acres of prescribed underburning within ponderosa pine dominated 

stands would be consistent with long-term objectives for managing this habitat to reduce stem densities 

and fuel loadings with a return to more single-story late and old structure conditions. There would be 

no identified additive effects associated with past, present and reasonably foreseeable projects for this 

guild of woodpecker species. 

Osprey

Ecology 

Ospreys are good biological indicators of ecosystem health, because they are long-lived and are the top 

predator of aquatic food webs (USGS 2005). Various fish species comprise 99 percent of their diet. 

Ospreys dramatically declined in abundance through the mid-1970s, as a side effect of pesticide use, 

but have since recovered and become a common nesting species along the Columbia and Willamette 

waterways in western Oregon (USGS 2005). They nest within two miles of fish bearing bodies of 

water and generally nest in larger broken top live trees or snags, but also utilize utility poles, man-made 

Canada goose nest boxes, channel markers and other man made structures where natural structures are 

lacking (Marshall et al. 2003). The primary habitat requirements of osprey include a dependable source 

of fish that can be captured near the surface and an elevated nesting platform within a few kilometers of 

their food supply. Ospreys are migratory, typically arriving on the Crescent Ranger District in April 

and May and stay into early autumn until fall migration. While the pair will mate for life, they migrate 

separately and re-unite at their nest site the following spring. The birds winter in central California 

south into Central and South America. They are currently ranked as S4, apparently secure 

(NatureServe 2008). 

Existing Condition 

There are at least 40 known osprey nests on the Crescent Ranger District, although none are located in 

the BLT analysis area. The greatest concentration of nests are found west and north of Davis Lake, but 

there are also several nests along the shoreline of Odell Lake - all of which are outside the BLT 

planning area. District records list one osprey observation on private lands along the Little Deschutes 

River at the north end of the planning area. The lack of nest data is likely indicative of an inadequate 

food base to support a nesting pair and young in the analysis area. While small brook and brown trout 

are present in the Little Deschutes River, there may not be enough fish or fishable water to sustain a 

pair as compared to a large lake or reservoir system. 

Effects Common to All Alternatives 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

170

There is no indication that nesting ospreys are present in the 80,000-acre analysis area, and only one 

recorded observation of an individual bird. The selection of any action alternative is unlikely to have 

any adverse effect on ospreys and direct, indirect, or cumulative effects are not expected to occur. If a 

nesting pair became known during sale activities or post-sale work, Project Design Features have been 

provided in Chapter 2 to restrict the activity if determined to be disturbing to the pair. 

Great Blue Heron 

Ecology 

The great blue heron is one of the most wide-spread waterbirds in Oregon (Marshall et al. 2003). 

Oregon State Heritage Program rates the great blue heron as S4, apparently secure (NatureServe 2008). 

It is highly adaptable and is found along estuaries, streams, marshes and lakes throughout the state. 

Nest locations are in the proximity of available food. They nest in colonies in shrubs, trees and river 

channel markers where there is little disturbance (Marshall et al. 2003). Tree species they would utilize 

in the analysis area include ponderosa pine and Douglas-fir. While the average preferred diameter of 

nest trees is 4.5 feet, they use a wide range of sizes from 1.5 to 6 feet in diameter (Marshall 2003). 

They hunt shallow waters of lakes and streams, wet or dry meadows feeding on fish, amphibians, 

aquatic invertebrates, reptiles, mammals and birds. Foraging habitat on the Crescent Ranger District 

includes the shallow water of Davis Lake, Odell Creek, Ranger Creek and their associated marshes and 

riparian habitat, which are outside the BLT analysis area. 

Existing Conditions 

District records show two observations of great blue herons in the northernmost portion of the planning 

area, although neither was on National Forest system lands. There are no known rookeries in the BLT 

analysis area. 

Effects Common to All Alternatives 

There are no activities planned within riparian reserves that would have the capability to affect wetland 

habitat which provides foraging habitat for the great blue heron. Fuels unit #1061 is adjacent to 

Hemlock Creek where the cutting of lodgepole pine trees less than 3 inches would occur and some spot 

burning of decadent willows. Because there are no documented observations of great blue herons along 

the riparian systems in the analysis area, there are no anticipated direct, indirect, or cumulative effects 

to the species. During project implementation, if a heron rookery is discovered, an evaluation would 

occur to determine if activities have the potential for nesting disturbance and a limited operating period 

attached as needed (Project Design Feature, Chapter 2). 

Great Gray Owl

Ecology 

This species is associated with mature stands of mixed conifer/lodgepole pine/mountain hemlock near 

meadow complexes. Great gray owls do not build their own nests, but rely on other raptor nests, 

mistletoe platforms, broken topped snags or artificial nest platforms. Bull and Henjum (1990) found 

that great gray owls tended to nest in unlogged, mature or older stands with a fairly open understory and 

dense overstory (60 percent or greater). In a study that included portions of the Deschutes National 

Forest south of LaPine, Oregon, Bryan and Forsman 1987 determined canopy cover at 11 nest sites 

ranged from 15-70 percent with a mean of 46.5 percent. Great gray owls have been documented using 

alternative nest sites and may nest more than 0.5 mile from the previous years nest (Bull and Henjum 

1990). Bryan and Forsman suggested that forest/meadow associations are a preferred habitat. In fact, 

their research located 63 sites with great gray owls, of which 60 sites were in forests less than 0.3 km 

from meadows and three were in forest areas 0.30-0.8 km from the nearest meadow. Fifty-nine sites 

were dominated by lodgepole pine or mixtures of lodgepole pine and ponderosa pine. Four sites were 

in mixed coniferous forests. Bryan and Forsman stated all sites where great gray owls were located 

were in old-growth (45 sites) or mature (15 sites) habitat characterized by large overstory trees. They 

defined old-growth lodgepole pine as any stand greater than 70 years of age and old-growth ponderosa 
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pine or mixed coniferous forests as any stand over 200 years of age. Elevations at occupied sites 

ranged from 1270 to 1650 meters, although great gray owls have been documented to occur at 

elevations up to 1890 meters in eastern Oregon. 

Home ranges for breeding adults in northeastern Oregon averaged 1,112 acres and ranged from 324 

acres to 1,606 acres, although they have been observed foraging up to 2 miles from the nest (Bull and 

Henjum 1990). Foraging habitat is typically defined as natural meadows greater than 10 acres in size, 

riparian areas, clear-cut and selectively logged areas where they forage on voles, pocket gophers, 

shrews, chipmunks, squirrels, and snowshoe hares. 

Existing Condition 

From a global perspective, great grey owl populations are stable (NatureServe, 2008). The Interior 

Columbia basin Ecosystem Management Project found populations to be widely distributed, although at 

low levels. Suitable habitat has been shown to be increasing and more than 50 percent of it is within 

the southern Cascades (Wisdom et al. 2000) – including the BLT analysis area. Since 1995, survey 

protocols have shown available nesting habitat to be found in wider bands of elevation as more nests 

are found region-wide. 

The Viable Ecosystem model was used to map potential nesting habitat in the analysis area. Lodgepole 

pine, ponderosa pine, white fir, and Shasta red fir Plant Association Groups with tree diameters 

exceeding 15-20 inches diameter with an open or dense canopy were used to define habitat. There are 

an estimated 4,500 acres of potential nesting habitat, with the habitat generally distributed near riparian 

systems, primarily on National Forest system lands. The Little Deschutes River corridors and the wet 

meadow complex of Spruce/Hemlock Creeks west of the Two Rivers housing subdivision are probably 

the most suitable areas because of the presence of adjacent meadows and forest openings. Great gray 

owl surveys were conducted in the BLT analysis area in 2007 with three visits completed. A single 

great gray owl was confirmed on two occasions (one audio and one visual) in nearly the same location 

along the Little Deschutes River at the northern end of the planning area. Follow-up visits were 

conducted but no additional detections were confirmed. Pair occupancy and nesting status for this 

individual was unknown. Additional great gray owl surveys were completed in the spring of 2008 for 

the same routes used in 2007. None were detected. As of April 2008, there is only one known great 

gray owl nest site on the Crescent Ranger District located near Refrigerator Creek, outside the BLT 

analysis area. 

Alternative A 

Direct and Indirect Effects 

This alternative would result in no immediate change in habitat conditions for great gray owls that may 

be using the planning area. Nesting habitat in the planning area would be maintained in late and old 

structure stands with broken topped trees and/or where other raptors have created stick built nests 

suitable for great gray owl nesting use. 

This alternative would be at the greatest risk to a disturbance process that could remove the largest trees 

and suitable nesting habitat. 

Alternatives B and C 

Direct and Indirect Effects 

The following Table 3-60 displays the amount of potentially suitable great gray owl nesting habitat 

present in the BLT analysis area.
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

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Table 3-60. Acres of Potential Great Gray Owl Nesting Habitat Affected By the BLT Project 

Alternative 

Existing 

Nesting 

Acres 

Acres of Commercial 

Thinning and Fuels 

Treatments Within 

Potential Nesting 

Habitat 

Nesting Acres 

Remaining 

A 4,500 0 4,500 (100%) 

B 4,500 507 (11%) 3,993 (89%) 

C 4,500 447 (10%) 4,053 (90%) 

D 4,500 144 (3%) 4,356 (97%) 

The selection of Alternatives B or C would result in nearly the same affects to nesting habitat for the 

great gray owl. Alternative B would conduct commercial thinning and fuels only treatment on 507 

acres (11 percent) of the estimated great gray owl nesting habitat in the analysis area, while Alternative 

C would implement a total of 447 or 10 percent of the total available nesting acreage. The habitat 

affected is located along the Little Deschutes River south of the Crescent cut-off road, south of Odell 

Butte, east of Bunny Butte, along the western planning area boundary, on Little Odell Butte, and 

Hemlock Butte in the upper Basin Creek drainage. 

Thinning and fuels reduction activities would focus on the retention of the largest and most dominant 

live trees on the landscape. Only in circumstances categorized as “uncommon” would a tree greater 

than 21 inches diameter be removed on lands within the Northwest Forest Plan lands and it would not 

occur on lands managed under the eastside screens (approximately 2/3 of the planning area). 

Underburning operations are proposed in the ponderosa pine Plant Association Group to reduce needle 

cast and small diameter down wood less than 3 inches in diameter. Burning may also reduce the 

number of small diameter lodgepole and ponderosa pine present in each unit; however, Project Design 

Features in Chapter 2 were incorporated into the alternatives to retain snags and down wood. Also, 

prescribed burning would be accomplished in a mosaic pattern with unburned areas within the burn, in 

addition to unburned designated leave areas. It is assumed, after timber harvest and fuels activities that 

post-harvest canopy cover levels would range from 20-25 percent in the lodgepole PAG and 30-35 

percent in the ponderosa and mixed conifer PAGs. These percentages would be below those described 

by Bull and Henjum (1990) that described suitable nesting conditions and below the average described 

by Bryan and Forsman (1987) in their south central Oregon study. While nesting capability would be 

reduced, active forest management would reduce stem densities and improve great gray owl foraging 

opportunities because visibility and access to the ground for prey capture would be enhanced. 

Bull and Henjum (1990) stated partial cuts are generally suitable foraging habitat because the stand is 

open enough for maneuvering, adequate perches are available, and dead and down material should be 

left for cover for voles. Passive management on areas adjacent to thinning activities would maintain 

sufficient nesting habitat which would equate to 89-90 percent of the remaining suitable nesting habitat. 

There would be no long-term effect on the great gray owl’s ability to successfully locate suitable nest 

platforms and adjacent foraging areas if nesting habitat is maintained over the long-term in the planning 

area. Bull and Henjum (1990) also state that managing habitat for northern goshawks will provide nest 

sites over time for great gray owls because the owls used old goshawk nests more than any other type of 

nest in their northeastern Oregon study sites. If active nest sites are discovered from future survey 

efforts, nest stands would be protected from harvest activities and seasonal restrictions placed on 

disturbing activities as needed (Project Design Features, Chapter 2). 

Alternative D 

Direct and Indirect Effects 

Alternative D proposes similar commercial thinning and fuels only treatments as described for 

Alternatives B and C. However, the amount of nesting habitat affected is reduced to 144 acres, or only 

3 percent of the total available in the planning area. Ninety seven (97) percent would remain in a 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – MIS Species 

173

passively-managed scenario. Activities would occur in suitable habitat along the western analysis area 

boundary, south of Odell Butte, and along the Little Deschutes River. Effects are as described for 

Alternatives B and C. Post-harvest canopy cover would likely be below the levels selected for great 

gray owls for nesting, although Bryan and Forsman (1987) noted nest sites had canopy cover as low as 

15 percent in their study area. Alternative D would retain more nesting acreage in a high canopy 

condition compared to the other alternatives. 

Similar to Alternatives B and C, Project Design Features (Chapter 2) retain 15 percent of each harvest 

unit in a passively-managed scenario which would provide a nest clump if a broken top snag, mistletoe 

clump or old nest is available for their use. If active nest sites are discovered from future survey efforts, 

nest stands would be protected from harvest activities and seasonal restrictions placed on disturbing 

activities as needed (Project Design Features, Chapter 2). 

Cumulative Effects 

Table 3-1 was reviewed for activities that overlap the zone of influence in time and space and have 

potential to incrementally affect the great gray owl. The zone of influence is identified as the 80,000-

acre Upper Little Deschutes Watershed because it is large enough for several home ranges for breeding 

adults (Bull and Henjum 1990). 

Viable Ecosystems modeling has accounted for all active management that has occurred prior to 

September 2004. Since that time, Baja West, Critter, and the Lower timber sales from Baja 58 EA and 

Finding of No Significant Impact have been completed (1,310 acres). For these reasons, the analysis 

of past actions other than those listed in this section is based on current environmental conditions. 

 

Past and present projects such as Rosedell CE, Prescribed Underburning and Mowing Project CE, and 

the Small Tree Thinning CE from Table 3-1 do not occur in potential nesting habitat. The Baja 58 EA 

decision and resulting sales removed approximately 480 acres of potential great gray owl nesting 

habitat. This was seven percent of the total potential nesting habitat in these watersheds based on 

analysis completed in 1998. While nesting capability was removed, activity units provide foraging 

habitat. Table 3-60 displays there are 4,500 acres of potential great gray owl nesting habitat in the BLT 

area primarily distributed along the Little Deschutes River corridor, the Hemlock/Spruce Creek wet 

meadow complex, and along the western analysis area boundary capable of supporting the species in 

the analysis area. Accounting for the 1,310 acres that occurred since September 2004, very little, if any 

nesting habitat was removed and there are no additive effects to disclose. Because great gray owls do 

not need entire home ranges to be dense LOS stands and that foraging habitat is generally more open 

areas, as long as replacement nest stands are available, there would be no reduction in the numbers of 

breeding pairs that could be sustained across the analysis area. 

 

Private lands were accounted for in the suitable habitat mapping. Any suitable nesting or foraging 

habitat is assumed to be incidental and may not be provided for in the long-term. It is possible great 

gray owls may nest on National Forest system lands in the analysis area and foraging may occur on 

adjacent private lands that are fairly open due to recent timber harvests. 

There are no other past, present, or reasonable foreseeable projects.

 

Waterfowl 

Existing Condition 

The Little Deschutes River is the primary water feature in the planning area. The lack of ponds, lakes 

or reservoirs limits the number of waterfowl species that would be present in the BLT area. 

Observations of Canada geese, mallards and an occasional hooded merganser have been reported along 

the Little Deschutes River. It is assumed that mallards and Canada geese are nesting in shoreline 
BLT Project Environmental Impact Statement 

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174

vegetation near the calmer waters of the side channels and river oxbows. Hooded mergansers would 

utilize tree cavities or nest boxes for egg laying. 

Effects Common to All Alternatives 

The implementation of the BLT project would have very little to no effect on waterfowl populations. 

Project work would only occur in the riparian zone of unit #1061 adjacent to Hemlock Creek and the 

Two Rivers housing subdivision. None of the remaining silvicultural or fuels activities would occur 

within the riparian zone. The felling of snags in the riparian zone is not expected to occur and it is 

unlikely there would be any disturbance to nesting waterfowl from upland thinning, pole cutting, slash 

treatments or firewood removal. Populations of the waterfowl species known to occur in the analysis 

area are not declining based on the waterfowl seasons the U.S. Fish and Wildlife Service recommends 

every year. In reviewing the activities listed in Table 3-1, only the Spruce Creek restoration project 

overlaps the BLT project. Its objective was to restore a proper hydrologic function, potentially 

increasing the quality of habitat for waterfowl in the analysis area. 

 

Golden Eagle

Ecology 

Gilligan et al. (1994) describes the golden eagle as an uncommon to fairly common summer resident in 

open country east of the Cascade Mountains and a very uncommon summer resident high in the 

Cascades. The golden eagle nests in open large (greater than 30 inches in diameter) live ponderosa 

pine or cliff ledges that support its 3-10 foot tall nest (Marshall et al. 2003). 

Existing Condition 

Because the majority of the analysis area is dominated by forested stands with 2 or 3 canopy layers of 

live trees, open country suitable for nesting and foraging is very limited for this species. The Viable 

Ecosystem analysis was completed that showed approximately 5,674 acres are present in the BLT 

analysis area with trees greater than 30 inches in diameter. There are also approximately 1,979 acres of 

grass/forb dominated plant communities. The most open ground in the analysis area is found on private 

lands along the Little Deschutes River west of the community of Crescent, Oregon and within the wet 

meadow complex of Spruce and Hemlock Creeks. While wildlife observation records list eleven 

golden eagle sightings across the entire district, only one was reported within the BLT analysis area 

near the community of Crescent, Oregon. The only known golden eagle nest on the district was 

discovered in 1994 as an active nest located outside the BLT analysis area east of Highway 97 near 

Little Walker Mountain. It is unknown if there is enough open habitat present in the analysis area for a 

golden eagle territory. The Natural Heritage program rank golden eagles as S4, apparently secure. 

 

Effects Common to All Alternatives 

There would be no effect on the golden eagle, regardless of the alternative selected. There are no 

known nests and only one reported observation in the analysis area. The live tree thinning associated 

with active management would rarely remove green trees larger than 21 inches in diameter and it is 

unlikely any trees would be greater than 30 inches in diameter with potential for nest habitat structure 

(Marshall et al. 2003). In the event nesting golden eagles are discovered in the analysis area and would 

be potentially affected, Project Design Features (Chapter 2) would protect the nest site as described in 

the Deschutes LRMP p. 4-52 (WL-2 and WL-3). 

Red-tail Hawk

Ecology 

Red-tail hawks are widely distributed across North America and winter from southern Canada south 

into the United States and Central America. The red-tail hawk has increased in numbers and expanded 

its range since Euro-American settlement (Marshall et al. 2003). While it was selected as a 

Management Indicator Species for large trees in mixed habitat, it uses any habitat that has perches to 

hunt from and open enough to capture its prey on the ground. Small mammals, such as rabbits, hares, 

and mice provide the bulk of their diet. They are also known to capture birds, reptiles, and amphibians. 
Environmental Impact Statement BLT Project 

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175

Red-tails use a wide variety of structures for nests, including trees, utility poles and cliffs (Marshall et 

al. 2003). They place their nests higher in trees than other raptors, and generally select larger trees or 

smaller deformed trees where branch structure supports this higher placement. Red-tailed hawks are 

ranked S5, secure in Oregon (NatureServe 2008). 

Existing Condition 

The Viable Ecosystem analysis showed there approximately 5,674 acres in the analysis area with trees 

exceeding 30 inches in diameter that could support a nest structure. District wildlife sighting records 

list nine red-tail hawk observations scattered across the analysis area although no nests have been 

reported as of April 2008. 

Private forestlands in the analysis area are not managed for red-tail hawks, although scattered large, 

overstory ponderosa pine may provide nest sites. However, any nesting capability for red-tail hawks 

would be incidental and would not be expected to persist for the long-term. 

Alternative A 

Direct and Indirect Effects 

This alternative has the highest risk of stand replacement from a disturbance process, but in the shortterm, it would have no effect on nesting habitat. There would be recruitment of additional acres into 

nesting status as younger managed stands develop the age and structure requirements sharp-shins and 

Cooper’s tend to select for nesting. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects

All active management alternatives propose activities within stands with trees large enough to provide 

nest structure for red-tail hawks. Alternative B proposes 324 acres of thinning in stands with trees 

greater than 30 inches diameter, 299 acres in Alternative C and 89 acres in Alternative D. Because redtails are not known to require dense multi-layered stands for nesting, the commercial thinning and fuels 

reduction activities would not affect nesting habitat and there would be no difference between 

alternatives. Live tree removal would focus on trees less than 21 inches in diameter and the residual 

stands would be more likely to sustain large trees over the longer term. It is unlikely any trees over 30 

inches would be marked for removal within the Northwest Forest Plan boundary, and no trees over 21 

inches would be marked for removal for lands affected by the Regional Forester’s Amendment #2. 

 

Stand density reduction, especially in removing trees less than 21 inches in diameter would tend to 

provide more foraging habitat for this species by opening up stands, allowing greater access to the 

forest floor to capture prey. Retaining the largest trees with the largest diameter limbs would also be 

beneficial in maintaining nesting capability in forested stands. Based on past marking for recent sales 

(Seven Buttes and Seven Buttes Return EAs USDA 1996 and 2001), less than five percent of live trees 

marked were greater than 21 inches diameter. Project Design Features (Chapter 2) have been provided 

to protect active nest sites during the nesting season by prohibiting disturbing activities such as timber 

harvest, temporary road construction, and fuel reduction activities. 

Cumulative Effects 

Forest-wide, monitoring has shown that measures used in past and present activities to protect known 

nests have been effective. Red-tail hawks are common and widely scattered on the district and the 

Natural Heritage program lists them as secure in Oregon. Table 3-1 was reviewed for activities that 

overlap the zone of influence in time and space and have potential to incrementally affect the red-tailed 

hawk. The zone of influence is identified as the 80,000-acre Upper Little Deschutes Watershed. 

The potential for additive effects would be the Baja 58 timber sales conducted 2,878 acres of understory 

commercial thinning in areas that overlap with BLT, however, Viable Ecosystems modeling has 
BLT Project Environmental Impact Statement 

Chapter 3 - Wildlife – MIS Species 

176

accounted for all active management that has occurred prior to September 2004. Since that time, Baja 

West, Critter, and the Lower timber sales from Baja 58 EA and Finding of No Significant Impact have 

been completed (1,310 acres). It is assumed that the ongoing 800 acres of prescribed burning does not 

have additive effects for this species. In general, prescriptions for past actions for vegetation 

manipulations promote and maintain nesting habitat by retaining the largest diameter trees during 

harvest operations, therefore there are no additive effects to disclose. 

Sharp-shinned and Cooper’s Hawks

Ecology 

Sharp-shined and Cooper’s hawks are both ranked S4, apparently secure in the state of Oregon 

(NatureServe 2008). Both species are closely associated with deciduous and mixed coniferous forests, 

open woodlands, and riparian woodlands. They can occur in large forests but are more likely to be 

found near forest edges and clearings near lakes or streams. In a study in eastern Oregon, Reynolds 

(1983) found nesting sharp-shinned hawks to use 25-50 year-old even-aged conifer stands while 

Cooper’s hawks used 30-70 year old even-aged conifer stands with somewhat larger and more widely 

spaced trees than those stands used by sharp-shins. Reynolds also reported the mean distance between 

the nearest nesting neighbor was 4.1 km. (2.5 miles) for sharp-shins and 4.7 km (2.8 miles) for 

Cooper’s hawks. Both species are adapted to catch avian prey but each will also capture small 

mammals, lizards and various large insects and amphibians (Johnsgard 1990). Home range estimates 

were 1,590 hectares (3,975 acres) for Cooper’s hawks and 460 hectares (1,150 acres) for sharp-shin 

hawks in Oregon (Reynolds 1983). 

Reynolds et al. (1983) studied accipiter nest sites in eastern Oregon and determined the mean canopy 

cover for sharp-shinned nests was 68 percent and 64 percent for Cooper’s hawks, although the range 

extends from 20-95 percent for sharp-shins and from 15-100 percent for Cooper’s. Both species select 

nest placement well up in the tree canopy for nest concealment or shading during warm temperatures 

(Moore and Henny 1983, Reynolds et al. 1983). Dense vegetation provides screening cover and 

physical protection from predators and predation may account for the high foliage density in the 

immediate vicinity of the nests of sharp-shins and Cooper’s hawks (Reynolds et al. 1982). 

Existing Condition 

The Viable Ecosystems model was used to estimate acres of suitable nesting habitat for these species. 

This accounted for all past activities up to September 2004 and all surrounding private lands. 

Lodgepole pine, ponderosa pine, white fir, Shasta red fir, and mountain hemlock Plant Association 

Groups with trees 10-15 inches or larger in diameter with a dense canopy greater than 25-55 percent 

(depending on the PAG) was used to define suitable nesting habitat. There are approximately 14,211 

acres of nesting habitat for these species. This acreage is generally well distributed on National Forest 

system lands across the analysis area. Suitable nesting acreage is also present on private lands on either 

side of the Little Deschutes River in the northern half of the planning area. The district wildlife 

sighting database lists two records of Cooper’s hawks, one near the base of Odell Butte and the other on 

private land near the community of Crescent, Oregon. There are also four records of sharp-shins 

including one near Odell Butte, Bunny Butte, the Crescent cut-off road, and one south of Crescent. 

Nests have not been documented for either species within the analysis area. The sightings came from 

general observations during other forest management activities as well as during surveys for northern 

goshawks. There is considerable overlap of habitat for each species and habitat. Formal surveys have 

not been conducted for either species and reported observations are the results of random observations 

and responses from conducting northern goshawk surveys.
Environmental Impact Statement BLT Project 

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Table 3-61. Acres of Potential Sharp-shinned and Cooper’s Hawks Nesting Habitat 

Alternative Pre-Treatment 

Nesting Acres 

Nesting Acres 

Treated 

Nesting Acres 

Remaining 

A 14,211 0 14,211 (100%) 

B 14,211 1,263 (9%) 12,948 (91%) 

C 14,211 1,009 (7%) 13,202 (93%) 

D 14,211 378 (3%) 13,833 (97%) 

It is unknown if Cooper’s and/or sharp-shins are nesting on private lands surrounding the analysis area. 

The majority of the private lands has been managed for industrial timber production and may only 

provide nesting habitat on an incidental basis. 

Alternative A 

Direct and Indirect Effects

This alternative would have no immediate direct effect on sharp-shinned and Cooper’s hawk potential 

nesting habitat. In the short-term, the existing habitat would be occupied with the assumption there are 

pair territories within the planning area. Over time, there is the greatest potential for stands to lose their 

desired nesting character from reduced canopy cover as a result of mortality from a disturbance event. 

Conversely, younger aged stands that have resulted from past regeneration timber harvest have the 

capability to develop into suitable nesting habitat because these species would use relatively small 

diameter trees for nesting purposes. 

Alternative B 

Direct and Indirect Effects 

Alternative B would result in activities on 1,263 acres, or 9 percent of the total potentially suitable 

nesting habitat in the analysis area. The combination of understory activities including thinning and 

underburning would likely reduce the canopy cover of most activity units below the 25-55 percent 

canopy level used to define dense stands modeled for nesting habitat. It is estimated, within lodgepole 

pine and ponderosa pine activity units post-harvest canopy would range from 30-35 percent, within 

mixed conifer sites 30-40 percent, and within ponderosa pine 25-40 percent. Because Reynolds noted a 

range of canopy cover conditions below the listed mean, modeling may underestimate suitable nesting 

habitat because there is the potential some activity units may remain functional for this life requirement. 

Cooper’s hawks would use a more open condition than sharp-shins, so they may use some of the stands 

with lower canopy for nesting and foraging following harvest activities. Sharp-shins would be expected 

to use thinned stands for foraging, but less likely to use them for nesting after the completion of harvest 

and post-sale work. Reynolds et al. (1983) stated that observations of foraging hawks indicated they 

utilized a variety of habitats from openings to dense forests. All stands were activities occur would 

function as foraging habitat for both species. 

While project activities would reduce the amount of potential nesting acreage for each species, 

Reynolds et al. (1983) noted that nest sites contain the appropriate vegetative structure for a limited 

number of years and that turnover of nest sites must be accounted for. Within the BLT analysis area, 91 

percent of the potentially suitable nest habitat would be maintained in an unmanaged condition capable 

of providing nest habitat for this species across the planning area. Within activities in mixed conifer 

Plant Association Groups, suitable nesting conditions may return in 2-3 decades as canopy cover 

returns to a desired nesting level, particularly for Cooper’s hawks which can tolerate a more open 

condition. In the event an active nest is discovered, Project Design Features (Chapter 2) designate an 

unthinned clump around each nest site and place seasonal restrictions as needed to prevent disturbance 

to nesting pair(s). Less than 10 miles of temporary roads planned to access activity units are unlikely to 

have any short- or long-term effect to either species, since less than 20 acres of forested vegetation 

would be affected. Further, temporary roads may be used as flight paths for hunting prey. The 

temporary roads would be restored to proper hydrologically functional condition after their intended 

use. Project implementation would not affect known nest sites for either species. 
BLT Project Environmental Impact Statement 

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Alternative C 

Direct and Indirect Effects 

Alternative C would actively manage 1,009 acres or 7 percent of the total potentially suitable nesting 

habitat in the analysis area. The 254-acre difference between Alternatives B and C is fewer acres of 

commercial harvest than would occur near Bunny Butte and north of Highway 58 and east of the Little 

Deschutes River currently defined as nesting habitat. Effects of canopy are as discussed in Alternative 

B. 

The combination of understory activities for Alternative C would be similar to Alternative B, except 

reduced by 254 acres. Post-harvest canopy cover for the plant association groups is as disclosed for 

Alternative B and estimates for cover post activity are likely underestimating the cover actually used 

and activity units would function as foraging habitat for both species. 

Alternative C would retain 93 percent of the potentially suitable nest habitat available for species use. 

The 8.7 miles of temporary roads planned to access treatment units are unlikely to have any short- or 

long-term effect to either species, because of narrow road width and the less. Project implementation 

would not affect any known nest sites for either species. 

Alternative D 

Direct and Indirect Effects 

The difference from Alternatives B and C is majority of the nesting habitat for both species would 

remain passively managed, although it also has a corresponding higher risk of a stand replacement 

event. This alternative would result in actively managing 378 acres or 3 percent of the total potentially 

suitable nesting habitat. The main difference between the other two alternatives is that reduced harvest 

of suitable nesting habitat would occur near Bunny Butte, along the Little Deschutes River north and 

south of Highway 58. Effects of a reduction in canopy cover short- and long-term are as described for 

the other two action alternatives. All stands where active management occurs would function as 

foraging habitat post-harvest for both species. 

In Alternative D, 97 percent of the potentially suitable nest habitat would remain available for species 

use. The 4.7 miles of temporary roads to facilitate efficient harvest are unlikely to have any short- or 

long-term effect to either species, because of narrow road width and less than 9 acres of forested 

vegetation removed. Project implementation would not affect any known nest sites for either species. 

Cumulative Effects 

Table 3-1 was reviewed for activities that overlap the zone of influence in time and space and have 

potential to incrementally affect the red-tailed hawk. The zone of influence is identified as the 80,000-

acre upper Little Deschutes Watershed. 

The potential for additive effects would be the Baja 58 timber sales conducted 2,878 acres of understory 

commercial thinning in areas that overlap with BLT, however, Viable Ecosystems modeling has 

accounted for all active management that has occurred prior to September 2004. Since that time, Baja 

West, Critter, and the Lower timber sales from Baja 58 EA and Finding of No Significant Impact have 

been completed (1,310 acres). Some of this acreage is assumed to have been suitable Cooper’s and 

sharp-shinned hawk nesting habitat. Activities conducted in the mixed conifer Plant Association 

Groups have the capability to return to suitable nesting conditions, at least for Cooper’s hawks in 

another 10-15 years, based on expected canopy cover increases. Nesting conditions in the treated 

ponderosa pine and lodgepole stands may be less likely to occur because of underburning of ponderosa 

dominated sites to maintain open LOS forest and conditions may remain too open in the lodgepole sites 

until a second canopy layer forms. Other projects in Table 3-1 in the implementation phase such as 

Maintenance Burn CE, Prescribed Underburning and Mowing Project CE and the Rosedell CE are not 

relevant because no suitable nesting habitat would be effect. For these reasons, the analysis of past 

actions other than those listed in this section is based on current environmental conditions. 
Environmental Impact Statement BLT Project 

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179

While mid-and late-successional stands in the Baja 58 project that overlap with BLT have likely 

affected nesting habitat, the silvicultural objective was to make stands more resilient while maintaining 

large trees on the landscape. In spite of nesting habitat being converted to foraging habitat, Baja 58 

maintained at least 15 percent of each harvest unit in a passively-managed scenario. These patches of 

dense forest provide nest stands for both species. In addition over 90 percent of the existing nesting 

habitat would remain available to either species. Because each species would utilize more open stands 

for foraging (Reynolds 1983) than nesting, entire home range acreages would not require LOS habitat. 

Dense stands with suitable diameter nest trees are well distributed and remain across the 5th field 

watershed. As a result, there would be no reduction in the number of home ranges that could be 

supported in the BLT planning area. Consequently, there would be no long-term effect to either species 

regardless of the action alternative selected. There are no other past, present, or foreseeable actions 

that are relevant. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

180

Threatened, Endangered, and Sensitive Species 

A Biological Assessment (BA) has been prepared in compliance with the requirements of Forest 

Service Manual (FSM) 2630.3, FSM 2672.4 and the Endangered Species Act of 1973 (Subpart B: 

402.12, Section 7 Consultation, as amended) on actions and programs authorized, funded, or carried out 

by the Forest Service to assess their potential for effect on threatened and endangered species and 

species proposed for Federal listing (FSM 2670.1). Formal consultation with the U.S. Fish and Wildlife 

Service will not be required for the BLT project. 

The Federally listed species analyzed in this document include the northern spotted owl (Strix 

occidentalis). The Oregon spotted frog (Rana pretiosa) and the Pacific fisher (Martes pennanti) are 

Federal candidates for ESA listing and are also on the Region 6 Regional Forester’s Sensitive Species 

list. 

Table 3-62 displays those species that are currently Federally listed or candidates and whether the 

species has been documented to occur within the BLT analysis area. 

Table 3-62. Threatened, Endangered, and Federal Candidate Wildlife Species Documented to 

Occur or may Potentially Occur within the BLT Analysis Area 

Species Listing Status Habitat Presence Within 

BLT 

Northern Spotted Owl 

(Strix occidentalis 

caurina) 

Federal Threatened 

Late and Oldstructured Mixed 

Conifer Forest 

Not Documented 

Oregon Spotted Frog 

(Rana pretiosa) 

Federal Candidate and 

Regional Forester 

Sensitive 

Ponds, Marshes Documented 

Pacific Fisher 

(Martes pennanti) 

Federal Candidate and 

Regional Forester 

Sensitive 

Mixed Forest with 

Complex Structure Unknown 

Table 3-63. Summary of Conclusion of Effects for Threatened, Endangered, and Federal 

Candidate Wildlife Species, BLT Project 

Species/Habitat Alt. A Alt. B Alt. C Alt. D 

Northern Spotted Owl NE NE NE NE 

Northern Spotted Owl Critical Habitat NE NE NE NE 

Oregon Spotted Frog NE NE NE NE 

Pacific Fisher NE MIIH MIIH MIIH 

NE = No Effect 

NLAA = May Effect, Not Likely To Adversely Affect 

LAA = May Effect, Likely To Adversely Affect 

NLJ = Not Likely To Jeopardize (Proposed species only) 

MIIH = May Impact Individuals or Habitat, But Will Not Contribute To a Trend toward Federal 

Listing or Loss of Viability To the Population or Species 
Environmental Impact Statement BLT Project 

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Summary Conclusions for Threatened and Endangered and Federal Candidate Species

1. Alternatives A, B, C, and D would have “No Effect” on the northern spotted owl or Critical 

Habitat and the Oregon spotted frog. 

2. Alternatives B, C, or D would result in a determination of “May Impact Individuals or 

Habitat, But Will Not Contribute To a Trend Toward Federal Listing or Loss of Viability 

To The Population or Species” for the Pacific fisher. 

Note: Where there was a “No Effect” or “No Impact” determination, it was concluded the BLT project 

either does not have the habitat for a particular species, or the zone of influence and its activities do not 

have the potential to overlap the biological needs of an individual, or a combination of both. It is not 

informative to discuss the incremental effects (cumulative) of past timber sales because they have been 

factored into the existing condition analysis and the assumption is their activities would not coincide 

with the implementation of the BLT project. For these reasons, the analysis of past actions other than 

those listed in this section is based on current environmental conditions. Cumulative or additive effects 

are discussed where they exist. 

Northern Spotted Owl, Federal Threatened, MIS

There would be no activity associated with the BLT project within Northern Spotted Owl Nesting, 

Roosting, or Foraging habitat. 

Existing Condition 

In June, 1990, the northern spotted owl was listed as a threatened species by the U.S. Fish and Wildlife 

Service and critical habitat was designated in 1992 and a final recovery plan was released in May 2008. 

In 2004 the USFWS completed a five year review of the status of the owl. They concluded a change in 

the classification of the owl was not warranted (USDI 2004). Beginning in 2004 a series of new 

publications became available on the northern spotted owl. In September 2004 the Sustainable 

Ecosystem Institute (SEI) under contract to the USFWS released a document titled The Scientific 

Evaluation of the status of the Northern Spotted Owl. Anthony et al. (2004) released a paper on the 

Status and Trends in Demography of Northern Spotted Owls 1985-2003. In September 2005 the Forest 

Service released a General Technical Report (GTR) on the Status and Trends of Northern Spotted Owl 

Populations and Habitat (Lint 2005). The Forest Service publication looked at results from monitoring 

spotted owl populations and habitat during the first 10 years of implementation of the Northwest Forest 

Plan. In April 2008, the Sustainable Ecosystem Institute evaluated the Draft Recovery Plan (DRP) and 

the scientific comments on the DRP received by the U.S. Fish and Wildlife Service. In May 2008, the 

U.S. Fish and Wildlife Service released the Final Recovery Plan for the Northern Spotted Owl. 

Collectively, these documents have been reviewed for relevant new information regarding the 

magnitude or imminence of previously identified threats to the species, new information regarding new 

threats, and their applicability to the BLT project. Some key results of these reports are listed below: 

Review and Summary of Key Findings Regarding the Northern Spotted Owl 

The Bureau of Land Management (BLM), Forest Service (FS), and US Fish and Wildlife Service 

(USFWS) coordinated review of recently completed reports containing information on the Northern 

Spotted Owl (NSO). These agencies reviewed the following reports (hereinafter collectively referred to 

as the reports): 

• Scientific Evaluation of the Status of the Northern Spotted Owl (Sustainable Ecosystems 

Institute, Courtney et al. 2004); 

• Status and Trends in Demography of Northern Spotted Owls, 1985-2003 (Anthony et al. 

2004); 

• Northern Spotted Owl Five Year Review: Summary and Evaluation (USFWS, November 

2004); and 
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Chapter 3 – Wildlife- TES Species 

182

• Northwest Forest Plan – The First Ten Years (1994-2003): Status and trend of northern 

spotted owl populations and habitat, PNW Station Edit Draft (Lint, Technical Coordinator, 

2005). 

• U.S. Fish and Wildlife Service. 2007. Draft Recovery Plan for the Northern Spotted Owl. 

Strix occidentalis caurina. Portland, Oregon. p. 176. 

• Scientific Review of the Draft Northern Spotted Owl Recovery Plan and Reviewer 

Comments (Sustainable Ecosystems Institute, Courtney et al. 2008). 

• U.S. Fish and Wildlife Service. 2008. Recovery Plan for the Northern Spotted Owl. Strix 

occidentalis caurina. U.S. Fish and Wildlife Service, Portland, Oregon. xii+142 pp. 

 

The most important conservation concerns addressed in the reports are: 

1) The precipitous NSO population declines in Washington, and declining trends in the three northern 

Oregon demographic areas, as described by Anthony et al. 2004; 

2) The three major current threats identified by Courtney et al. (2004), which are: 

• lag effects from prior harvest of suitable habitat, 

• habitat loss due to wildfire in portions of the range, and 

• competition from barred owls. 

3) The threat from wildfire is underestimated in the Draft Recovery Plan for the dry forest provinces 

and the threat is likely to increase given current forest conditions and future climatic change 

(Courtney et al. 2008). 

Some of the key findings from these reports are that reductions of spotted owl habitat on Federal lands 

are lower than those originally anticipated by the Service and the NWFP (Courtney et al. 2004). The 

primary current source of habitat loss is catastrophic wildfire (Courtney et al. 2004). Although the total 

amount of habitat affected by wildfires has been small, there is concern for potential losses associated 

with uncharacteristic wildfire in a portion of the species range. Lint (2005) indicated that the NWFP 

recognized wildfire as an inherent part of managing spotted owl habitat in certain portions of the range. 

Courtney et al. (2004) stated that the risk to spotted owl habitat due to uncharacteristic stand 

replacement fires is sub-regional, confined to the dry eastern and to a lesser extent the southern fringes 

of the spotted owl range. Wildfires accounted for 75 percent of the natural disturbance loss of habitat 

estimated for the first decade of NWFP implementation (Courtney et al. 2004). A simple reserve 

network is unsustainable in east-side fire-prone habitats. Conservation strategies to be viable must be 

designed and implemented at the landscape scale (Courtney et al. 2008). 

Anthony et al. (2004) indicated there is some evidence that barred owls may have had a negative effect 

on NSO survival in the northern portion of the NSO range. They found little evidence for such effects 

in Oregon or California. The threat from barred owl competition has not yet been studied to determine 

whether it is a cause or a symptom of NSO population declines, and the reports indicate a need to 

examine threats from barred owl competition. Courtney et al. (2008) stated that control of barred owls 

may be warranted (to be determined after experimentation and other research) and would be consistent 

with conservation actions for other endangered species. 

The full reports are accessible on the internet as follows. 

• USFWS, May 2008: 

http://www.fws.gov/pacific/ecoservices/endangered/recovery/nsorecoveryplanning.html 

• Courtney et al. 2004 and 2008: 

http://www.sei.org/projects.htm

• Anthony et al. 2004: 

http://www.reo.gov/monitoring/trends/Compiled%20Report%20091404.pdf

• USFWS, November 2004: 

http://www.fws.gov/pacific/ecoservices/endangered/recovery/5yearcomplete.html
Environmental Impact Statement BLT Project 

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183

• Lint, Technical Coordinator, 2005: 

http://www.reo.gov/monitoring/10yr-report/northern-spottedowl/documents/owl_text%20and%20tables.pdf

Nesting Habitat Associations 

On the Deschutes National Forest, northern spotted owl nesting, roosting, and foraging habitat (NRF) is 

defined as forested stands having a total canopy cover greater than or equal to 40 percent AND a 

canopy cover of at least 5 percent among trees greater than 21 inches in diameter. This definition 

assumes that the stand is multi-storied and contains some large trees 32 inches dbh or greater (USDA 

2006 Programmatic BA). A maximum 6,000 foot elevational limit was also applied in defining NRF 

habitat. At the present time there is no evidence of spotted owls nesting above 6,000 feet on the 

Deschutes National Forest. That is why the 6,000 foot limit has been applied. Field verification is also 

a method used to confirm NRF capability and/or delete those stands that have been incorrectly 

identified as NRF habitat. Stand exam data collected on Deschutes National Forest in occupied and 

previously occupied spotted owl nest stands seem to indicate a strong association with old growth 

Douglas-fir (Stone pers comm. 2005). This is consistent with dwarf mistletoe infected Douglas-fir trees 

being commonly used as spotted owl nests on east-side forests (Forsman presentation 2005). However, 

Forsman et al. (2006) also stated spotted owls will use late and old-structured ponderosa pine, Douglasfir and grand fir with cavities as nest sites with ponderosa pine being less commonly used. 

 

Using the Deschutes National Forest NRF definition, there are currently 4,275 acres of NRF habitat in 

the analysis area. The majority of the NRF stands are located in the upper Little Deschutes River 

canyon within the Mt. Thielsen Wilderness. Smaller, widely dispersed stands of NRF are also present 

in the upper reaches of the Hemlock, Basin, and Rabbit Creek drainages of the Oregon Cascades 

Recreation Area (OCRA). Small parcels are also present on Beals Butte and Chinquapin Butte of the 

analysis area. The patchiness of NRF habitat in most of the analysis area may preclude occupancy by 

spotted owls with the exception of the upper Little Deschutes River canyon. The NRF habitat in the 

canyon is consolidated with large enough blocks that future occupancy is more likely there than the 

remainder of the BLT area. The patchiness of NRF habitat is the result of past regeneration timber 

harvests and the dominance of ponderosa pine and lodgepole pine plant associations that comprise 

approximately 71 percent of the analysis area and do not contribute to NRF habitat. 

Prey Base 

The northern spotted owl’s primary prey in much of the Pacific Northwest is the northern flying 

squirrel (Forsman et al. 2006). Spotted owls will also prey on a wide range of other small mammals. 

An analysis of regurgitated pellets collected from Deschutes National Forest spotted owls showed prey 

species of flying squirrels, snowshoe hares, grouse, western pocket gophers, Pacific jumping mice, red 

back voles, Douglas squirrels, arboreal crickets, shrews, bushy-tailed woodrats, and chipmunks 

(Henshaw pers comm. 2005). Forsman et al. (2006) stated that northern spotted owl diets on the eastside forests showed northern flying squirrels make up about 40 percent of the owl diet in numbers of 

prey capture. He also stated that bugs represent 15 percent, other mammals 12 percent, red back voles 

10 percent, woodrats 8 percent, and rabbits and pikas 5 percent of their total prey captures. 

Dispersal 

The term dispersal habitat is commonly used to describe forest stands used by juvenile spotted owls 

during movement away from natal areas or by subadult and adult owls moving from one territory to 

another (Forsman et al. 2002 cited in Lint 2005). Generally, forest stands with an average tree diameter 

greater than 11 inches and conifer overstory trees with closed canopies (greater than 40 percent canopy 

cover) with open space beneath the canopy to allow for the owls to fly are considered owl dispersal 

habitat (Thomas et al. 1990 in Lint 2005). This dispersal habitat definition is not biologically possible 

in all east-side Cascades plant association groups. The Deschutes National Forest convened a Science 

Team of experts on local conditions to determine dispersal habitats. The team determined a process by 
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Chapter 3 – Wildlife- TES Species 

184

which local biological knowledge of sites would be used to describe dispersal habitat (USDA Letter 

1996). The criteria displayed in Table 3-64 were developed using the prescribed process and used to 

define dispersal habitat for past projects such as Seven Buttes, Baja 58, and Seven Buttes Return 

environmental assessments and will be used for the BLT project. 

Table 3-64. Dispersal Habitat Definition Developed by the Deschutes National Forest 

Plant Association Group Even-aged Stands Uneven-aged Stands 

Mixed Conifer Wet 11” dbh, 40% Canopy Cover 11” dbh, 40% Canopy Cover 

Mixed Conifer dry 8” dbh, 35% Canopy Cover 11” dbh, 35% Canopy Cover 

Ponderosa Pine 8” dbh, 35% Canopy Cover 11” dbh, 35% Canopy Cover 

Lodgepole Pine 7” dbh, 30% Canopy Cover 7” dbh, 30% Canopy Cover 

Mountain Hemlock 7” dbh, 30% Canopy Cover 7” dbh, 30% Canopy Cover 

While past regeneration harvests have created edge habitat, owl dispersal is possible through the NWFP 

portion of the analysis area. There have been no large fire events which have eliminated spotted owl 

dispersal ability through this area. 

Northern Spotted Owl Critical Habitat and the Recovery Plan 

The BLT analysis area lies within the Eastern Cascades Province which includes all forested lands in 

Oregon east of the crest of the Cascades and north of the Klamath Mountains province within the range 

of the spotted owl. This province provides the easterly extension of the spotted owl in Oregon. 

The northern spotted owl was listed as Federally threatened in 1990 and a draft recovery plan was 

published in 1992 (USFWS 1992). However, that plan was not completed due to the development of 

the Northwest Forest Plan in 1994, which became the cornerstone for conserving and recovering the 

northern spotted owl on 24.4 million acres of Federal land in Oregon, Washington and California. 

However, the Northwest Forest Plan only addressed northern spotted owl conservation on Federal land 

and it did not establish criteria for measuring whether the species has recovered. A revised recovery 

plan was released for public comment in 2007. 

A Final Recovery Plan for the Northern Spotted Owl was signed on May 13, 2008. For lands east of 

the Cascade crest, a landscape management approach is recommended due to the landscape being 

strongly influenced by natural disturbances such as wildfire and insect outbreaks. The Plan recognizes 

the need to manage entire landscapes to meet spotted owl objectives. It lists a series of recovery actions 

to identify, maintain, and restore a percentage of the habitat capable lands to provide spotted owl 

habitat patches while also reducing the potential of significant loss by stand replacement fires, insects, 

and disease by active forest management. The Recovery Plan recommended the formation of a Dry 

Forest Province workgroup which will be led by Brian Woodbridge of the U.S. Fish and Wildlife 

Service. Appendix E of the Recovery Plan provides information on managing for sustainable spotted 

owl habitat in the dry Eastern Cascades forests of the Inland Northwest. On page 110 of the Recovery 

Plan, the panel of experts recommended five stand restoration and fuel treatment principles: 

1) favor fire tolerant species 

2) retain large and very large fire tolerant species 

3) apply treatments unevenly within stands 

4) apply treatments unevenly among stands 

5) develop silvicultural prescriptions for entire landscapes that integrate fuel reduction activities 

with those maintaining or improving habitat for northern spotted owl prey, habitat for other 

species and restoration of dry forest ecological processes and function. 

These stand restoration and fuel treatment principles have been applied to BLT. This analysis discloses 

those instances where the rare removal of trees greater than 21 inches in diameter would occur (Project 

design Features, Chapter 2). Activity units and size, silvicultural and fuels prescriptions have also been 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – TES Species 

185

provided. These actions show the intent of managing habitat as described in the Recovery Plan in the 

dry forest provinces. 

On August 13, 2008, the U.S. Fish and Wildlife Service announced a Revised Designation of Critical 

Habitat for the Northern Spotted Owl (Federal Register Vol. 73, No. 157, August 13, 2008). At the 

present time, the landscape management approach for the eastside provinces identified in the Recovery 

Plan was not incorporated into the new Critical Habitat rule until the new approach is further defined. 

In the interim for eastside provinces, the areas identified as Option 1 Managed Owl Conservation Areas 

(MOCAs) in the 2007 draft recovery plan are finalized as Critical Habitat in this rule. MOCA 

#OMOCA-52 (34,233 acres) is within the Crescent Ranger District boundaries and has a relatively 

similar configuration as the prior Critical Habitat Unit CHU OR-07 and overlaps almost entirely with 

the Davis Late-Successional Reserve. The BLT project area does not overlap with any MOCA acreage 

as defined and mapped in the 2007 Draft Recovery Plan for the Northern Spotted Owl. 

Survey Status 

The BLT analysis area has been extensively surveyed for northern spotted owls including three visits to 

protocol in 2001, 2002, 2003, 2005, and 2006. There were no documented responses of spotted owls in 

or adjacent to the project in any of those years. There are also no pairs or territorial single spotted owls 

in the BLT area or adjacent area that would be affected by project activities. The nearest territories are 

located in the Big Marsh Creek drainage approximately 1.5 miles west of the BLT southwestern 

boundary and greater than 3.5 miles to the nearest planned activity unit. 

 

There is one documented report of a barred owl in the Little Deschutes River heard in 1996 while 

conducting great gray owl surveys. There have been no other barred owl observations or vocalizations 

heard in the analysis area since then. Two single barred owl responses have been heard outside the 

analysis area, near Big Marsh in 2002 and west of Beals Butte in 2003. As of April 2008 there are no 

known barred owl pairs on the Crescent Ranger District and barred owl reproduction has not been 

documented. Across the entire Crescent Ranger District, barred owl auditory calls and/or visual 

observations have been recorded on Royce Mountain (1996 and 2006), McCool Butte (2004), and 

above Odell Lake (2005). There is no evidence to date that barred owls are occupying spotted owl core 

areas, home ranges, or have resulted in any spotted owl displacement because they were not heard in 

consecutive years or the same location. Barred owls are thought to be transients and not an established 

population. 

Effects Common to All Alternatives 

There are no activities planned within stands classified as NRF habitat. However, activities would 

occur within stands identified as providing dispersal habitat and post-harvest, each treated stand would 

be expected to provide dispersal capability after the completion of commercial, non-commercial and 

fuels activities. Because no activities would occur in NRF stands, the 4,275 acres of existing NRF 

habitat would be maintained in the status quo and continue on a trajectory with an increase of risk 

associated with a wide-scale disturbance event. There are no present or foreseeable projects that 

overlap mapped NRF habitat within the BLT analysis area. None of the project area is within a 

designated Late-Successional Reserve (LSR), MOCA, or CSA as described in the Draft and Final 

Northern Spotted Owl Recovery Plans. 

While the barred owl has been identified as a current threat to the spotted owl, the greatest uncertainties 

on the potential effects is the lack of accurate information on barred owl density, numbers, population 

trends, and that we are unable to resolve with certainty whether the observed changes of barred owls 

and spotted owls are causal or merely correlated in opposite ways with some other unknown factors 

(Courtney et al. 2004). It is also clear that in some portions of the northern spotted owl’s range, barred 

owls are increasing and spotted owls are declining to some degree independently of forest management 

history in the area. On the Gifford Pinchot National Forest, the density and impact of barred owls 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

186

appears higher in areas without timber harvest (Pearson and Livezey 2003 cited in Courtney et al. 

2004). Barred owls use more types of habitats and have a broader range of prey selection. Evidence 

suggests that the barred owl is having a negative effect on northern spotted owls in some areas, but in 

other areas, the barred owl has not had an effect, because either the conditions are not entirely suitable 

for its occupation or it has yet to increase to sufficient density to have an impact on the spotted owl 

(Courtney et al. 2004). On the Crescent Ranger District barred owl responses are few in spite of almost 

annual surveys for spotted owls. The reasons for this are currently unknown. There is no indication at 

this time that barred owls are having a negative effect on spotted owls or that commercial thinning 

harvests are encouraging barred owl occupancy on the district. 

Determination 

It has been determined that implementation of any BLT alternative would have “No Effect” on the 

northern spotted owl, conservation strategy areas, or critical habitat. This conclusion was reached 

because spotted owl pairs or territorial singles are not known to occur in the analysis area, that no NRF 

habitat would be modified or removed, that all dispersal habitat would be retained post harvest, and that 

no activities would occur in any LSR, MOCA, or CSA. 

Consistency with the Programmatic Biological Assessment 

The BLT project complies with all spotted owl Project Design Criteria (PDCs) described on pages 84-

85 of the 2006 Programmatic BA and formal consultation with the USFWS will not be required. 

Oregon Spotted Frog (Rana pretiosa) R6 Sensitive, Federal Candidate Species

The Oregon spotted frog (Rana pretiosa) is currently listed as a Federal candidate species by the 

USFWS. Spotted frogs have a historic distribution that covers a small part of western North America, 

from southern British Columbia to northeastern California, and from the west side of the Willamette 

Valley to the east side of the Klamath Basin in Oregon. They have been extirpated in much of their 

range by the introduction of the bullfrog (Rana catesbeiana) and habitat alternation/loss through 

intensified agriculture, grazing, and urbanization (USGS 2003). Pearl (pers comm. 2008) remarked that 

central Oregon, including Big Marsh on the Crescent Ranger District and Sunriver south of Bend, seem 

to represent strongholds for the species and have the largest populations in the state of Oregon. 

Ecology 

Oregon spotted frogs are associated with wetland complexes greater than 4 ha (10 acres) in size with 

extensive emergent marsh coverage that warms substantially during seasons when Oregon spotted frogs 

are active at the surface. Sites always include some permanent water juxtaposed to seasonally 

inundated water (Pearl and Hayes 2004 cited in Cushman and Pearl 2007). They use shallow 

oviposition sites consistently across their range with average depths per site ranging from 2.3” to 10” in 

depth (Pearl and Hayes 2004). Oviposition usually occurs between mid-February and mid-April 

depending on water temperature. The diet of the Oregon spotted frog includes arthropods (e.g. spiders, 

insects), earthworms and other invertebrate prey. In turn, they may be preyed upon by mink, river otter, 

herons, bitterns, corvids, and garter snakes. Threats to the species were hypothesized by Cushman and 

Pearl (2007) to include direct loss and conversion of marsh habitats, interactions with non-native fishes, 

plant succession and other vegetation changes, livestock grazing, degraded water quality, isolation from 

other populations, and drought. 

Existing Condition 

In 1994 Oregon spotted frog surveys were conducted on selected streams and marshes on the Crescent 

Ranger District (Hayes 1995). Oregon spotted frogs were confirmed in Big Marsh, Odell Creek and 

Ranger Creek. Greater than 300 frogs were counted in Big Marsh but only small populations (<10 

individuals) on Odell Creek and Ranger Creek. Hayes (1995) stated spotted frog habitat was limited in 

Odell Creek and Ranger Creek because brook trout were present, stream temperatures were cold, and 

side channels were limited that offer warm shallow water habitat needed by frogs. In late July 2004 
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another inventory was conducted on Odell Creek and Ranger Creek to determine if Oregon spotted 

frogs were still present in these streams 10 years after the first survey. District wildlife personnel 

confirmed 2 sub-adult and 1 adult spotted frogs in Odell Creek between East Davis campground and the 

confluence of Odell Creek and Davis Lake. There were no observations of spotted frogs or egg masses 

in Ranger Creek in 2004. 

Within the BLT analysis area two small populations of spotted frog adults were confirmed in the Little 

Deschutes River near Highway 58 during inventories conducted in 2001 (Branum pers comm. 2005). 

It is unknown if Oregon spotted frogs exist further south of known populations on the Little Deschutes 

River near Highway 58. Branum (pers comm. 2008) stated surveys for Oregon spotted frogs were 

conducted in Hemlock and Spruce Creek drainages during the mid-90s though no spotted frogs were 

located. 

Effects Common to All Alternatives 

There is only one activity unit (#1061 on Hemlock Creek) with potential to overlap spotted frog habitat. 

It includes small diameter thinning and prescribed burning immediately adjacent to the Two Rivers 

subdivision. Since no individuals are known to inhabit the site and no other activities are within 

riparian resources, there would be no direct or indirect effect. There is no other past, present or 

foreseeable action that has potential to be additive. 

Determination 

Implementation of any alternative of the BLT project would have “No Effect” on the Oregon spotted 

frog or their habitat. The BLT project is consistent with all Project Design Criteria (PDCs) in the 2006-

2009 Joint Aquatic and Terrestrial Programmatic Biological Assessment for Federal Land Administered 

by the Deschutes and Ochoco National Forests (USDA 2006). 

Pacific Fisher (Martes pennanti), R6 Sensitive, Federal Candidate Species

The Pacific fisher is a Federal Candidate he USFWS was issued a court order in April 2003 to conduct 

a 90 day finding on a petition to list a distinct population segment of the fisher. In July 2003 the 

USFWS published a 90 day finding that substantiated a listing may be warranted and began a 12 month 

status review. In April 2004 the USFWS determined that the fisher in Washington, Oregon and 

California is a “distinct population segment” of the entire fisher species. The USFWS determined that 

the fisher faces significant biological threats that are sufficient to warrant listing but is precluded by 

other higher priority listing actions (Federal Register Vol. 69, No. 68). Threats to the fisher include loss 

and fragmentation of habitat, mortalities and injuries from incidental captures, decreases in prey base, 

increasing human disturbance, and small isolated populations. 

Ecology 

The fisher is a house-cat sized member of the Mustelidae family which includes weasels, mink, marten, 

and otters. Their occurrence is closely associated with low- to mid-elevation forests (generally less 

than 1,250 m) with a coniferous component, large snags or decadent live trees and logs for denning and 

resting, and complex physical structure near the forest floor to support adequate prey populations 

(Powell and Zielinski 1994). Rosenberg and Raphael (1986 cited by Kremaster and Bunnell in 

Rochelle et al. 1999) stated the fisher was negatively associated with edges at all scales of 

measurements and could be considered a forest interior species. However, fishers also venture into 

openings to feed (reviews of Buskirk and Powell 1994 and Martin 1994 cited by Kremaster and Bunnell 

1999 in Rochelle et al. 1999). 

Within a given region the distribution of fishers is likely limited by elevation and snow depth and fisher 

are unlikely to occupy habitats in areas where elevation and snow depth act to limit their movements 

(Krohn et al. 1997 cited by USFWS 2004). However, in mid-elevation areas with intermediate snow 

depth, fishers may use dense forest patches with large trees because the overstory increases snow 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

188

interception (Weir 1995 cited by USFWS 2004). Aubry and Houston (1992 cited by Powell 1993) 

believe snow affected fisher distribution and population density in Washington state. Powell (1993) 

also stated that fishers will choose habitats with prey they can catch. Those habitats will meet the 

requirements of fisher prey as well as be structured such that fishers can forage successfully without 

high foraging costs. 

Prey in Oregon include snowshoe hare, brush rabbit, California ground squirrel, Douglas’ squirrel, 

northern flying squirrel, woodrats, opossum, striped skunk, porcupine (male fishers only), bobcat, deer, 

elk, Stellar’s jay, pileated woodpecker, and hairy woodpeckers (Aubry and Raley 2002). Fishers are 

fast, agile and adept at climbing trees and will eat any prey they can catch and overpower, including 

squirrels, hares, mice, birds and porcupines. Although adapted for climbing, fishers are primarily 

terrestrial. When inactive, the fisher occupies dens in tree hollows, under logs, or in the ground or 

rocky crevices, or rests in the branches of conifer trees during the warmer months. Female fishers give 

birth and raise kits in cavities in large-diameter (>80 cm, 31 inches) live trees, snags, and logs, and use 

these structures and large platform branches for rest sites (Powell and Zielinski 1994; Aubry and Raley 

2002). In the western USA, fishers generally avoid clearcuts and forested stands with less than 40 

percent canopy cover (Buck et al. 1994 and Jones and Garton 1994 cited by Aubry and Lewis 2003). 

Powell (1993) reported that open habitat vegetated with young deciduous trees and shrubs (typical of 

clear-cut areas) are used by fishers in summer but are truly open with no overhead cover in winter. 

Aubry and Raley (2006) in a study area of the southern Oregon Cascades determined that home ranges 

for adult females was 25 square kilometers (9.7 square miles) and for males averaged 62 square 

kilometers (23.9 square miles, non-breeding season) and 147 square kilometers (56.7 square miles) 

during the breeding season. 

Prior to extensive European settlement, fishers occupied most coniferous forest habitats in Washington, 

Oregon and California (Aubry and Lewis 2003). Extensive trapping in the 1800s and 1900s is 

frequently cited as the principal initial cause of the substantial reduction of the range of the fisher in 

Washington, Oregon and California (Federal Register Vol. 69, No. 68). The extent of past timber 

harvest is one of the primary causes of fisher decline across the United States (Powell 1993 cited in 

USFWS 2004) and may be one of the main reasons fishers have not recovered in Washington, Oregon, 

and portions of California as compared to the northeastern United States (Powell and Zielinski 1994). 

Habitat fragmentation has contributed to the decline of fisher populations because they have limited 

dispersal distances and are reluctant to cross open areas to recolonize historical habitat (USFWS 2004). 

Fishers have a low annual reproductive capacity; not all females produce young every year and litters 

usually consist of 2 to 3 kits raised entirely by the female. In addition, recent evidence suggest only 

juvenile males disperse long distances which would affect the rate at which fishers may be able to 

colonize formerly occupied areas within its historical range (Aubrey et al. 2003). Fishers are estimated 

to live up to 10 years (Powell 1993). 

Existing Condition 

In Oregon, the fisher apparently has been extirpated from all but two portions of its historical range 

(Aubry and Lewis 2003). Within Oregon, the two known extant populations are in the southwestern 

portion of the state: one in the southern Cascade Range that was established through reintroductions of 

fishers from British Columbia and Minnesota that occurred between 1961 and 1981, and one in the 

northern Siskiyou Mountains of southwestern Oregon that is presumed to be an extension of the 

population in northern California. Genetic testing has revealed the populations are isolated from each 

other (Aubry et al. 2002). The same study revealed juvenile male fishers are capable of long distance 

dispersal with one collared male relocating to the Crescent Ranger District in the summer of 1999 

having traveled fifty-five kilometers from point of capture on the Rogue River National Forest. The 

radio signal from this animal was lost in December 1999 due to battery failure. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – TES Species 

189

Carnivore surveys were conducted on the Crescent District in 1993-1996 and 1998 using bait with 

camera sets, snow tracking and track plates. There were no detections of fishers or wolverine from 

these surveys although marten were confirmed. At the present time there is no confirmation of 

reproducing fisher populations on the Crescent Ranger District. 

Suitable denning habitat was defined as forested stands with greater than 20 inch diameter trees in 

lodgepole pine, ponderosa pine, white fir, Shasta red fir, and mountain hemlock PAGs having a dense 

canopy greater than 40-55 percent depending on the PAG. Using this definition the Viable program 

estimated approximately 4,304 acres of habitat. This figure accounts for all past and present timber 

sales, natural events such as wildfire, and any other habitat-altering activity that would express itself in 

a vegetative manner. This way of presenting this information is the most informative manner for the 

decision maker. The majority of this habitat is located in the upper Little Deschutes River canyon 

including the Mt. Thielsen Wilderness and Oregon Cascades Recreation Area (OCRA) but also along 

the western planning area boundary although discontinuous in nature primarily due to changes in stand 

tree diameters. 

Figure 3-24 represents fisher denning habitat using the Viable Ecosystem Modeling method with the 

appropriate live tree structure, tree species and density. It also shows where the Viable definition 

overlaps with snag and down wood densities that meet the 50 percent tolerance interval as described in 

DecAID (greater than 10 inches in diameter and greater than 12.9 snags per acre and down wood 

greater than or equal to 5 inches in diameter and greater than 5.6 percent cover). As displayed in Figure 

3-24, fisher denning habitat is concentrated in the upper Little Deschutes River canyon of the Oregon 

Cascades Recreation Area and the Mt. Thielsen Wilderness. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

190

Figure 3-24. Pacific Fisher Habitat
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – TES Species 

191

Alternative A 

Direct and Indirect Effects 

There would be no direct impact to fishers or their habitat with implementation of this alternative. 

Fishers, if currently present could continue to utilize late and old structural stands in the planning area 

for foraging, denning, and as resting sites. Habitats would also be available to fishers that may be 

trying to colonize into suitable lands from existing populations on the Rogue-Siskiyou National Forests. 

Barring catastrophic habitat changes, habitat would be maintained at least in the short-term. Over the 

long-term increased tree growth in existing plantations will develop enough canopy cover for a more 

connected landscape available to fishers. Implementation of the no-action alternative would have “No 

Impact” on the Pacific fisher. 

A passive management scenario would have an elevated risk of large tree loss to a wide-scale 

disturbance. Suitable denning habitat is typically comprised of dense, old, and large diameter stands 

with multiple layers of tree canopy. Stands in this condition are likely more susceptible to loss from 

competition, insects, and wildfire. 

Effects Common to Action Alternatives 

This is based on tree size classes and appropriate Plant Association Groups described in the 

existing condition. Table 3-65 (snags) displays the range of tolerance intervals based on snag 

levels taken from DecAID. For snags greater than 10 inches in diameter, 64 percent of the habitat 

is less likely to support denning females (less than 50 percent tolerance interval) while 36 percent 

of the habitat is more likely to support denning females (greater than 50 percent tolerance interval). 

For snags greater than 20 inches in diameter, 66 percent of the analysis area is less likely to support 

denning females (less than 50 percent tolerance interval) while 34 percent of the analysis area is 

more likely to support denning females (greater than 50 percent tolerance interval). Project Design 

Features disclose the limited circumstances where snag felling may be needed during project 

implementation. 

Table 3-66 (down wood) displays the range of tolerance intervals based on down wood densities 

taken from DecAID. For down wood greater than 5 inches in diameter, 77 percent of the habitat is 

less likely to support denning females (greater than 50 percent tolerance interval), while 23 percent 

of the habitat is more likely to support denning females (greater than 50 tolerance interval) because 

of increased levels of down wood cover. While personal use and/or commercial firewood removal 

may occur in a limited number of harvest units, none would occur within the 4,304 acres of 

denning habitat. 

Table 3-65. Tolerance Intervals for the Pacific Fisher and Snag Use 

Pacific Fisher 

4,304 Acres 

Density of Snags 10"+dbh 

 by tolerance interval 

Density of Snags 20" + dbh 

by tolerance interval 

Tolerance Interval* below 50% above 50% 0-50% 50-80% 80%+ 

Density (#/hectare)* 0-31.9 31.9+ 0-3.5 3.5-14.1 14.1+ 

Density (#/acre) 0-12.9 12.9+ 0-1.4 1.4 5.7 

% of Habitat 64.2% 35.8% 65.7% 14.0% 20.3% 

Acres 2,761 1,543 2,828 600 876 

*From DecAID 2.0 Table MMC_S/L.sp-22. Information synthesized from various studies 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

192

Table 3-66. Tolerance Intervals for the Pacific Fisher and Down Wood Use 

Pacific Fisher 

4,304 

Down wood cover (%) 

of down wood 

 5"+ (12cm) 

Tolerance 

Interval* below 50% above 50% 

% Down wood 

Cover 0-5.6 5.6+ 

% of Habitat 77% 23% 

Acres 3,330 974 

* Developed from DecAID 2.0 Tables MMC_S.sp24 and MMC_L.sp-24. Information synthesized from 

various studies. 

Overall, the BLT project would improve future habitat conditions for the Pacific fisher. Viable 

Ecosystem outyear modeling was conducted to determine changes in suitable denning habitat acreage at 

10 years, 20 years and 50 years for all alternatives. All alternatives showed an increase in suitable 

denning habitat acreage over each decade. At the end of the first decade, denning acreage ranged from 

6,637 acres (Alternative A) to a high of 6,833 acres (Alternative B) as compared to an existing amount 

of 4,304 acres. At 20 years, denning acreage ranged from 8,906 acres (Alternative A) to a high of 

9,295 acres (Alternative B). At 50 years, modeling showed denning acreage that ranged from 15,866 

acres (Alternative A) to a high of 16,839 acres (Alternative B). This determination was based on 

silvicultural prescriptions, expected increased vigor from thinning and the probability of advancing to 

the next successional stage. 

Alternative B 

Direct and Indirect Effects 

This alternative would commercial thin 344 acres (8 percent) of the acreage identified as potential 

denning habitat for this species. The silvicultural prescriptions would reduce understory tree 

densities to relieve competition for scarce site resources. Post-sale activities may include small 

diameter thinning to further reduce the densities of trees smaller than 8 inches. Fuels activities 

could include grapple piling or handpiling with disposal, prescribed underburning, or a 

combination of treatments. While personal use and/or commercial firewood removal may occur in 

a limited number of harvest units (80, 270, 295, 435, 575, 690, 940, 1190, 1200, 1205, 1235, and 

1300), none would occur within the 4,304 acres of denning habitat. 

 

In the western USA, fishers generally avoid clearcuts and forested stands with less than 40 percent 

canopy cover, and occur at low densities in second-growth forests and landscapes that have been 

extensively fragmented by timber harvesting (Aubrey and Lewis 2003). Even though generally the 

largest live trees would be retained, the level of harvest would likely reduce canopy cover levels below 

the 40 percent level. Post-harvest canopy would range from 20-25 percent in the lodgepole pine stands 

and approximately 30-35 percent in the ponderosa pine and mixed conifer PAGs. Except in lodgepole 

pine, canopy cover levels are assumed to increase approximately 5 percent per decade after harvest. It 

is assumed fishers, if present in the project area, would avoid treated areas for several decades or until 

canopy cover returns to the 40 percent level. 

Management activities have the potential to cause disturbance which could displace individuals if they 

are dispersing through an active sale area. This is considered a short-term effect as it potentially could 

last up to five years. In the worst case scenario, disturbance could cause dens to be moved while rearing 

young. Activities would not inhibit the ability of dispersing fishers to re-colonize into the analysis area 

and surrounding lands. There would be sufficient opportunities for displaced individuals to occupy 

suitable habitat (absent of disturbing activities above existing levels) inside and adjacent to the analysis 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – TES Species 

193

area. Current research shows that fishers are slow to re-colonize formerly occupied sites and that only 

juvenile males will disperse long distances (Aubrey et al 2003). Habitat fragmentation from active 

management is usually associated with timber harvest with a regeneration prescription. Since none is 

planned, an active management scenario would not increase habitat fragmentation. In addition, tree 

growth in existing plantations will gradually provide overhead forest cover also lessening the effects of 

a fragmented landscape. 

While this alternative proposes construction of 9.7 miles of new temporary roads, when viewed over an 

80,000 (125 square miles) planning area, there would likely be little effect to fishers over what has been 

described because the scale of this effect, temporary roads are mostly located within units, are not 

permanent, and would be restored in a relatively short timeframe (sooner than 5 years). 

While it is unknown if fishers occupy the analysis area, active forest management would lessen risk for 

wide scale habitat loss from a disturbance event. As evidenced by the 2003 Davis Fire on the Crescent 

District, large-scale loss of LOS stands are possible that could remove suitable habitat and fragment the 

landscape for more than a century. Overall, this alternative is likely to have little long-term effect to 

this species. Although it is estimated to take several decades for the 344 acres thinned to return to 

denning habitat, over 92 percent of the currently suitable denning habitat would be retained in its 

current capacity. 

Alternative C 

Direct and Indirect Effects 

The selection of this alternative would result in the commercial thinning of 296 acres (7 percent) of the 

acreage identified as potential denning habitat for this species, and construction of 8.7 miles of 

temporary roads. As described in Alternative B, over 90 percent of existing suitable denning habitat 

would be retained. Although the scope of activities is less than those described in Alternative B, its 

effects are similar. There exists a possibility disturbance could displace individuals. As in Alternative 

B, no personal or commercial firewood removal would occur within the 4,304 acres of denning habitat. 

Alternative D 

Direct and Indirect Effects 

The selection of this alternative would result in the commercial thinning of only 35 acres (less than 1 

percent) of the total defined fisher denning habitat in the analysis area. The minimal amount of acreage 

treated with commercial thinning and post-sale activities would likely have little effect to the species. 

The silvicultural and fuels prescriptions would be similar to that described in Alternatives B and C, 

although greatly reduced in the number of acres treated. 

The potential for disturbance impact from management actions is also reduced because of the fewer 

acres being treated. This alternative would require the construction of 4.7 miles of temporary road to 

access harvest units. As in Alternatives B and C, there is likely little long-term effect to this species. 

Over 99 percent of the currently suitable denning habitat would be retained in its current capacity. 

Cumulative Effects 

Table 3-1 was reviewed for projects that have the capability to overlap in time and space within the 

same zone of influence. The zone of influence was defined as the 80,000-acre 5th field watershed 

because it most closely matches home ranges (Aubry and Raley 2006). 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. Since most of the denning habitat is in the Oregon Cascades 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- TES Species 

194

Recreation Area and Wilderness, it is assumed very little denning habitat would be affected. It is 

assumed ongoing prescribed underburning on 800 acres would not overlap suitable habitat. For these 

reasons, the analysis of past actions other than those listed in this section is based on current 

environmental conditions. 

As described in the project biological evaluations/assessments for all past and present projects, none 

individually or collectively resulted in a trend toward Federal listing, even though individuals or habitat 

may be affected. Activities included commercial thinning with no regeneration timber harvest, which 

has potential to completely remove habitat. The BLT project would implement similar silvicultural and 

fuels prescriptions designed to reduce the risk of large-scale loss of forest. Also, each project was 

designed to increase the potential to retain the largest trees on the landscape, which would take the 

longest to replace, if lost. 

As of April 2008 there is only one confirmed record of fishers utilizing habitats on the Crescent Ranger 

District and no documentation of year-round use or species reproduction. Neither of the past or present 

projects listed would overlap the same time BLT would operate. It is unclear if habitat conditions and 

average winter snow depths can provide suitable year-round habitat for this species within the analysis 

area and adjacent lands on the district. Foreseeable actions include implementation of the Travel 

management Rule in 2009. This Rule would prohibit off road travel and restrict them to designate 

routes. Although off highway vehicle travel is occurring mostly adjacent to the Two Rivers 

Subdivision, implementation of this rule would further reduce the potential for disturbance. Based on 

existing knowledge of species presence and habitat conditions available, and the factors disclosed in 

this section, there are no other past, present, or foreseeable actions identified. Effects disclosed for 

direct and indirect would not change. 

Determination 

While there is no documented evidence that fishers are currently occupying the planning area, there is 

suitable habitat present. Timber harvest and fuel treatments activities have the potential to reduce 

canopy cover below the levels described for the species and may create disturbance to animals that may 

occupy a drainage or may be dispersing through the planning area. The determination that 

implementation of Alternative B, C, or D is “May impact individuals or habitat, but will not likely 

contribute to a trend toward Federal listing or cause a loss of viability to the population or 

species”. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

195

Regional Forester’s Sensitive Species 

Species classified as sensitive by the Forest Service are to be considered by conducting biological 

evaluations (BE) to determine potential effects of all programs and activities on these species (FSM 

2670.32). The BE is a documented review of Forest Service activities in sufficient detail to determine 

how a proposed action may affect sensitive wildlife species. 

Table 3-67. Regional Forester Listed Sensitive Animal Species for the Deschutes National Forest 

Species Listing Status Habitat Presence within BLT 

Analysis Area 

Bald Eagle 

(Haliaeetus leucocephalus) 

Regional Forester 

Sensitive 

Lakes, Reservoirs, Large 

Trees for Nesting 

Incidental ObservationsNo Known Nests 

Horned Grebe 

(Podiceps auritus) 

Regional Forester 

Sensitive Lakes No Habitat 

Red-necked Grebe 

(Podiceps gisegena) 

Regional Forester 

Sensitive Lakes No Habitat 

Bufflehead 

(Bucephala albeola) 

Regional Forester 

Sensitive Lakes, Snags Unknown 

Harlequin Duck 

(Histrionicus histrionicus) 

Regional Forester 

Sensitive Fast Flowing Streams Unknown 

American Peregrine Falcon 

(Falco pergrinus anatum) 

Regional Forester 

Sensitive Cliffs, Riparian Unknown 

Tricolor Blackbird 

(Agelaius tricolor) 

Regional Forester 

Sensitive Lakeside, Bulrushes Unknown 

Lewis’ Woodpecker 

(Melanerpes lewis) 

Regional Forester 

Sensitive 

Open woodland habitat 

(oak, ponderosa, or 

cottonwood) near water 

Unknown 

White-Headed 

Woodpecker 

(Picoides albolarvatus) 

Regional Forester 

Sensitive 

Ponderosa pine or mixed 

conifer forests dominated 

by ponderosa pine 

Unknown 

Northern Waterthrush 

(Seiurus aurocapillus) 

Regional Forester 

Sensitive 

Riparian hardwoods 

(willows) Documented 

Western Sage Grouse 

(Centrocercus 

urophasianus phaeios) 

Regional Forester 

Sensitive Sagebrush No Habitat 

Yellow Rail 

(Coturnicops 

noveboracensis) 

Regional Forester 

Sensitive Marshes No Habitat 

California Wolverine 

(Gulo gulo) 

Regional Forester 

Sensitive 

Mixed Forest, High 

Elevations Unknown 

Pygmy Rabbit 

(Brachylagus idahoensis) 

Regional Forester 

Sensitive Sagebrush Flats No Habitat 

Townsend’s Big-Eared Bat 

(Plecotus townsendii) 

Regional Forester 

Sensitive 

Roost sites in buildings, 

caves and bridges Unknown 

Crater Lake Tightcoil Snail 

(Pristiloma arcticum 

crateris) 

Regional Forester 

Sensitive Riparian Unknown 

Silver-Bordered Fritillary 

(Boloria selene) 

Regional Forester 

Sensitive 

Wet meadows, marshes, 

bogs and more open parts 

of shrubby wetlands 

Unknown 

Johnson’s Hairstreak 

(Callophrys johnsoni) 

Regional Forester 

Sensitive 

Mostly in late and old 

structured coniferous 

forests with mistletoe 

presence 

Unknown 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Regional Forester’s Sensitive Species 

196

The Regional Forester’s Sensitive Species list was updated in January 2008 and Table 3-67 includes all 

animal species documented or suspected to occur on the Deschutes National Forest and their status 

within the BLT analysis area. 

After a review of existing records, habitat requirements, and existing habitat components, it was 

determined that the following sensitive species may have habitat present in the analysis area or are 

known to occur and will be included in this analysis: Northern bald eagle (Haliaeetus leucocephalus), 

Bufflehead (Bucephala albeola), Harlequin (Histrionicus histrionicus), American peregrine falcon 

(Falco peregrinus anatum), Tricolor blackbird (Agelaius tricolor), Lewis’ woodpecker (Melanerpes 

lewis), White-headed woodpecker (Picoides albolarvatus), Northern waterthrush (Seiurus 

aurocapillus), California wolverine (Gulo gulo), Townsend’s big-eared bat (Plecotus townsendii), 

Crater Lake tightcoil (Pristiloma arcticum crateris), Silver-bordered fritillary (Boloria selene), and 

Johnson’s hairstreak (Callophrys johnsoni). 

Summary of Conclusions for Sensitive Species 

1. There is no habitat present and/or the following species are not expected to occur within the 

analysis area and therefore, were not analyzed: horned grebe, red-necked grebe, pygmy rabbit, 

western sage grouse, and the yellow rail. 

2. The no-action alternative would not affect the bald eagle, bufflehead, harlequin, peregrine 

falcon, tricolor blackbird, Lewis’ woodpecker, white-headed woodpecker, Northern 

waterthrush, California wolverine, Townsend’s big-eared bat, Crater Lake tightcoil, Silverborder fritillary, and the Johnson hairstreak. 

3. The action alternatives “May Impact Individuals or Habitat” but will not likely contribute to 

a trend toward Federal listing for the white-headed woodpecker, California wolverine, Lewis’ 

woodpecker and Johnson’s hairstreak. 

4. The action alternatives would not affect the bald eagle, bufflehead, harlequin, peregrine falcon, 

tricolor blackbird, northern waterthrush, Townsend’s, big-eared bat, Crater Lake tightcoil, and 

the silver-bordered fritillary. 

Note: Where there was a “No Effect” or “No Impact” determination, it was concluded the BLT project 

either does not have the habitat for a particular species, or the zone of influence and its activities do not 

have the potential to overlap the biological needs of an individual, or a combination of both. It is not 

informative to discuss the incremental effects (cumulative) of past timber sales because they have been 

factored into the existing condition analysis and the assumption is their activities would not coincide 

with the implementation of the BLT project. For these reasons, the analysis of past actions other than 

those listed in this section is based on current environmental conditions. Cumulative or additive effects 

are discussed where they exist. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

197

Table 3-68. Summary of Conclusion of Effects to Region 6 Sensitive Animal Species 

Species Alt. A Alt. B Alt. C Alt. D 

Bald Eagle NI NI NI NI 

Horned Grebe NI NI NI NI 

Red-necked Grebe NI NI NI NI 

Bufflehead NI NI NI NI 

Harlequin Duck NI NI NI NI 

American Peregrine Falcon NI NI NI NI 

Tricolor Blackbird NI NI NI NI 

Lewis’ Woodpecker NI MIIH MIIH MIIH 

White-Headed Woodpecker NI MIIH MIIH MIIH 

Northern Waterthrush NI NI NI NI 

Western Sage Grouse NI NI NI NI 

Yellow Rail NI NI NI NI 

California Wolverine NI MIIH MIIH MIIH 

Pygmy Rabbit NI NI NI NI 

Townsend’s Big-Eared Bat NI NI NI NI 

Crater Lake Tightcoil Snail NI NI NI NI 

Silver-Bordered Fritillary NI NI NI NI 

Johnson’s Hairstreak NI MIIH MIIH MIIH 

NI = No impact 

MIIH = May impact individuals or habitat, but will not likely 

contribute to a trend toward Federal listing or loss of viability to the 

population or species 

BI = Beneficial impact 

The following species were determined not to occur in the analysis area based on a lack of existing 

sighting information, a review of habitat requirements and habitat types present in the analysis area. 

These species will not be included in any further analysis: Horned grebe (Podiceps auritus), Rednecked grebe (Podiceps grisgena), Western sage grouse (Coturnicops noveboracensis), Yellow rail 

(Coturnicops noveboracensis), and the Pygmy rabbit (Brachylagus idahoensis). 

The horned and red-necked grebes nest in lakes and ponds with tall vegetation or marshy habitats. The 

analysis area does not contain any lakes or ponds that could potentially provide nesting habitat for 

either species. While the horned grebe has been documented to occur on Big Lava Lake on the 

Deschutes National Forest (Marshall et al. 2003) there are no known breeding locations of either 

species on the forest. Implementation of any alternative would have “No Impact” on the horned grebe 

and red necked grebe. 

Western sage grouse are found in foothills, plains, and mountain slopes where sagebrush is present and 

the habitat contains a mixture of sagebrush, meadows, and aspen in close proximity. Winter habitat 

containing palatable sagebrush probably is the most limited seasonal habitat in some areas (NatureServe 

2008). While this habitat type and sage grouse are known to occur on the Deschutes National Forest, 

this habitat type does not occur within the analysis area or the Crescent Ranger District. 

Implementation of any alternative would have “No Impact” on the western sage grouse. 

From information gathered over the last 6-7 years, nesting habitat for the yellow rail in Oregon has 

been described as marshes or wet meadows which have an abundance of thin-leaved sedges, a layer of 

senescent vegetation to conceal their nests, and an average water depth of 7 cm. (Popper 2001). Winter 

habitat is thought to occur along the California coast although more research is needed to confirm this 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Regional Forester’s Sensitive Species 

198

(Popper 2001). A very small breeding population of yellow rails (2-5 pairs annually) is known to occur 

on Big Marsh on the Crescent Ranger District based on information gathered since 1997 (Popper 2004). 

Within the analysis area there is no suitable breeding habitat although the margins of Davis Lake 

contain marsh habitat. However, this marsh habitat is not sufficient in size, does not contain the 

necessary vegetative conditions or the consistent water depths conducive for breeding yellow rail 

habitat. Implementation of any action alternative would have “No Impact” on the yellow rail. 

Pygmy rabbits typically occur in dense stands of big sagebrush growing in deep loose soils 

(NatureServe 2008). This habitat type does not occur within the analysis area. Implementation of any 

alternative would have “No Impact” on pygmy rabbit. 

Northern Bald Eagle (Haliaeetus leucocephalus), R6 Sensitive, MIS

The northern bald eagle was officially de-listed as a Federal threatened species on August 8, 2007. The 

Federal Register (Vol. 72, No. 130/Monday July 30, 2007) stated the bald eagle has made a dramatic 

resurgence from the brink of extinction. The banning of DDT, coupled with cooperative conservation 

efforts of the Service, States, other Federal agencies, non-government organizations, and individuals, 

have all contributed to the recovery of our National symbol. While the bald eagle has been de-listed, 

they remain protected under the Bald and Golden Eagle Protection Act of 1940. This law prohibits the 

take, possession, sale, purchase, barter, offer to sell, transport, export or import, of any bald or golden 

eagle, dead or alive, including any part, nest, or egg, unless allowed by permit (16 U.S.C. 668(a); 50 

CFR 22). The U.S. Fish and Wildlife Service (2007) have prepared Bald Eagle Management 

Guidelines to help landowners, land managers, and others to meet the intent of this Act. In addition, 

monitoring of selected bald eagle nest sites will continue to occur including sites on national forest 

system lands. As of March 2008, a long-term monitoring strategy is being finalized. 

The Deschutes National Forest LRMP also provides direction for the management of habitat through 

the designation of Bald Eagle Management Areas (BEMAs). Management direction in the Deschutes 

LRMP for BEMAs permits small diameter thinning and timber harvest to achieve eagle habitat 

objectives. In catastrophic situations, all efforts are to be made to protect or create suitable eagle 

habitat (Deschutes LRMP M3-4, 5, 6, 7 pages 4-94). It also calls for protection of all existing nest, 

roost, and perch trees which are defined as 110 feet in height and 40 inches or greater in diameter 

(Deschutes LRMP M3-11, 12, page 4-95). Site specific BEMA plans have also been prepared by 

district personnel for nest sites near Wickiup Reservoir, Davis Lake, Crescent Lake, and Odell Lake. 

Ecology 

A detailed account of bald eagle habitat requirements can be found in the Pacific Bald Eagle Recovery 

Plan (USDI 1986). Bald eagle nesting territories are normally associated with lakes, reservoirs, or 

rivers. Nests are usually located in large conifers in uneven-aged, multi-storied stands with old-growth 

components (Anthony et al. 1982). Nest trees usually provide an unobstructed view of the associated 

body of water. Live, mature trees with deformed tops are often selected for nesting. East of the 

Cascade Mountains in Oregon, bald eagles prefer nesting in ponderosa pine trees that average 46 inches 

in diameter (range 21-76 inches) and tend to be larger than the surrounding trees (Anthony et al 1982). 

Existing Condition 

Table 3-69 displays the results of nesting surveys conducted on the Crescent Ranger District by Frank 

Isaacs (Isaacs and Anthony 2007) and by district personnel over the last 10 years. Nesting surveys 

were conducted in the spring of 2008 to contribute to post de-listing monitoring data. 
Environmental Impact Statement BLT Project 

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Table 3-69. Bald Eagle Nest Territories and Historical Nesting Status (1998-2007) for Territories 

on the Crescent Ranger District 

Territory 

Name 

Year 

First 

Located 

Status 

2008 

Status 

2007 

Status 

2006 

Status

2005 

Status

2004 

Status

2003 

Status 

2002 

Status 

2001 

Status

2000 

Status

1999 

Round 

Swamp 1971 oF oF oF 1 2/s 2,ND/n* 2 F oF 2 

Wickiup 

South 1978 1 1 1 2 2 oF oF oF oF oF 

Lava Flow 1993 oF oF 1 oF oF 1 2 2 1 1 

Davis SE 1971 1 2 oF 2 1/s 2/n oF *2 2 F 

Davis W 985 oF oF 1 1 2 1 1 al al al 

Davis NW 1973 oF oF 1 2 *oF 1/n oF 1 F oF 

Odell SE 1976 oF 2 1 1 1 F 1 oF oF 2 

Odell 

Creek/Resort 

Ridge 

2004 oF oF oF 2 2 

Triple 

Thunder 1995 oF oF 2 2 1 oF 2 1 1 al 

Odell NE 1979 oF oF 1 oF oF oF NL NL NL 2 

Odell NW 1976 oF oF 1 oF 1 *2d F/j 2 1 1 

Pengra Pass 1998 2 1 2 1 1 2 2 1 F 1 

Pebble Bay 1997 oF 2 2 oF oF 2 2/j 2 1 1 

Chinquapin 

Point 2006 oF 1 oF 

Odell/Hwy 

58 2007 oF 1 

Crescent 

Lake 1978 oF 1 oF oF F oF 1 F F 2 

Tranquil 

Cove 2002 oF 2 oF 2 1 2d 1 

Total Young 4 13 13 16 14 15 14 11 6 12 

(Compilation from Isaacs and Anthony 2006 and Survey Results from 2007) 

1or 2 = # young produced 2/n = 2 young, nest burned in a fire 

oF = site occupied, nest failed F = failed nesting 

NL = nest not looked for or not located 2,ND/n* = 2 young, nest down burned in a fire 

1/s = 1 young, nest tree 100% dead RT = red-tailed hawk occupied the nest 

2/j = 2 young, camera installed after nesting season al = alternate nest 

*2 = 2 young, nest rebuilt since last observation 

In addition to nest site monitoring, a mid-winter survey is conducted in early to mid-January of each 

year to estimate the number of bald eagles wintering on Crescent Lake, Odell Lake and Davis Lake. 

Over the last 5 years, the annual mid-winter count of bald eagles has ranged from a low of 16 in 2005 to 

a high of 27 birds in 2004. 

Within the BLT analysis area there are no designated BEMAs and no known bald eagle nests on 

national forest system lands. The Viable program estimated there to be approximately 5,674 acres of 

forest with trees exceeding 30 inches in diameter that could provide a potential nest tree. This figure 

accounts for all past and present timber sales, natural events such as wildfire, and any other habitataltering activity that would express itself in a vegetative manner. This way of presenting this 

information is the most informative manner for the decision maker. Incidental bald eagle observations 

have been noted in the upper Little Deschutes River canyon (Powers, pers. comm. 2005) although it is 

unlikely this area would support a nesting pair. This conclusion is reached based on the apparent lack 

of a sustainable food supply. While the Little Deschutes River does contain brook and brown trout, the 
BLT Project Environmental Impact Statement 

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numbers of fish and difficulty in catching them may prevent the establishment of a territory. There are 

also no lakes or ponds in the analysis area that could provide a more dependable and well-stocked 

forage base. The nearest nesting bald eagle territory and BEMA is located on the east side of Crescent 

Lake approximately three miles west of the analysis area boundary. 

Effects Common to All Alternatives 

Direct and Indirect Effects 

Because there are no known bald eagle nests or designated BEMA acreage within the analysis area, the 

selection of any alternative is not expected to have adverse effects on bald eagles. While random 

observations of bald eagles have occurred along the Little Deschutes River, there is no evidence 

sightings are anything other than incidental. There are also no known roost sites within the analysis 

area. Based on the information available, the selection of any alternative would have “No Impact” on 

the bald eagle or their habitat. 

Consistency with the Programmatic Biological Assessment 

The Deschutes and Ochoco National Forests completed a Joint Aquatic and Terrestrial Programmatic 

Biological Assessment for Federal Lands within the Deschutes and John Day River Basin’s 

administered by the Deschutes and Ochoco National Forests in August 2006. At the time of document, 

the northern bald eagle remained Federally listed as a threatened species. Current direction is to 

continue to incorporate the Project Design Criteria (PDCs) to limit effects to bald eagles. The PDCs for 

the northern bald eagle were reviewed in relation to the BLT project as proposed and were determined 

to be consistent. The project is also consistent with the National Bald Eagle Management Guidelines 

(USFWS 2007). 

 

Bufflehead (Bucephala albeola) , R6 Sensitive, MIS

Ecology 

The bufflehead is North America’s smallest diving duck. It winters throughout Oregon but is an 

uncommon breeder in the central and southern Cascades (Marshall 2003). Known nest sites in central 

and southern Oregon include Hosmer Lake, Crane Prairie Reservoir, Twin Lakes, Wickiup Reservoir, 

Davis Lake and along the Little Deschutes River in Deschutes County. Broods have also been reported 

in small lakes near the crest of the Cascades in western Deschutes County. The bufflehead will use 

tree cavities or artificial nest boxes in trees close to water. Human disturbance at Cascade lakes and a 

shortage of suitable nesting cavities due to forestry practices may have had an impact on their 

population status in Oregon (Marshall et al. 2003). 

Existing Condition 

On the Crescent Ranger District buffleheads are commonly seen on Odell Lake, Crescent Lake, Davis 

Lake, and on the nearby Wickiup Reservoir nearly year-round or until freeze-up. They have also been 

observed on some of the high elevation lakes and ponds in the Oregon Cascades Recreation Area 

during the summer months. There are no reports of buffleheads within the BLT analysis area and no 

surveys have been conducted to determine their presence. 

It is unknown if suitable snag habitat for nesting is present on private lands that border the Little 

Deschutes River. Most of the acreage is industrial timberlands where commercial activities have taken 

place in the last 6-7 years. If snag habitat is currently present, it may not be there for the long-term. 

Also, past vegetation management practices including felling of hazard trees and regeneration harvest 

likely reduced snag densities along the Little Deschutes River corridor. 

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would not affect snag habitat that may be used by this species. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

201

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

Because buffleheads are dependent on tree cavities or artificial nest structures for nesting purposes, the 

removal of snag habitat near lakes or reservoirs have the potential to negatively impact this species. 

There is only one activity unit within the riparian reserve zone which has a prescription for small 

diameter thinning and underburning in close proximity to a subdivision. Typically, these activities 

create snags and potentially increase the size of future snags, rather than removing them. Chapter 2 

includes Project Design Criteria and measures for all snag and cavity dependent species. 

Implementation of this measure would assure snag habitat is present for all cavity-nesting species 

including the bufflehead. 

 

Determination 

Because no activities in the BLT analysis area have potential to remove snags in riparian reserves along 

the Little Deschutes River, or any other body of water, and Project Design Features have been 

incorporated to maintain snags in the uplands, it is determined implementation of the BLT project 

would have “No Impact” to the bufflehead. 

Harlequin Duck (Histrionicus histrionicus), R6 Sensitive, MIS

Ecology 

The harlequin duck nests along fast-flowing rivers and mountain streams in the Cascade Mountains of 

Oregon and Washington. There are no confirmed breeding sites in the east Cascades of Oregon with 

the exception of the Hood River basin (Marshall et al. 2003). Harlequin broods have been documented 

though in northeast Oregon. In the western Cascades of Oregon, breeding pairs are observed on low to 

moderate gradient (1-7 percent) third to fifth-order streams in the western hemlock zone with simple 

channels and abundant in-stream rocks for loafing sites (Marshall et al. 2003). Nests are scooped 

depressions lined with down feathers. Bruner (1997 in Marshall et al. 2003) stated 35 percent of his 

located nests were placed on exposed shelves of logs or root wads and 65 percent were found on natural 

ledges on slopes or cliffs within 1-82.5 feet of water. On the breeding range foraging occurs on stream 

invertebrates such caddis flies and stoneflies. Non-breeding adults can be found along the Oregon coast 

and the winter population includes migrant birds. They are often seen resting on rocks at high tide and 

feeding about exposed rocks at low tide (Gilligan et al. 1994). Threats to the species may include 

recreation-related disturbances and oil spills. Direct effects of timber harvesting, mining, road building 

or other activities have not been documented (Marshall et al. 2003). 

Existing Conditions 

Potential breeding habitat may exist on the Crescent Ranger District in the upper Little Deschutes River 

canyon and perhaps in Trapper Creek which flows into Odell Lake. At the present time, there are no 

documented sightings of harlequin ducks on the Crescent District although there have been no 

formal surveys conducted by district personnel to determine their presence. It is unknown if the 

private lands that border the Little Deschutes River provide any potential nesting or rearing habitat for 

harlequins. 

Effects Common to All Alternatives 

Potential breeding habitat in the planning area may occur in the upper Little Deschutes River canyon. 

The BLT project proposes only one activity unit within the riparian zone located adjacent to the Two 

Rivers subdivision. Although there is a lack of breeding information in the east Cascades, due to the 

extensive human use that occurs in proximity to the subdivision, it is unlikely to function as nesting 

habitat for this species. The underburning proposed in unit #1061 is designed to rejuvenate decadent 

willows within the riparian zone, and may potentially improve nesting habitat. This activity or any 

other within the BLT analysis area would not reduce the current available habitat for this species. 
BLT Project Environmental Impact Statement 

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Determination 

Because this project would not affect available habitat, and the lack of documented sightings, 

implementation of the BLT project has been determined to have “No Impact” on the harlequin duck or 

its habitat. 

American Peregrine Falcon (Falco peregrinus anatum), R6 Sensitive, MIS

The peregrine falcon was officially de-listed as a threatened species by the USFWS on August 25, 

1999, although the species currently remains on the Northwest Regional Forester’s sensitive species 

list. At the present time, known eyries in the region are being monitored annually for occupancy and 

reproductive success. 

Ecology 

In Oregon, peregrines occur as resident and migratory populations. They nest on cliffs greater than 75 

feet in height and within 1 mile of some form of water (Pagel 1992). Nesting occurs in xeric areas of 

eastern Oregon, marine habitats of western Oregon, montane habitats to 6,000 feet elevation, small 

riparian corridors statewide, and (more recently) urban habitats of the lower Willamette and Columbia 

Rivers. Riparian corridors are used for travel and as hunting areas (90-95 percent of all prey items are 

birds that may come from these systems, Pagel 1992). Peregrine falcons are most susceptible to 

disturbance during the onset of their courtship activities. Land management activities which the falcons 

are not accustomed to during the preliminary phase of their nesting chronology could induce desertion 

of the site (Pagel 1992). 

Existing Conditions 

District wildlife sighting records list one peregrine report from Davis Lake during the fall however this 

may have been a migrant. Clowers (2004) reported seeing an adult peregrine hunting near Wickiup 

Dam (outside the analysis area) during the late winter of 2003-2004 and 2 fledgling peregrines hunting 

near Reservoir Campground on Wickiup Reservoir in August 2004. Potential nesting habitat may be 

present on the Crescent Ranger District in the lava flow near Davis Lake, in the upper Little Deschutes 

River canyon (BLT analysis area), and on Maiden Peak in the OCRA. One survey for nesting 

peregrines was conducted in April 2005 on the lava flow near Davis Lake but no peregrines were 

observed. As of August 2008, there is only one known eyrie on the Deschutes National Forest located 

on the Sisters Ranger District. As of April 2008, there are no documented observations of peregrines 

in the BLT analysis area. 

Effects Common to All Alternatives 

The nearest potentially suitable eyrie habitat to proposed treatment units is located in the upper Little 

Deschutes River canyon west of Hemlock Butte. The nearest activity units (#1260 and #1310) are 

approximately 1 mile to the east of the cliff habitat on the north side of the Little Deschutes River. 

Harvest and post-sale activities on both units would not require moving closer to the cliff sites. Even if 

individuals were present, based on this spatial distance there should be no direct, indirect or cumulative 

negative impacts to nesting peregrines, if present in the upper Little Deschutes River canyon. If an 

eyrie is discovered before or during any management activity, the activity would be reviewed for 

potential disturbance to nesting peregrines and the activity halted from February 15 – August 15 as 

needed (Project Design Feature, Chapter 2). There is no cliff habitat present on private lands in the 

analysis area that could provide suitable nesting habitat. 

 

Determination 

Because of the spatial proximity of activity from potential nesting habitat and the lack of documented 

sightings, the BLT project has been determined to have “No Impact” on the peregrine falcon or its 

habitat. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

203

Tricolored Blackbird (Agelaius tricolor), R6 Sensitive

Ecology 

The Tricolored blackbird is a highly gregarious colonial breeder largely endemic to California. 

However, breeding colonies are scattered and intermittent in Oregon. In Oregon they breed most 

consistently in southern Klamath County in the southern part of the state. There are no records of 

nesting Tricolored blackbirds in Deschutes County or northern Klamath County. Nesting occurs in 

fresh-water marshes of cattails, tules, bulrushes and sedge, or in thickets of willows or other shrubs. 

Most birds in Oregon migrate to California for the winter. Threats to this species include habitat loss 

due to drainage of wetlands and conversion of former nest and roost sites to agriculture. Human 

disturbance has also been implicated in nesting colony abandonment or failure (Marshall et al. 2003). 

The Oregon population was estimated to have declined by 22 percent in the 1980s but the Oregon 

population represents only 1 percent of the total tricolored blackbird population (Beedy et al. 1999). 

The species currently holds rankings in Oregon as SP sensitive (peripheral or naturally rare) and by the 

Natural Heritage program as G3 Vulnerable – either rare throughout its range or found locally in a 

restricted range. 

Existing Condition

There are no documented sightings of tricolored blackbirds on the Crescent Ranger District although 

potentially suitable nesting habitat is present within and outside the analysis area. The Little Deschutes 

River corridor with it expanses of dense willow thickets may represent suitable nesting habitat in the 

BLT area. There have been no formal surveys conducted to confirm the presence of tricolored 

blackbirds in the analysis area or Crescent District. Willow thickets are also present along the private 

land segments of the Little Deschutes corridor. Tricolored blackbirds have not been reported on these 

lands. 

Effects Common to All Alternatives 

With the exception of unit #1061 no other activities would occur within the riparian reserve where this 

species may potentially occur. Unit #1061 has a prescription to thin lodgepole pine less than 6 inches 

diameter and spot burn some patches of willow that are decadent to rejuvenate them. This unit is not 

currently considered suitable habitat but has the capability if the willow community becomes reestablished along Hemlock Creek. 

Determination 

Because no suitable habitat would be affected, and that implementation of activities in unit #1061 may 

potentially increase suitable nesting habitat, it has been determined the BLT project would have “No 

Impact” to the Tricolored blackbird. 

Lewis’ Woodpecker (Melanerpes lewis), R6 Sensitive, MIS

Ecology 

This woodpecker is a medium-sized, vaguely crow-like bird that relies on fly catching during the spring 

and summer and stores nuts and fruits in the fall (Marshall et al. 2003). It breeds in low numbers in 

open habitats along eastern Oregon river and stream valleys including the lower Deschutes River. The 

species is most common in open habitats (e.g. burns) in and near Cascade forests. Wisdom (2000) 

reported that burned ponderosa pine forests created by stand-replacing fires provide highly productive 

habitats as compared to unburned pine. They are not considered strong cavity excavators, but require 

large snags in an advanced stage of decay that are easier to excavate. Lewis’s woodpeckers will also 

use old cavities created by other woodpeckers. Forty-two percent of the nest trees on the eastern edge 

of the Mt. Hood National Forest were in ponderosa pine (typically snags) and 43 percent were in living 

and declining Oregon white oak. The mean dbh of nest trees was 26 inches and mean nest tree height 

was 41 feet (Marshall et al. 2003). Haggard and Gaines (2001) determined that the Lewis’ woodpecker 

was most abundant in low snag density stands within a stand replacement fire study conducted on the 

Wenatchee National Forest in Washington. Marshall et al. (2003) reports the species is declining 
BLT Project Environmental Impact Statement 

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throughout its range possibly due to loss of suitable habitat, competition for nest holes and the effects of 

pesticides. 

Existing Condition 

The Viable Ecosystem model was used to map suitable nesting habitat defined as open forested stands 

with less than 40 percent canopy in the lodgepole pine and dry ponderosa pine PAGs with trees greater 

than 9 inches in diameter. There is an estimated 2,194 acres of this habitat in the analysis area, the 

majority of which is present on National Forest system lands. This figure accounts for all past and 

present timber sales, natural events such as wildfire, and any other habitat-altering activity that would 

express itself in a vegetative manner. This way of presenting this information is the most informative 

manner for the decision maker. 

 

Privately owned timberlands likely have few stands with trees greater than 9 inches diameter that could 

provide habitat for this species. The Muttonchop Fire of 2000 (within the analysis area) was a stand 

replacement event on a ponderosa pine dominated site. This, as well as all other past activity is 

accounted in this discussion. No salvage harvesting was conducted and represents an approximate 80 

additional acres of potential nesting habitat. There are no records of Lewis’ woodpeckers being in the 

analysis area, although a nesting pair was confirmed in the Davis Fire are in July 2008. The 

minimal number of acres of habitat is primarily due to most ponderosa pine stands being densely 

stocked and not providing the more open forest this species selects for nesting. 

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would likely have no impact on the Lewis’ woodpecker for the shortterm. This alternative would forego the opportunity to reduce stand densities in ponderosa pine stands 

to increase the amount of suitable nesting habitat for this species. Over time, as currently existing 

nesting habitat increases in stand density and canopy cover there would likely be a reduction in habitat 

capability to support this species within the analysis boundary until a disturbance event, such as a 

wildfire or large scale loss to insects, occurs. The determination for this alternative is for “No Impact” 

to the Lewis’ woodpecker. 

Effects Common to All Action Alternatives 

Commercial thinning and post-sale activities including small tree thinning and slash piling and disposal 

would occur within potential Lewis’ woodpecker nesting habitat on 264 acres (12 percent of the total) 

in Alternative B, 214 acres (10 percent of the total) in Alternative C, and 78 acres (4 percent of the 

total) in Alternative D. Prescribed underburning in ponderosa pine stands would occur on 2,312 acres 

(Alternative B), 1,764 acres (Alternative C) and 824 acres (Alternative D). Because these activities 

would not reduce existing snags where they occur, except for incidental felling for occupational safety, 

temporary road construction, or for decking logs, this habitat feature would remain in place. This 

species, as well as the white-headed woodpecker, favor open ponderosa pine stands with large trees and 

stands. The most limiting factor is available habitat. Activities would focus on understory removal 

retaining the largest trees. This would maintain their capability to support Lewis’ woodpeckers. 

Because Alternative B would conduct the largest amount of thinning and prescribed underburning 

(which has the potential to create snags), this alternative would likely have the greatest long-term 

benefit to the species. Lowering the existing canopy cover increases the length of time this habitat 

would remain suitable nesting habitat. Post-sale, prescribed underburning plans are required and would 

include a measure for protection of existing snags, particularly those greater than 15 inches in diameter 

(Project Design Features, Chapter 2). This measure has been shown to be effective and is monitored for 

each prescribed burn where snags large enough to be protected are present. 

Timber harvest and spring underburning have the potential to disrupt nesting pairs of Lewis’ 

woodpeckers. This is considered a short term impact (1-5 years). Because less than 12 percent (264 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

205

acres Alt. B) of the potentially suitable nesting habitat would be impacted by planned activities, 

undisturbed nesting habitat would be maintained within the analysis area. Overall, the BLT project 

should result in improved habitat conditions for this species, especially as a result of maintaining a 

lower canopy cover and reduced shrub levels in ponderosa pine habitats. 

Viable outyear modeling was conducted to determine changes in suitable nesting acreage at 10 years, 

20 years and 50 years. All alternatives showed an increase in suitable nesting habitat acreage over each 

decade and the difference between alternatives in any decade was less than 50 acres. It was projected 

suitable nesting acreage would increase from an existing 2,194 acres to 4,788 to 4,831 acres at 50 years, 

depending on the alternative. This determination was based on silvicultural prescriptions, expected 

increased vigor from thinning and the probability of advancing to the next successional stage. Overall, 

the BLT project would result in improved habitat conditions for the Lewis’ woodpecker especially as a 

result of maintaining a lower canopy cover and reduced shrubs in ponderosa pine habitats. 

Altman (2000) in the Landbird Conservation Strategies for the East-Slope Cascades recommended the 

retention of at least 1 ponderosa pine snag per acre at least 40 feet tall and 30 inches dbh and an open 

overstory with mean canopy closure less than or equal to 40 per cent. The PDCs and mitigation 

measures in Chapter 2 prescribe even higher levels. The BLT project is consistent with Altman’s 

recommendations for the Lewis’ woodpecker. 

Determination 

The Lewis’ woodpecker has not been documented within the analysis area. However, because harvest 

and/or underburning may occur during the nesting season and result in disturbance to nesting pairs, 

implementation of any action alternative “May impact individuals or habitat, but will not likely 

contribute to a trend toward Federal listing or cause a loss of viability to the population or 

species” for the Lewis’ woodpecker.

Cumulative Effects 

Table 3-1 was reviewed for projects that overlap in time and space and have the same zone of influence. 

The zone of influence for this species is the 80,000 acre Upper Little Deschutes 5th field watershed 

because home ranges are relatively small and the project is the best scale to assess potential additive 

effects. Recently completed projects from the Baja 58 EA and the 5825 Fuels Reduction Project have 

focused on understory tree reduction and underburning that overlap with the BLT analysis area. 

Collectively these projects have resulted in improved habitat conditions for this species. Ongoing 

projects such as Maintenance Burn CE, Prescribed Underburning and Mowing Project, and the Rosedell 

CE are also improving ponderosa pine habitats for the Lewis’ woodpecker. While some of these 

projects may overlap the BLT analysis area and may disturb some individuals, this affect is much more 

offset by the increasing trend for improving and maintaining available habitat within the watershed. 

White-Headed Woodpecker (Picoides albolarvatus), R6 Sensitive, MIS

Ecology 

The white-headed woodpecker is a medium-sized bird and unique because of striking plumage with a 

mostly white head and males having a red patch on the nape. They are a resident of montane forests 

from southern interior British Columbia south through central Washington, northern Idaho, east and 

southwest Oregon, north and central California, and the eastern edge of central Nevada to the 

mountains of southern California (Marshall et al. 2003). The presence of late- and old-structured pine 

is thought to be important to white-headed woodpeckers. Larger diameter pines provide bark crevices 

for the invertebrate prey of white-headed woodpeckers and are good cone producers. During the winter 

months, white-headed woodpeckers rely on seeds from ponderosa pine and sugar pine. Older stands 

also have greater densities of the large-diameter snags that white-headed woodpeckers appear to select 

for nesting (Frenzel 2002). He also reported that the presence of sugar pine may be important at high 

elevation sites as an alternate food source. They usually excavate nest cavities in snags, but other 
BLT Project Environmental Impact Statement 

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recorded substrates include stumps, leaning logs, and the dead tops of live trees. Frenzel’s study area 

on the Deschutes and Winema National Forests (2002) determined that nest trees ranged from 23.6 to 

118.1 cm (9-46 inches) with an average of 27 inches. Eighty nine (89) percent of the nest trees were in 

ponderosa pine. He also measured canopy closure at the nest tree which ranged from 0 to 57 percent 

with a mean of 13 percent. 

Frenzel (2002) concluded population recruitment for this woodpecker was insufficient to offset 

mortality in his study areas on the Deschutes and Winema National Forests. He also reported that shrub 

growth and increased understory tree densities from fire exclusion policies may be factors affecting 

levels of mammalian nest predation and vulnerability of adults to avian predation. Marshall et al. 

(2003) stated that the long-term stability of this woodpecker in Oregon and Washington appears to rest 

with reversing the declining health of ponderosa pine forests. 

Existing Condition 

The Viable Ecosystem model estimated there are approximately 1,686 acres of ponderosa pine, white 

fir and Shasta red fir with the presence of ponderosa pine greater than 15-20 inch diameter with an open 

canopy condition defined as suitable nesting habitat. This figure accounts for all past and present 

timber sales, natural events such as wildfire, and any other habitat-altering activity that would express 

itself in a vegetative manner. This way of presenting this information is the most informative manner 

for the decision maker. 

This habitat is mostly located on National Forest system lands in the Little Deschutes River canyon, 

Muttonchop Butte, Bunny Butte, and near Little Odell and Odell Buttes. Mapping also shows some 

suitable nesting habitat along the Little Deschutes River on private lands north of the community of 

Crescent, Oregon although this has not been field verified. The Baja 58 EA analysis (USDA 1998) and 

its timber sales that overlap with the BLT analysis area conducted some silvicultural and fuels activities 

that likely benefited this species. As of April 2008, there have been no surveys conducted to determine 

species presence and distribution across the analysis area. District records report one white-headed 

woodpecker observation on private land north of Highway 58 and south of the Little Deschutes River. 

 

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would likely have no effect in the short-term on the white-headed 

woodpecker. This alternative would forego the opportunity to reduce stand densities in ponderosa pine 

stands to increase the amount of suitable nesting habitat. Over time, as nesting habitat decreases in 

stand density and canopy cover, there would likely be a reduction in habitat capability to support this 

species within the analysis boundary. The determination is “No Impact” to the white-headed 

woodpecker. 

Effects Common to All Action Alternatives 

The Viable Ecosystem Model estimated there are 1,686 acres of nesting habitat for the whiteheaded woodpecker in the analysis area. This is based on tree size classes and appropriate PAGs 

typically selected for nesting white-headed woodpeckers. Table 3-70 displays the range of 

tolerance intervals based on snag levels taken from DecAID. For snags greater than 10 inches in 

diameter, 33 percent of the habitat is less likely to support nesting individuals (less than 30 percent 

tolerance interval) while 67 percent of the habitat is more likely to support nesting individuals (30-

80 percent tolerance interval) based on snags greater than 10 inches in diameter. For snags greater 

than 20 inches in diameter, 58 percent of the analysis area is less likely to support nesting 

individuals (30 percent tolerance interval) while 42 percent of the analysis area is more likely to 

support nesting individuals (30-80 percent tolerance interval). Project Design Features (Chapter 2) 

disclose the limited circumstances where snag felling may be needed during project 

implementation. 
Environmental Impact Statement BLT Project 

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Table 3-70. Tolerance Intervals for White-headed Woodpeckers 

White-headed 

Woodpecker 1,686 

Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 30% 30-50% 50-80% 80%+

Density 

(#/hectare)* 0-0.7 0.7-2.2 2.2-10.6 10.6+ 0-1.1 1.2-4.4 4.4-9.4 9.4+

Density (#/acre)* 0-0.3 0.3-1.9 1.9-4.3 4.3+ 0-0.5 0.5-1.8 1.8-3.8 3.8+

% of Habitat 32.6% 4.2% 32.7% 30.5% 58.3% 28.4% 10.2% 3.1%

Acres 550 71 551 514 984 478 172 52

Density of Snags = 10" dbh

 by tolerance interval

Density of Snags = 20" dbh 

by tolerance interval

*From DecAID 2.0 Tables PPDF_S/L.sp-22, EMC_S/L.sp-28, EMC_O.sp-22, and PPDF-O.sp-22. Information 

synthesized from various studies. These numbers should be used with caution as these data are from a population 

that is likely declining because adult mortality is higher than recruitment of young (Frenzel 2004), snag densities may 

or may not be contributing. (DecAID PPDF Narrative)

Commercial thinning and post-sale activities include small tree thinning and slash piling and disposal 

would occur within white-headed woodpecker nesting habitat on 139 acres (8 percent of the total) in 

Alternative B, 127 acres (8 percent of the total) in Alternative C, and 48 acres (3 percent of the total) in 

Alternative D. Prescribed underburning in ponderosa pine stands would occur on 2,312 acres 

(Alternative B), 1,764 acres (Alternative C) and 824 acres (Alternative D). Because these activities 

would not reduce existing snags where they occur, except for incidental felling for occupational safety, 

temporary road construction, or for decking logs, this habitat feature would remain in place. This 

species, as well as the Lewis’ woodpecker, favor open ponderosa pine stands with large trees and 

stands. The most limiting factor is available habitat. Activities would focus on understory removal 

retaining the largest trees. This would maintain their capability to support white-headed woodpeckers. 

Because Alternative B would conduct the largest amount of thinning and prescribed underburning 

(which has the potential to create snags), this alternative would likely have the greatest long-term 

benefit to the species. Lowering the existing canopy cover increases the length of time this habitat 

would remain suitable nesting habitat. Post-sale, prescribed underburning plans are required and would 

be include a measure for protection of existing snags, particularly those greater than 15 inches in 

diameter (Project Design Features, Chapter 2). This measure has been shown to be effective and is 

monitored for each prescribed burn where snags large enough to be protected are present. 

Timber harvest and spring underburning have the potential to disrupt nesting pairs of white-headed 

woodpeckers. This is considered a short term impact (1-5 years). Because less than 8 percent (139 

acres Alt. B) of the potentially suitable nesting habitat would be impacted by planned activities, 

undisturbed nesting habitat would be maintained within the analysis area. Overall, the BLT project 

would result in improved habitat conditions for this species, especially as a result of maintaining a 

lower canopy cover and reduced shrub levels in ponderosa pine habitats. 

Viable Ecosystem outyear modeling was conducted to determine changes in suitable nesting acreage at 

10 years, 20 years and 50 years. All alternatives were relatively similar across the decades and show an 

increase of approximately 250 acres at the 50 year mark as compared to the existing condition. This 

determination was based on silvicultural prescriptions, expected increased vigor from thinning and the 

probability of advancing to the next successional stage. 

Altman (2000), in his Landbird Conservation Strategies recommended that for white-headed 

woodpeckers, ponderosa pine stands have at least 10 trees per acre at least 21 inches dbh of which 2 

should be greater than 31 inches. There should be at least 1.4 snags per acre at least 8 inches with 50 
BLT Project Environmental Impact Statement 

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208

per cent having decay and an overall mean canopy closure of 10-40 per cent. These conditions will be 

met where they occur consistent with Altman’s recommendations. 

 

Determination 

Because harvest and/or underburning may occur during the nesting season and result in disturbance to 

nesting pairs, implementation of any action alternative “May impact individuals or habitat, but will 

not likely contribute to a trend toward Federal listing or cause a loss of viability to the population 

or species” for the white-headed woodpecker. 

Cumulative Effects 

Table 3-1 was reviewed for projects that overlap in time and space and have the same zone of influence. 

The zone of influence for this species is the 80,000 acre Upper Little Deschutes 5th field watershed 

because home ranges are relatively small and the project is the best scale to assess potential additive 

effects. Recently completed projects from the Baja 58 EA and the 5825 Fuels Reduction Project have 

focused on understory tree reduction and underburning that overlap with the BLT analysis area. As 

disclosed for the Lewis’ woodpecker, collectively, these projects have resulted in improved habitat 

conditions for this species. Ongoing projects such as Maintenance Burn CE, Prescribed Underburning 

and Mowing Project, and the Rosedell CE are also improving ponderosa pine habitats for the Lewis’ 

woodpecker. While some of these projects may overlap the BLT analysis area because they may 

disturb some individuals, this affect is much more offset by the increasing trend for improving and 

maintaining available habitat within the watershed. For these reasons, the analysis of past actions other 

than those listed in this section is based on current environmental conditions. 

 

While BLT and overlapping projects may result in some short-term displacement of individuals and 

pairs due to disturbance from harvest and/or prescribed burning activities, there would be no loss of 

nesting habitat. This is the result of snags being retained except where log landings and temporary 

roads would be located. In addition, prescribed burning plans are prepared that require the retention of 

snags (Project Design Features, Chapter 2). Consequently, there are no past, present, or foreseeable 

actions that have additive effects. 

Northern Waterthrush (Seiurus aurocapillus), R6 Sensitive

Ecology 

The northern waterthrush is a small neotropical migrant that travels long distances nocturnally. 

Breeding habitat in North America includes Alaska and west to east across Canada extending into New 

England, the Mid-Atlantic States, the Great Lakes region, Montana, Idaho, North Dakota (NatureServe 

2008) and a small area in the central Cascades of Oregon. It winters in the West Indies and Central and 

South America. The species has been known to occur along Crescent Creek and the Little Deschutes 

River near the communities of Crescent and Gilchrist, Oregon, since 1977 (Contreras 1988). Marshall 

et al. (2003) states the northern waterthrush is one of Oregon’s rarest and most local breeders. 

Occupied sites during the breeding season have also been identified at Salt Creek and Gold Lake on the 

Willamette National Forest (Contreras 1988). The birds in central Oregon seem to prefer dense riparian 

willow thickets and were usually found in willow clumps 5 to 8 feet high, with some Sitka alder 

intermixed with small grassy patches and pools of water left in old stream meanders, although no nests 

have been found (Contreras 1988). Clutch size is 4 to 5 eggs sometimes 3 to 6 (NatureServe 2008). 

Mean territory size on breeding grounds ranges from 0.5-1.0 hectares (1.3-2.5 acres). 

NatureServe (2008) lists the northern waterthrush as G5, globally secure and populations seem to 

holding steady and may be increasing in some regions. Survey-wide North American Breeding Bird 

Survey (BBS) showed no population trend, but in western North America, data indicated a significant 

increase. In Oregon, the species is listed as S2, Imperiled. Threats to the species include pesticides and 

contaminants including spraying to control spruce budworm outbreaks. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

209

Existing Condition 

Potentially suitable breeding habitat in the analysis area extends southward along the Little Deschutes 

River at least to Highway 58 and potentially beyond. In 2004, approximately a one mile segment of the 

Little Deschutes River system was burned in the Little Deschutes Fire. This included the temporary 

loss of the dense mature willow community. While some loss of nesting habitat may have occurred, the 

willows have since regenerated and would likely provide suitable nest substrate in several more years. 

It is unknown if the willow community on private lands would be impacted by individuals’ actions, 

consequently it is also unknown to what extent private lands would contribute to providing habitat for 

this species in the short- or long-term.

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would result in no immediate change in vegetative conditions for this 

riparian associated bird species. In central Oregon, including the analysis area, dense willow clumps 

that are currently present along Crescent Creek and the Little Deschutes River would continue to 

provide breeding habitat unless wildfires impact the riparian zones. The determination is “No Impact” 

to the Northern waterthrush. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

All three alternatives propose one activity unit within the riparian reserves (unit #1061) located on the 

west side of the Two Rivers subdivision and adjacent to Hemlock Creek. The objective for this unit is 

to remove lodgepole pine less than 3 inches in diameter and spot burn decadent willows. Neither 

activity would have a deleterious effect on the waterthrush because neither is currently providing 

nesting habitat. However, the spot burning would rejuvenate the willows and may provide additional 

dense willow nesting habitat in six to eight years. Implementation of any action alternative would not 

result in any loss of habitat for the species. 

Determination 

It is determined implementation of Alternatives B, C, or D would result in “No Impact” to the northern 

waterthrush. 

Cumulative Effects 

There are no overlapping or additive effects to the BLT project. However, there are several foreseeable 

actions that are designed to improve waterthrush suitable habitat within the BLT analysis area. The 

Spruce Creek Riparian Rehabilitation project proposes to conduct 100 acres (on one mile of stream) of 

lodgepole pine removal (less than 3 inches in diameter) beginning in the spring and summer of 2009 if 

funding is available. Currently, dense willow clumps are lacking in the Spruce Creek area due to a 

lower water table and old age. Spot burning and caging of willows is also proposed. Over the longterm, this may increase the amount of willow clumping needed for nesting by the waterthrush. 

California Wolverine (Gulo gulo), R6 Sensitive

On March 11, 2008, the USFWS announced a 12-month finding that the population of North American 

wolverine occurring in the contiguous United States does not constitute a listable entity under the 

Endangered Species Act and listing is not warranted (Federal Register/ Vol. 73, No. 48/ Tuesday, 

March 11, 2008). The Service determined that the contiguous United States population of North 

American wolverine does not constitute a distinct population segment (DPS) under the Act and 

therefore a listable entity unto itself. They also found that the contiguous United States population of 

the North American wolverine is not a significant portion of the range of the North American 

subspecies and does not warrant further consideration under the Act. This review was initiated as a 

result of a complaint filed by Defenders of Wildlife and others in September 2006 alleging the Service 

used the wrong standards the assess the wolverine petition. The U.S. District Court in Missoula, 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Regional Forester’s Sensitive Species 

210

Montana ruled the 90-day petition filed was in error and ordered a 12-month review which was 

conducted and published in the March 11, 2008 edition of the Federal Register. 

Ecology 

The wolverine is the largest terrestrial member of the mustelid family with males weighing 26 to 40 

pounds and females 17 to 26 pounds. Wolverines are opportunistic feeders consuming a variety of 

foods, depending on availability. There is no evidence hunting by wolverines is limited by habitat 

structure. Primarily a scavenger rather than a hunter, the wolverine forages where carrion can be found 

(Ruggiero 1994). In addition to carrion they will also prey on small animals and birds and eat fruits, 

berries, and insects. Copeland et al. (2007) reported little seasonal movement (400 meter elevational 

band) among collared wolverines in Idaho and the modest shift was likely due to prey availability in the 

form of ungulate carrion at lower elevations and upslope movement to locate rodents at higher 

elevations in the summer. 

Wolverines occupy a wide variety of habitats from the arctic tundra to coniferous forest. The most 

common habitats are those that contain a high diversity of microhabitats and high prey populations. 

Copeland (2007) described wolverine habitat in the contiguous United States as consisting of small, 

isolated “islands” of high-elevation, alpine habitats containing sufficient depth of snow during the 

denning period, separated from each other by low valleys of unsuitable habitats. Wolverines occupy 

habitat in a high elevation band from 6,888 feet to 8,528 feet in the mountains of the lower 48 states 

(Federal Register/ Vol. 73, No. 48/ Tuesday, March 11, 2008). The intervening valleys in this area 

range from 3,198 feet to 4,920 feet and are unsuitable for long-term wolverine habitat because they do 

not have the snow conditions or other habitat features required by wolverines (Aubry et al. 2007 in 

Federal Register/ Vol. 73, No. 48/ Tuesday, March 11, 2008). High elevation alpine wilderness areas 

appear to be preferred in summer, which tends to effectively separate most wolverine and human 

interactions. Aubry et al. (2007) reported that virtually all of the wolverine records located in the 

Pacific states were within or near alpine areas. Copeland et al. (2007) reported that adult males tend to 

travel more widely than females and as such, they are more likely found in lower, coniferous-dominated 

habitats simply by chance. The essential component of wolverine habitat may be isolation and the total 

absence of disturbance by humans (Ruggiero 1994). However, Copeland et al. (2007) reported 

unmaintained winter roads used for snowmobile access to trapping sites in the study area were 

frequently used for travel by wolverines. 

The most critical and limiting habitat for wolverines seems to be acceptable natal denning habitat. 

Magoun and Copeland (1998) described two types of dens used by wolverines: natal and maternal. 

Natal dens are used during parturition and occur more commonly in subalpine cirque basins associated 

with boulder talus slopes. Maternal dens are used subsequent to natal dens and before weaning occurs 

and consist of a complex of dens associated with boulders or fallen trees. Magoun and Copeland 

(1998) believe that a critical feature of wolverine denning habitat is the dependability of deep snow to 

persist through the denning period of February through May with at least one meter of snow depth. 

Ruggiero (1994) described natal dens having been found in snow tunnels, hollow trees and even caves 

in the ground. Ruggierro (1994) also reported that in forested habitats the structural diversity provided 

by large snags, fallen logs and stumps would likely provide natal den sites. 

Home ranges for adult wolverines tend to be large ranging from 38.5 square miles to 348 square miles 

(Banci 1994 in Federal Register Doc. 03-26475). Copeland (1996) radio collared wolverines in Idaho 

and reported annual home ranges of resident adult females averaged 148 square miles and an average of 

588 square miles for resident adult males. Aubry et al. (2007) compiled verifiable and documented 

records of wolverine occurrences and suggest that the historical distribution of wolverines in the 

Cascade Mountain and Sierra Nevada was disjunct, contradicting previous interpretations. Current 

records (1995-2005) are limited to north-central Washington, northern and central Idaho, western 

Montana, and northwestern Wyoming (Aubry et al. 2007). A recent observation with photographs 
Environmental Impact Statement BLT Project 

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211

indicates wolverines are still present in California (Zielinski, pers comm. 2008). Aubry et al. (2007) 

found no current records in Oregon despite concerted efforts to obtain verifiable evidence of wolverine 

occurrence using remote cameras, bait stations, and helicopter surveys in many areas of the Pacific 

states. However, five verifiable records of wolverine presence in Oregon were documented from 1961 

to 1994 (Aubry et al. 2007). 

Wolverine may be impacted by management practices that influence subalpine and alpine communities, 

particularly those that reduce the presence and opportunity for carrion availability (Copeland et al. 

2007). Resource extraction (including timber harvesting, backcountry skiing and snowmobiling, roads 

and other forms of human disturbance merit careful consideration by those concerned about wolverine 

conservation (Ruggiero et al. 2007). Researchers in British Columbia found a consistent negative 

association between wolverine occurrence and areas where helicopter and backcountry skiing occur. 

However, the causal factors associated with these patterns are not well understood (Copeland et al. 

2007). Squires et al. (2007) found that trapping was the primary factor explaining decreased survival in 

western Montana. He also determined that harvest pressure was capable of reducing isolated 

populations beyond sustainable levels despite a regulated harvest within a state-wide quota system. 

Existing Conditions 

The Viable Ecosystem model was used to estimate acreage of potential denning habitat for this species. 

There are approximately 2,363 acres of mountain hemlock stands greater than 20 inch diameter that 

may serve as potential denning habitat. These acres are all located in the Mt. Thielsen Wilderness and 

OCRA. This figure accounts for all past and present timber sales, natural events such as wildfire, and 

any other habitat-altering activity that would express itself in a vegetative manner. This way of 

presenting this information is the most informative manner for the decision maker. 

The Crescent Ranger District performed carnivore surveys from 1993-1996 and 1998 using bait with 

camera stations but the only carnivore species detected was the American marten. District records list 

unconfirmed wolverine sightings near Willamette Pass, on Maklaks Mountain, and near Crescent 

Creek. Potentially suitable natal denning habitat may be found in the Mt. Thielsen and Diamond Peak 

Wilderness areas and Cowhorn Mountain within the OCRA. It is unlikely denning habitat would be 

found in remainder of the Crescent Ranger District because of open roads, high recreational use, and 

the lack of persistent snow cover in alpine and subalpine areas where denning may occur. Aubry et al. 

(2007) reported that virtually all of the wolverine records located in the Pacific states were within or 

near alpine areas. They also reported that spring snow cover was the only habitat layer in their study 

that fully accounted for the distribution of historical wolverine records in the western mountains. 

In 2000, the Forest Service (Willamette, Deschutes, and Umpqua National Forests) completed an 

environmental assessment that allowed them to conduct helicopter surveys during the winter over the 

southern and central Cascade Mountains of Oregon including the Sky Lakes Wilderness, Mt. Thielsen 

Wilderness, and the Diamond Peak Wilderness. The study was to last 5 years and beginning in 2001 

were authorized a limited number of landings in wilderness areas to investigate possible tracks, if 

sighted. Flight areas have included some of the most southern portions of the Crescent Ranger District. 

At the conclusion of the study in late 2006, no track observations from any flight have been confirmed 

to be wolverine (Henshaw pers comm. 2005). At the present time, wolverines have not been 

confirmed to occur on the Crescent Ranger District. 

Environmental Consequences 

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would have no immediate change in the vegetative character of the 

planning area. Natural vegetative succession would continue to occur resulting in increased tree growth 

in younger aged stands and a trajectory to wide-scale loss of forest from a disturbance event. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Regional Forester’s Sensitive Species 

212

Wolverines, if present, would likely continue to utilize the highest elevations in the planning area 

during most, if not all of the year. There would be no change in prey availability at least in the shortterm unless a large-scale habitat altering event occurred that would change mammal populations. This 

would result in a determination of “No Impact” to the California wolverine. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

While there is no recent evidence to suggest wolverines are present in the state of Oregon, potentially 

suitable denning habitat may be present in the alpine and subalpine areas of the Cascade Range 

including portions of the Mt. Thielsen Wilderness which is present at the far west end of the analysis 

area. Existing road systems are in place extending into the upper Little Deschutes River canyon near 

the wilderness boundary. Recreational use of this area is primarily limited to summer camping, fall 

hunting seasons and occasional snowmobile activity during the winter months. Overall human use of 

this area would be described as relatively minor compared to more populated areas and back country 

skiing that occurs around Bend, Oregon. 

The BLT project proposes commercial harvest in the upper Little Deschutes River basin, which would 

be the closest to suitable habitat found within the wilderness and OCRA boundary. Timber harvest and 

post-sale activities (non-commercial thinning and slash removal) would most likely occur during the 

months of May through October however winter logging may occur where required to protect 

matsutake production. Winter harvest is also dependent upon timber sale contract time, snow depths, 

distances to plow, and value of the timber (Turley, pers comm. 2008). Copeland et al. (2007) reported 

that male wolverines were more likely to use lower elevations because of their large home ranges. If 

wolverines are present in the analysis area, they may use portions of the Little Deschutes River canyon 

for foraging. Access to activity units #1300 and #1246 would require approximately 0.8 miles of 

temporary road construction (Alternatives B and D only). Most of these roads would be within units 

themselves to facilitate efficient removal, and they would be restored to proper hydrologic function 

within 5 years following their intended use. Harvest activities near suitable habitat in the river canyon 

may result in wolverine(s) shifting their pattern of use to areas with less human disturbance, particularly 

if winter logging is ongoing on all or portions of the treatment units in this area. Prescriptions are 

designed to reduce the density of trees and resulting canopy cover. Ruggiero (1994) reported that 

wolverines seem less sensitive to overhead canopy cover or vegetation near the ground as compared to 

marten or fisher. 

No timber harvest related activities would occur within potentially suitable denning habitat. If winter 

logging occurs there would be an increase in the amount of human activity that would occur in this 

area. However, because resident male wolverines can have home ranges that vary from 193 square 

miles to 588 square miles depending on the study area (FR Vol. 73, No. 48) the animal(s) would likely 

move into adjacent drainages where less or no disturbance may be occurring. Any impact to the 

wolverine would likely be temporary and localized to the river bottom where logging activities would 

occur. It is unlikely winter logging would result in greater snowmobile use of this area because access 

during the winter in the BLT area would not accommodate parking of snowmobile trailers and adjacent 

groomed trails would be favored. 

Determination 

While wolverines have not been documented to occur on the Crescent Ranger District, they may be 

infrequent visitors to the analysis area because of potentially suitable denning habitat in the Mt. 

Thielsen Wilderness and Cascade Range. While no activities would occur within denning habitat, there 

is the potential for disturbance to foraging or dispersing wolverines for up to several years while the 

BLT project operations are being conducted. It is determined the BLT vegetation management actions 

“May impact individuals or habitat, but will not likely contribute to a trend toward Federal 

listing or cause a loss of viability to the population or species”. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

213

Cumulative Effects 

The projects described in Table 3-1 were reviewed to assess whether there are other actions with the 

potential to overlap in time and space within the same zone of influence. The zone of influence for the 

wolverine would be the Crescent Ranger District (approximately 400,000 acres) because it abuts the 

Cascade Mountains and higher elevation habitat that can provide solitude. Projects listed as 

“completed” are assumed to no longer have effects that are quantifiable. The remaining projects, such 

as Five Buttes, listed for “implementation” were reviewed for effects on the wolverine for each 

applicable NEPA review. All are planned in relatively low elevation terrain and generally near urban 

interface where existing background levels of disturbance would likely be avoided by wolverines. 

None of the projects would occur in potential denning habitat and the only potential effect to 

wolverines would be the possibility for disturbance to foraging or dispersing wolverines if present in 

the immediate area. None of these projects are likely to overlap in timing, but if they do, the effect 

coupled with winter recreation would be localized and wolverine would tend to avoid operations and 

traverse around in areas that provide more solitude, such as the adjacent Oregon Cascades Recreation 

Area and wilderness. For these reasons, the analysis of past actions other than those listed in this 

section is based on current environmental conditions. 

Because of the large home ranges, that wolverines have not been documented to occur in this area, that 

no denning habitat would be impacted, and that project work would not likely occur in all areas at the 

same time, leads to a conclusion that additive effects are so small in potential to affect the wolverine, 

they would be more than offset by the implementation of the Travel Management Rule in 2009. This 

Rule would prohibit off road travel and restrict them to designate routes. Although off highway vehicle 

travel is occurring mostly adjacent to the Two Rivers Subdivision, implementation of this rule would 

further reduce the potential for disturbance. Based on existing knowledge of species presence and 

habitat conditions available, and the factors disclosed in this section, there are no other incremental 

effects identified. 

Townsend’s Big-Eared Bat (Plecotus townsendii), R6 Sensitive

Ecology 

The Townsend’s big-eared bat has very large ears, two large fleshy lumps on its snout and has darker 

and shorter wings than other subspecies (NatureServe 2008). Maternity and hibernation colonies are 

typically in caves and mine tunnels. Females give birth to one pup in late spring/early summer and the 

young can fly at 2.5-3 weeks and are weaned by 6 weeks. Females form nursery colonies seldom 

exceeding 100 adults; males roost separately (apparently solitary) during this time (NatureServe 2008). 

They roost almost exclusively in cavity roosts, both in human-made structures (that is, buildings, 

bridges and mines) and caves (Christy and West 1993). Christy and West (1993) report Townsend’s 

have been observed foraging along forest edges, roads, or open areas within the forest. They are 

extremely sensitive to disturbance while roosting, because they hang directly from the ceiling of the 

roost and do not go into inactivity during the day in summer colonies (Barbour and Davis 1969 and 

Dalquist 1948 cited in Christy and West 1993). Perkins and Levesque (1987) estimated the Oregon 

population at 2,300-2,600 bats and Gaines (1997 cited in NatureServe 2008) estimated 3,000-5,000 

individuals in Oregon. The species range extends from southwestern British Columbia, western 

Washington, western and central Oregon, and northwestern and west-central California. NatureServe 

(2008) gives them a status of S2, Imperiled in the state of Oregon. The greatest threat to the species is 

vandalism and disturbance by humans. Disturbance of a nursery colony or of a hibernating group is 

likely to cause the bats to abandon the site and move to an alternate roost. An additional threat is 

blockage of cave/mine entrances through collapse or human activities (NatureServe 2008). 

Existing Conditions 

There are no known caves or mines on the Crescent Ranger District (L. Hickerson, pers comm. 

2008) and there are no documented reports of Townsend’s big-eared bats occurring on the district. 
BLT Project Environmental Impact Statement 

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214

Townsend’s big-eared bats are known to occur within cave systems on the Bend-Ft. Rock Ranger 

District of the Deschutes National Forest. Winter hibernaculum surveys are generally conducted each 

winter on a select number of caves to determine which species are present. Dobkins (1992) conducted 

a radio-telemetry study of Townsend’s big-eared bats on the Bend-Ft. Rock District and documented 

movements at least 24 kilometers form the original point of capture. Initial reports from a study of bat 

use in the Davis Fire area on the Crescent Ranger District (Manning pers comm. 2006) did not confirm 

the presence of Townsend’s. Perlmeter (1996 and 1997) conducted bat surveys under several bridges 

on the Crescent Ranger District including a wooden bridge on Odell Creek and concrete and wooden 

bridges over Crescent Creek and the Little Deschutes River on Highway 58. One long-eared myotis 

was detected day roosting under the Odell Creek concrete and wooden bridge during the 1996 survey. 

In 1997 there were no bats observed roosting under these bridges although foraging activity was noted 

on both evenings mist nets were set up (Perlmeter 1997). It is unknown if any caves or mines are 

present on private lands in the analysis area that may contribute to conservation for this species. 

Effects Common to All Alternatives 

Because Townsend’s big-eared bats are not known to occur on the Crescent Ranger District and that no 

maternity or hibernaculum sites exist, there would be no direct, indirect, or cumulative effects. BLT 

implementation would result in “No Impact” to the Townsend’s big-eared bat. 

Crater Lake Tightcoil Snail (Pristiloma articum crateris), R6 Sensitive

Ecology 

The Crater Lake Tightcoil may be found in perennially wet substrates in mature conifer forests, among 

rushes, mosses and other surface vegetation or under rocks and woody debris within 10 meters (30 feet) 

of open water in wetlands, springs, seeps and riparian areas (Duncan et al. 2003), generally in areas 

which remain under snow for long periods of time during the winter. Threats to the species include 

activities that compact soils, reduce litter and/or vegetative cover, or impact potential food sources. 

Existing Conditions

Due to the well-drained pumice soils on the Crescent Ranger District, areas that retain permanent 

surface moisture are very narrow margins along the edge of springs, seeps, or streams. Within the 

analysis area, permanent water sources include the Little Deschutes River, Hemlock Creek, Spruce 

Creek, Basin Creek, and Rabbit Creek. Surveys for the Crater Lake tightcoil snail were conducted in 

2001 in the Spruce Creek, Rabbit Creek, Basin Creek, and Hemlock Creek drainages of the analysis 

area. There were no Crater Lake tightcoils located although several more common snails and slugs 

(Discus and Deroceras) were found to be present in several of these stream systems and/or riparian 

zones. As of August 2008, there remains only one confirmed population of Crater Lake Tightcoil snails 

on the Crescent Ranger District. That population was located outside the analysis area near the 

confluence of Princess Creek and Odell Lake in June 1999. 

Alternative A- No Action 

The selection of Alternative A would result in no immediate change in the vegetative condition within 

the riparian zones of the BLT analysis area. Because no habitat would be directly impacted there would 

be “No Impact” to the Crater Lake tightcoil snail.

Effects Common to All Action Alternatives 

There is only one activity unit with potential to affect the Crater Lake Tightcoil within the BLT analysis 

area. Unit #1061 is located adjacent to Hemlock Creek and borders the west side of the Two Rivers 

subdivision. Activities would be limited to non-mechanical thinning of lodgepole pine less than 3 

inches in diameter and spot burning of decadent willows is planned. Duncan et al. (2003) listed some 

examples of activities that may not require pre-disturbance surveys. One of the activities listed was 

pre-commercial thinning with no removal of key habitat elements. Because only 3 inch and smaller 

live trees would be removed, the lodgepole pine and Engelmann spruce greater than four inches 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

215

diameter would be retained within the riparian zone capable of providing virtually the same canopy 

cover. These residual trees would also become the future down logs within the riparian zone. An 

indirect effect of the pre-commercial thinning would be an increase in forb and shrub cover including 

willows, bog blueberry, bog birch. A Project Design Feature/measure has been included in Chapter 2 to 

prohibit prescribed burning of decadent willow clumps within 10 meters of permanently wetted 

portions of riparian zones, unless additional surveys are conducted. These measures would assure 

habitat elements described by Duncan et al. (2003) would be maintained for the Crater Lake Tightcoil 

snail if present in the lower Hemlock Creek drainage. 

Determination 

Based on the level of surveys previously conducted and the Project Design Feature to avoid activities 

within the permanent wetted portion of any riparian zone, implementation of any BLT action alternative 

would have “No Impact” to the Crater Lake Tightcoil snail. 

Silver-Bordered Fritillary (Boloria selene), R6 Sensitive

Ecology 

The silver-bordered fritillary butterfly has a holarctic range extending from northern Canada southward 

into the United States and as far south as New Mexico (NatureServe 2008). While the species is 

common and widespread in northeastern Washington and northern Idaho, colonies are extremely local 

and isolated southward, and are particularly vulnerable to local extinctions. Only two primary colonies 

are found in Oregon, one at Big Summit Prairie on the Ochoco National Forest and one in the 

Strawberry Mountains Wilderness on the Malheur National Forest (Miller and Hammond 2007). 

NatureServe lists this species as G5, demonstrably secure globally, though it may be quite rare in parts 

of its range, especially at the periphery. In Oregon, its ranking is listed as S2, Imperiled. Suitable 

habitat for this species is described as mostly wet meadows, marshes, bogs and more open parts of 

shrubbier wetlands (NatureServe 2008, Miller and Hammond 2007). This species is dependent on the 

maintenance of open and wet meadow habitats (Miller and Hammond 2007). Food sources for the 

adults include nectar sources such as composite flowers, including goldenrod and black-eyed Susan 

(Opler et al. 2006). Eggs are laid singly near host plants and caterpillar hosts are violets including 

Viola glabella and Viola nephrophylla. (Opler et al. 2006). 

Existing Conditions 

There have been no formal surveys conducted on the Crescent Ranger District, but the species is 

suspected to occur. Within the BLT analysis area, suitable habitat for this species may occur in the wet 

meadow complexes of Spruce Creek, Hemlock Creek, and in the upper Little Deschutes River canyon. 

Riparian habitat is also present in the analysis area on private lands although it is unknown if suitable 

habitat conditions exist for this species on those lands. 

Alternative A – No Action 

Direct and Indirect Effects 

In the short-term (less than 10 years), there may not be much noticeable change in the wet meadow 

complexes of the analysis area. Lodgepole pine encroachment in the wet meadow complexes has been 

noted and seems to be increasing. This alternative would forego the opportunity to remove encroaching 

lodgepole pine trees in unit #1061 which include some wet meadow habitat. The selection of 

Alternative A would not help maintain open wet meadow habitat this species requires. The selection of 

Alternative A would have “No Impact” on the Silver-bordered Fritillary butterfly. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

All three action alternatives propose lodgepole pine tree removal (less than 3 inches in diameter) and 

prescribed underburning in unit #1061 along Hemlock Creek outside the wetted portion of the riparian 
BLT Project Environmental Impact Statement 

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216

zone. The planned prescribed underburning would occur early in the spring before flowering occurs 

and would not prohibit the flowering potential of the host species. Overall, restorative actions would 

create more open wet meadows described as suitable habitat for the species and would be beneficial by 

creating suitable habitat. 

Determination 

The selection of any of the action alternatives would have “No Impact” on the silver-bordered fritillary 

butterfly. This determination is based on the premise that no suitable habitat would be negatively 

impacted by project activities. 

Cumulative Effects 

Table 3-1 was reviewed for actions which have a similar zone of influence and overlap in time and 

space. The only project which applies is the Spruce Creek Rehabilitation Project. Approximately 100 

acres of riparian habitat along Spruce Creek (upstream of Hemlock Creek and unit #1061) is also 

scheduled to have lodgepole pine trees less than 3 inches in diameter removed, and prescribed 

underburning to reduce tree encroachment into wet meadow habitats. Included in the 100 acres are 

boggy meadows which may provide habitat for the silver-bordered fritillary. Cumulatively, these 

actions would improve habitat for this species. There are no anticipated additional cumulative effects 

to this species. 

Johnson’s Hairstreak (Callophrys johnsoni), R6 Sensitive

Ecology 

The Johnson hairstreak butterfly is found from southwest British Columbia southward into the Coast 

Ranges to San Francisco in California; south in the Cascades and Sierra Nevada to Yosemite and also in 

the Blue Mountains of eastern Oregon. In Oregon, its ranking is listed as S2, Imperiled. Globally, its 

status is G3, very rare or local throughout its range or found locally in a restricted range (NatureServe 

2008). 

Suitable habitat for this species is described as coniferous forests, especially old structured stands 

(Opler et al. 2006) with red firs, western hemlocks, or gray pines on which its parasitic (mistletoe) hosts 

grows (NatureServe 2008). Johnson’s hairstreak is believed to feed generally on all dwarf mistletoe 

species throughout its range, and to perhaps specialize on locally available dwarf mistletoes in specific 

localities (Miller pers comm. 2008 cited by Schmitt and Spiegel 2008). Miller and Hammond (2007) 

describe suitable habitat as almost identical to that of the northern spotted owl except that the butterfly 

does not occur south of central California. The caterpillar food plant is western dwarf mistletoe. 

Adults find nectar on low growing plants such as whitethorn ceanothus and Mt. Hood pussypaws 

(NatureServe 2008 and USDA, NRCS 2008). Miller and Hammond (2007) described management 

practices to benefit this species need to promote the maintenance of mature and old-growth conifers at 

middle to low elevations on the west slope of the Cascade Mountains and Coast Range. 

Existing Condition 

Opler et al. (2006) shows Johnson Hairstreak documentation for western and central Oregon plus the 

Blue Mountains in northeastern Oregon. The species is suspected to occur on the Deschutes National 

Forest but currently there is no confirmed documentation. Formal surveys have not been conducted. 

Because the species is closely associated with dwarf mistletoe which is present in the analysis area, the 

Johnson’s hairstreak is assumed to occur. Schmitt and Spiegel (2008) state that claims of dwarf 

mistletoes occurring solely in old growth or are dependent upon old growth are erroneous. Dwarf 

mistletoes generally increase in incidence and intensity in older stands, although even young stands 

readily host dwarf mistletoes and maturing stands may be severely infected if they have been 

continually infected by a residual overstory. They also state that in the absence of recent large scale 

disturbance, dwarf mistletoe infestation levels can occur in early, mid, and late successional stands. 

Because the BLT analysis area has not experienced a large scale event like an uncharacteristic wildfire, 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Regional Forester’s Sensitive Species 

217

mistletoe infection is assumed to be present and abundant in all stand age classes which could serve as a 

host for the caterpillar. It is unknown if suitable habitat conditions exist for this species on private 

lands in the analysis area and how it could contribute toward conservation of this species. 

Alternative A – No Action 

Direct and Indirect Effects 

The selection of this alternative would not result in any change in vegetative conditions of conifer LOS 

stands in the analysis area. This alternative contains the greatest risk of loss of habitat due to a widescale disturbance process. However, because of a passive management scenario associated with this 

alternative, the determination is “No Impact” to the Johnson’s Hairstreak butterfly. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

The selection of any action alternative would result in the commercial thinning of mid-successional and 

LOS conifer forests which would likely include some trees infected with the western dwarf mistletoe. 

None of the alternatives propose to eradicate mistletoe so the infection would continue to exist within 

actively treated stands, as well as forested stands not selected for treatment within the 80,000-acre 

Upper Little Deschutes Watershed (BLT analysis area). These management actions would be 

consistent with the recommendations from Miller and Hammond (2007) that promoting the 

maintenance of mature and old-growth conifer forests would benefit this species. The commercial 

thinning prescriptions are designed to reduce stand competition for scarce resources related to density. 

Activities would reduce the stress on the overstory trees and maintain their presence on the landscape. 

Also, there would be no net loss of LOS forests. In addition to the understory thinning, prescribed 

underburning is proposed on 1,702 acres (Alt. B), 1,405 (Alt. C), and 591 acres (Alt. D). This would 

occur on ponderosa pine dominated stands, but may result in a reduction in the amount of host plants 

such as ceanothus and pussypaws within burn units. Each prescribed burn is required to have a sitespecific plan, and Project Design Features in Chapter 2 require these plans to retain unburned patches 

including acreage with shrubs and forbs. Monitoring has shown these requirements to be generally 

effective, given the minute to minute changing environmental conditions. Generally, 30-40 percent of 

the shrubs are to be maintained after the underburn operations. This measure would ensure host plants 

are present for nectar gathering for the adults if present in the analysis area. 

Determination 

It is determined implementation of any action alternative “May impact individuals or habitat, but 

will not likely contribute to a trend toward Federal listing or cause a loss of viability to the 

population or species” for the Johnson’s Hairstreak. This conclusion is based on the expected 

outcome of commercial thinning maintaining the presence of mistletoe infected host conifer trees for 

the caterpillars and the retention of host shrubs species following underburning operations. 

Cumulative Effects 

Table 3-1 was reviewed for project actions that have a similar zone of influence and overlap in time and 

space as the BLT project. The zone of influence was determined to be the 80,000-acre Upper Little 

Deschutes Watershed because the BLT analysis area is the best scale to assess potential additive effects. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees and endemic levels of mistletoe remains. In addition, 800 

acres of prescribed underburning maintained shrubs. The Maintenance Burn CE (2005) and Prescribed 

Underburning and Mowing Project CE (1997) also overlap with the BLT boundary with similar 

successful measures prescribed for the retention of shrubs which may provide butterflies a food source. 

None of the remaining activities in Table 3-1 were considered relevant for cumulative effects 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Regional Forester’s Sensitive Species 

218

discussion due to the small scope of the projects, or their effects have diminished to a point that are not 

quantifiable. For these reasons, the analysis of past actions other than those listed in this section is 

based on current environmental conditions. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Rare and Uncommon Species 

219

Rare and Uncommon Species 

In 1994, the Northwest Forest Plan (NWFP) developed a system of reserves, Aquatic Conservation 

Strategy, and various standards and guidelines for the protection of old growth associated species. 

Mitigation measures and management recommendations were also included for species that were rare, 

or thought to be rare due to a lack of information about them. It was unknown whether the major 

elements of the NWFP would protect these species. Subsequent decisions have placed some of these 

species on the Regional Forester’s Sensitive Species list and some are now identified as “Strategic” 

meaning there are information gaps (i.e. distribution, habitat, threats) resulting in status or taxonomic 

uncertainties. Strategic species are not considered “sensitive” species under Forest Service Manual 

2670. 

White-Headed Woodpecker, Black-Backed Woodpecker, Pygmy Nuthatch, Flammulated Owl 

Of this group of species, only the white-headed woodpecker moved to the “sensitive” species list with 

the January 31, 2008 update and it is discussed in Chapter 3, Threatened and Endangered Species. 

Discussion on the effects of the project on the black-backed woodpecker is disclosed in Chapter 3, 

Management Indicator Species. Effects to the pygmy nuthatch and flammulated owl are disclosed in 

this section. 

Pygmy Nuthatch and Flammulated Owl

Ecology

Marshall et al. (2003) described the pygmy nuthatch as a resident of ponderosa pine dominated 

forests from the east slopes of the Cascades eastward into the Blue and Warner Mountains of 

Oregon. It will forage in young ponderosa pines and in lodgepole pines that are adjacent or near 

ponderosa stands. Nesting is described to be in snags or dead portions of live trees and they 

reportedly can excavate nest cavities, often using cracks to gain entrance to a hollow or decaying 

wood (Marshall et al. 2003). Their diet includes beetles, ants, true bugs, and butterfly/moth larvae. 

Typical nest cavities in California were found in decaying pines that usually exceeded 20 inches in 

diameter and in one study from Arizona the mean diameter of nest cavities 16 inches. 

The flammulated owl is one of the smallest owls in North America and is unique in that it preys 

almost exclusively on insects and is a neotropical migrant. The species winters in central and 

southern Mexico, Guatemala, and perhaps El Salvador. In Oregon, the species breeds on the 

eastern slope of the Cascades, Blue and Wallowa Mountains and in small numbers in the 

mountains of southwest Oregon (Marshall et al. 2003). They are most closely associated with 

ponderosa pine forest, but also nests in mixed coniferous stands dominated by ponderosa pine. 

Marshall (2003) reported that forested stands used for nesting tend to have moderate to high levels 

of canopy cover ranging from 31-94 percent (mean 67 percent) with a rather open understory or an 

open area adjacent. The species is a cavity nester and in northeastern Oregon ponderosa pine 

snags was the common nest tree. Snags and trees used for nesting averaged 22 and 28 inches in 

diameter in two Oregon studies (Goggans 1985, Bull et al. 1990 cited by Marshall et al. 2003). 

Existing Condition 

The Viable Ecosystem model was used to determine acres of suitable nesting habitat for this 

species group. Both the pygmy nuthatch and flammulated owl use similar habitats, so the same 

characteristics were modeled using a definition of ponderosa pine and mixed conifer stands 

dominated by ponderosa pine greater than 15-20 inches diameter. Stands can be open or closed 

canopy. 

Modeling indicates there are approximately 4,469 acres of potential nesting habitat in the analysis 

area, and although private lands were included in the model, most is located on National Forest 

system lands. There are no documented reports of pygmy nuthatches in the analysis area but they 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Rare and Uncommon Species 

220

are assumed to occur. District observation records show five reports of flammulated owls in the 

analysis area, although there are no known nests. Observation sites were located along the Little 

Deschutes River, Swamp Creek, and Hemlock Creek. 

Alternative A 

Direct and Indirect Effects 

This alternative would result in no immediate change in the vegetative structure of the analysis 

area. Over the long-term, ponderosa pine dominated stands would grow into larger diameter trees 

and tree mortality in the greater than 15 inch range would provide suitable nest sites for the pygmy 

nuthatch and flammulated owl. In the absence of large scale forest loss to wildfire or beetle 

outbreaks, there should be an increasing trend in habitat for these species as stands mature into 

larger trees. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

Table 3-71. Tolerance Interval Projections for the Pygmy Nuthatch 

Pygmy Nuthatch 

4,469 Acres

Tolerance Interval below 

30% 30-50% 50-80% 80%+ below 

50% 50-80% 80%+

Density (#/hectare)* 0-2.7 2.7-13.8 13.8-29.9 29.9+ 0-4.0 4.0-9.9 9.9+

Density (#/acre)* 0-1.1 1.1-5.6 5.6-12.1 12.1+ 0-1.6 1.6-4.0 4.0+

% of Habitat 53.9% 21.1% 9.9% 15.1% 86.8% 9.1% 4.1%

Acres 2,408 945 443 673 3,877 409 183

Density of Snags = 10" dbh

 by tolerance interval

Density of Snags = 20" dbh 

by tolerance interval

*From DecAID 2.0 Tables EMC_S/L.sp-22 and PPDF_S/L.sp-22. Information synthesized from various 

studies

The Viable Ecosystem Model estimated there are 4,469 acres of nesting habitat for the pygmy 

nuthatch. This is based on tree size classes and appropriate Plant Association Groups typically 

selected for nesting. Table 3-71 displays the range of tolerance intervals based on snag levels 

taken from DecAID. For snags 10 inches in diameter, 54 percent of the habitat is less likely 

support nesting individuals (less than 30 percent tolerance interval), while 46 percent of the habitat 

is more likely to support nesting individuals (30-80+ percent tolerance interval). 

For snags greater than 20 inches in diameter, 87 percent of the analysis area is less likely to support 

nesting individuals (less than 50 percent tolerance interval), while 13 percent of the analysis area is 

more likely to support nesting individuals (greater than 50 percent tolerance interval). The 

DecAID data did not include tolerance intervals of less than 30 percent or 30-50 percent for snag 

use greater than 20 inches in diameter. Loss of snags would only occur for occupational safety, 

clearing an area for log landings, and temporary road construction. Based on past timber sale 

reviews by sale administrators, snag removal would be considered minimal. In addition, a Project 

Design Feature (Chapter 2) would protect existing snags when prescribed underburning. 

All action alternatives propose commercial timber harvest and post-sale activities including post 

and pole removal, reduction of activity-generated slash and prescribed underburning within 

ponderosa pine dominated sites. Alternatives B and C are nearly identical in the amount of 

thinning that would occur in currently suitable nesting habitat. Alternative B would conduct 

commercial thinning on 508 acres (11 percent of the total) and 452 acres (10 percent of the total) 

for Alternative C. Alternative D would conduct timber harvest and post-sale activities on 135 acres 

(3 percent of the total existing) of currently suitable nesting habitat. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Rare and Uncommon Species 

221

Because both species would use stands that are either considered open or dense, the removal of 

understory trees would not affect their ability to utilize actively-managed stands for nesting 

purposes. 

Timber harvest and prescribed underburning operations may be conducted during the spring and 

early summer months when pygmy nuthatches and flammulated owls may be nesting. This may 

result in some pairs being displaced while activities are ongoing. Considering that only 3-11 

percent of the total nesting habitat may be impacted by this project, and that not all sales or 

activities would be underway during the same time period, the majority of the analysis area would 

have undisturbed habitat present during the nesting season. Because both species are dependent 

upon healthy ponderosa pine forests, planned activities within the BLT analysis area would 

improve habitat for these species by increasing average stand diameters and reducing the risk of 

wide-scale loss of forest. Endemic levels of insects and mistletoe would be maintained to provide 

future snag recruitment. 

All three action alternatives require the construction of temporary roads (Alternative B - 9.7 miles, 

Alternative C - 8.7 miles, and Alternative D - 4.7 miles) which may result in an undetermined number 

of snags being felled for clearing width some of which may provide nesting habitat. The clearing width 

for the temporary roads would equate to about 20 acres for Alternative B, 17 acres for Alternative C, 

and 9 acres for Alternative D. This is less than 1 percent of the total acreage scheduled for commercial 

and/or fuels activities in each alternative. Consequently, road construction is not expected to 

measurably increase the snag loss during implementation. While down wood removal is proposed for a 

limited number of units, neither species is thought to be closely associated with down wood for nesting 

or foraging, therefore, commercial and/or personal use firewood removal would not affect either 

species. 

The Viable Ecosystem Model projected that all alternatives including the no-action (Alternative A) 

would show an increase in the number of suitable nesting acres for the pygmy nuthatch and 

flammulated owl over all decades modeled. All three action alternatives also show increasing 

acreage of nesting habitat over time as compared to the no-action. This is the result of expected 

increased tree growth as a result of thinning and younger aged stands that develop into the 

minimum tree diameters used by both species. 

The activities prescribed for every action alternative are consistent with the habitat objective in 

Altman’s 2000 Landbird Conservation Strategy for the pygmy nuthatch and flammulated owl. 

Ponderosa pine trees at least 21 inches dbh and the retention of snags are needed by both species. 

The PDCs and mitigation measures described in Chapter 2 would be incorporated into contracts 

during project implementation. 

Cumulative Effects 

The projects in Table 3-1 were reviewed for actions that have a similar zone of influence and overlap in 

time and space as the BLT project. The zone of influence is defined as the 80,000-acre 5th field 

watershed because it represents an area large enough to evaluate landscape processes. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. These activities would be considered to increase suitable 

habitat. Remaining projects from Table 3-1 listed as “completed” no longer have any effects that are 

quantifiable. Maintenance Burn CE, Prescribed Underburning and Mowing Project CE and the 

Rosedell CE all overlap in time and space with the BLT project and could occur within habitats used by 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Rare and Uncommon Species 

222

pygmy nuthatches and flammulated owls. All of these projects have mitigation measures prescribed for 

the retention of snags for cavity excavator and secondary cavity users and the approximate 800 acres of 

prescribed burning within ponderosa pine dominated stands would be consistent with maintaining 

habitat for both species. For these reasons, the analysis of past actions other than those listed in this 

section is based on current environmental conditions. Therefore, the effects discussed for direct and 

indirect effects do not change. 

Fringed Myotis, Silver-Haired Bat, Long-Eared Myotis, Long-Legged Myotis, Pallid Bat, and 

Townsend’s Big-Eared Bat

The Townsend’s big-eared bat was placed on the “sensitive” species list in the January 31, 2008 update. 

Effects to this species and habitat are disclosed in Chapter 3, Threatened and Endangered Species. 

Effects to the remaining species are discussed in this section. 

Most bat species roost and hibernate in crevices in protected sites. Sites commonly used by bats 

include caves, mines, snags and decadent trees, wooden bridges, and old buildings (USDA 1994 ROD 

C-43). While snag management guidelines were provided (USDA and USDI S&G-37-38), the authors 

of the plan determined that additional protection was needed for caves, mines, abandoned wooden 

bridges and buildings. Surveys of these structures were recommended to determine bat presence 

including the fringed myotis, silver-haired bat, long-eared myotis, long-legged myotis, pallid bat, and 

Townsend’s big-eared bat. The purpose of the management recommendation is to protect these sites 

from destruction, vandalism, disturbance from road construction, blasting or any other activity that 

could change cave or mine temperatures or drainage patterns. 

Ecology 

Sites commonly used by bats include caves, mines, snags and decadent trees, wooden bridges and old 

buildings. The bats in this group vary slightly on habitat use. The fringed myotis and the Townsend’s 

big-eared bat focus on caves, mines, and rock crevice habitat while the long-legged myotis, long-eared 

myotis, and the pallid bat will utilize buildings, caves, snags and hollow trees. The silver-haired bat 

relies heavily on standing snags and hollow trees in and adjacent to riparian areas that are used for 

foraging (NatureServe 2008). 

Most of the myotis species and Townsend’s big-eared bats are colonial breeders which can range from 

12 to 500 individuals but generally contain less than 100 (Christy and West 1993). Silver-haired bats 

are generally considered solitary breeders though a few nursery colonies have been reported (Christy 

and West 1993). Most bat species are aerial foragers but a few (long-eared and fringed myotis) also 

glean insects from the ground or foliage and rely on vision as well as echolocation when hunting (van 

Zyll de Jong cited in Christy and West 1993). Most bat species in the Pacific Northwest probably 

undergo relatively short migrations to and from hibernacula each year although silver-haired bats are 

believed to migrate fairly long distances (Shump and Shump cited in Christy and West 1993). Pacific 

Northwest bat species have many predators but are not a major prey item for any animal group 

consequently; predation is not a major mortality factor. However, the influence of people may have 

negative effects on bats from disturbances to hibernacula from cave exploration. Pesticide spraying to 

control insects may also negatively affect bats by reducing prey populations as well as contaminating 

their prey. 

Table 3-72 displays the bat species that are known to occur or may potentially occur within the BLT 

project. Data from the table below is from Perlmeter 1996-1997, Christy and West 1993, NatureServe 

2008, and preliminary data results from T. Manning, Oregon State University 2006. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Rare and Uncommon Species 

223

Table 3-72. Bat Species Known or Suspected to Occur and Habitat Requirements 

Species Forage 

Substrate 

Roost Site Main Prey 

Species 

Comments 

California Myotis Forest edges and 

over water 

Cliff faces, tree 

crevices, caves and 

structures 

Moths One offspring per 

female/season 

Western Smallfooted Myotis Ponderosa pine and 

mixed conifer forests 

Rock crevices, under 

boulders, and 

beneath bark 

Small insects Will also forage over 

rocks 

Yuma Myotis 

Riparian, moist 

woodlands, and open 

forests 

Buildings, caves and 

bridges 

Moths, midges, flies 

and termites 

Closely associated 

with water and very 

sensitive to 

disturbance 

Little Brown Myotis Moist forests and 

riparian areas 

Buildings, bridges, 

caves, mines, rock 

crevices, snags 

Flies Closely associated 

with water 

Long-legged Myotis Coniferous forests 

and riparian areas 

Crevices, buildings 

and caves Moths Closely associated 

with forests 

Long-eared Myotis Forested habitats and 

forested edges 

Snags, hollow trees 

or rock features Moths One offspring per 

female/season 

Silver-haired Bat 

Forested areas and 

over ponds and 

streams 

Under bark Wide variety of 

insects 

Deforestation and 

loss of snags is a 

threat 

Big Brown Bat 

More common in 

deciduous forests 

versus coniferous 

forests 

Structures Beetles 

Forages over open 

areas and uses 

hollow trees 

Hoary Bat Riparian and brushy 

areas Trees Moths 

Solitary breeder and 

only foliage roosting 

bat in Pac. Northwest 

Pallid Bat Arid regions and 

open forest types 

Cliff faces, caves, 

and buildings 

Moths and 

grasshoppers 

Forages on ground 

and very intolerant to 

disturbance 

Townsend’s Bigeared Bat Arid regions and 

open forest types 

Buildings, caves, and 

bridges 

Moths primarily, 

flies, bugs and 

beetles 

Presence of suitable 

roosts more 

important than 

vegetation type; very 

intolerant of human 

disturbance 

Fringed Myotis Along forest edges, 

roads or open areas 

Caves, mines, rock 

crevices, buildings Primarily moths One offspring per season 

Existing Condition 

There are no abandoned building structures, caves or mines in the BLT analysis area (Hickerson, 

Archeologist, Crescent Ranger District personal comm. 2008). However, rock outcrops are present in 

the Little Deschutes River canyon that could provide rock crevices for day roosts. Snags for bat 

roosting habitat varies considerably across the analysis area with the highest snag densities per acre 

located in the mature stands of lodgepole pine and mixed conifer. Snag densities are also relatively 

high in the 80 acre Muttonchop Fire of 2000. 

There were no bat surveys conducted for this project and only limited surveys have ever been 

conducted on the Crescent Ranger District. Perlmeter (1996 and 1997) conducted bat surveys under 

several bridges of the Crescent Ranger District. Included bridges were a wooden bridge on Odell Creek 

and concrete and wooden bridges over Crescent Creek (outside the analysis area) and the Little 

Deschutes River on Highway 58. One long-eared myotis was detected day roosting under the Odell 

Creek concrete and wooden bridge during a 1996 survey. In 1997, there were no bats observed roosting 

under these bridges, although foraging activity was noted on both evenings mist nets were set up 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Rare, and Uncommon Species 

224

(Perlmeter 1997). A research study is currently underway in the Davis Fire area (outside the BLT 

analysis area) of the Crescent Ranger District to determine bat response to salvage harvest. 

The Viable Ecosystem model was used to determine an approximate number of acres of suitable habitat 

for those bats species associated with trees cavities, loose tree bark, or snags. The habitat definition 

used was all forest Plant Association Groups with a minimum live tree diameter of 10-15 inches. 

Modeling indicated there were approximately 35,169 acres of habitat that met this definition with the 

majority of this acreage present on National Forest system lands. Adjoining private lands were 

formerly managed for industrial timber production and have removed most trees of suitable diameter. 

Alternative A 

Direct and Indirect Effects 

This alternative would not potentially affect any bat roosting or maternity sites, including snags, rock 

outcrops, or lava pressure ridges. Bats where they occur would remain under current disturbance levels 

associated with ongoing activities, such as 800 acres of prescribed underburning. This alternative 

would have the greatest risk for loss of large trees from a widespread disturbance. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

Bats tend to use more than one snag or tree for roosting and may show fidelity to roost areas, rather 

than specific roosts (Ormsbee pers comm. 2005). An objective is to maintain and enhance late and old 

structured forests, focusing on the retention of large diameter trees. Although there is a difference in 

the number of potentially suitable acres treated by commercial thinning (3,217 acres Alternative B, 

2,566 acres Alternative C, and 1,121 acres Alternative D), each action alternative would retain the 

largest diameter trees in each harvest unit and encourage the development of smaller diameter trees as 

future replacements. There would be no intentional removal of snags although a small percentage may 

have to be removed to meet OSHA safety requirements and/or where the placement of temporary roads 

or landings may necessitate the removal of a limited number of snags. This short-term effect could be 

offset by snags intentionally created by prescribed burning and ongoing snag recruitment from natural 

successional process. 

In addition to bat species associated with caves, they also tend to use rock features such as outcrops or 

lava pressure ridges, which provide roosting and maternity habitat. Rock features are limited in the 

BLT analysis area and are mainly confined to rock outcrops in the upper Little Deschutes River canyon 

west of Hemlock Butte. There are no planned activities within approximately 1⁄2 mile of this formation. 

In addition mitigation measures have been provided to restrict all project activities on lava pressure 

ridges greater than or equal to 100 square feet in size, if they occur in the analysis area. Without this 

mitigation, bats could awaken while resting, which would interfere with their ability to conserve 

energy. This could have consequences dependent on the time of year. If they have young, it could 

potentially cause mortality as the bats move their pups and search for another suitable area. Also, 

disturbance would hamper the adults in storing fat reserves which are critical for surviving hibernation. 

While prescribed burning has the potential to disturb bats that may be roosting under the bark of snags, 

a Project Design Feature ensures prescribed burn plans are written to protect existing snags and rock 

outcrops. This measure for snag protection has been used extensively on the district and has proven to 

be effective. 

Cumulative Effects 

Table 3-1 was reviewed for actions that, in combination with the BLT project may have an additive 

effect. For bats, the most relevant discussion to assess effects from management activities is snag 

removal, since rock formations have been protected in the past and would continue to be protected in 

the future. There are also no known caves, mines, or abandoned buildings within the analysis area. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Rare and Uncommon Species 

225

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. The Maintenance Burn CE (2005), Prescribed Underburning 

and Mowing Project CE (1997) and the Rosedell CE (2005) overlap in time and space as the BLT 

project. These projects all call for snag retention. 

The majority of the private lands in the planning area are industrial forest timberlands and rock 

outcrops are not likely present on these lands. Snag densities are likely relatively low and any bat 

habitat provided is incidental. There would be no additive effects as incidental snag removal would be 

offset by natural and management activity-caused recruitment, such as prescribed underburning. As a 

result no additive effects to those discussed are present. 

 

Great Gray Owl

The great gray owl is a Management Indicator Species for the Deschutes National Forest and effects to 

this species and habitat is disclosed in the Management Indicator Species section in Chapter 3. 

Birds of Conservation Concern 

In January 2001, President Clinton issued an executive order on migratory birds directing Federal 

agencies to avoid or minimize the negative impact of their actions on migratory birds, and to take active 

steps to protect birds and their habitat. Within two years, Federal agencies were required to develop a 

Memorandum of Understanding (MOU) with the U.S. Fish and Wildlife Service to conserve migratory 

birds including taking steps to restore and enhance habitat, prevent or abate pollution affecting birds, 

and incorporating migratory bird conservation into agency planning processes whenever possible. 

Toward meeting this end, the U.S. Fish and Wildlife Service developed the Birds of Conservation 

Concern in 2002 and released the U.S. Shorebird Conservation Plan (2004). 

The “Birds of Conservation Concern 2002” (BCC) identifies species, subspecies, and populations of all 

migratory non-game birds that, without additional conservation protection actions, are likely to become 

candidates for listing under the Endangered Species Act of 1973. While all of the bird species included 

in the BCC are priorities for conservation action, the list makes no finding with regard to whether they 

warrant consideration for ESA listing. The goal is to prevent or remove the need for additional ESA 

bird listings by implementing proactive management and conservation plans. The U.S. Shorebird 

Conservation Plan (USFWS 2004, revised 2007) updated the 2001 Plan with new information and 

developed a list of U.S. and Canadian shorebirds considered highly imperiled or of high conservation 

concern. Conservation measures were not included but these lists should be consulted to determine 

reasons for conservation concern. 

Bird Conservations Regions (BCRs) were developed based on similar geographic parameters. One 

BCR encompasses the BLT analysis area – BCR 9, Great Basin. Table 3-73 displays the BCR species 

for this area, preferred habitat and whether suitable habitat is present in the analysis area. Birds 

appearing in bold type are those considered critically important by the U.S. Shorebird Conservation 

Plan as of March 2007. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

226

Table 3-73. Bird Conservation Region 9 (Great Basin) 

Bird Species Preferred Habitat Habitat in Analysis Area 

Swainson’s Hawk Open lands with scattered trees No 

Ferruginous Hawk Sagebrush-shrub steppe No 

Golden Eagle Elevated nest sites in open country Yes 

Peregrine Falcon Cliffs Yes 

Prairie Falcon Cliffs in open country Yes 

Greater Sage Grouse Sagebrush dominated rangelands No 

Yellow Rail Dense sedge marshes No 

American Golden-Plover Burned meadows/mudflats No 

Snowy Plover Dry sandy beaches No 

American Avocet Wet meadows No 

Black-necked Stilt Edges of Ponds and Lakes No 

Solitary Sandpiper Meadow/Marsh/Bogs No 

Whimbrel Marsh/Mudflats No 

Long-billed Curlew Grasslands No 

Marbled Godwit Marsh/Wet Meadows No 

Sanderling Sandbars and beaches No 

Long-billed Dowitcher Shallow Ponds and Lakes No 

Wilson’s Phalarope Marsh/Meadows No 

Yellow-billed Cuckoo Dense riparian/cottonwoods No 

Flammulated Owl Ponderosa pine forests Yes 

Burrowing Owl Non-forested grasslands No 

Black Swift Cliffs associated with waterfalls No 

Lewis’s Woodpecker Ponderosa pine forests Yes 

Williamson’s Sapsucker Ponderosa pine forests Yes 

White-headed Woodpecker Ponderosa pine forests Yes 

Loggerhead Shrike Open country with scattered 

trees/shrubs 

No 

Gray Vireo Pine/juniper woodland/sagebrush 

scrubland 

No 

Virginia’s Warbler Mountain Mahogany groves No 

Brewer’s Sparrow Sagebrush clearings in coniferous 

forests/bitterbrush 

Yes 

Sage Sparrow Sagebrush No 

Tricolored Blackbird Cattails or tules Yes 

The Peregrine falcon, Flammulated owl, Lewis’s woodpecker, Williamson’s sapsucker, White-headed 

woodpecker, Golden eagle, and Tricolored blackbird have been discussed in previous sections of 

Chapter 3 of the EIS. The following species have not been documented to occur and there is no 

suitable habitat present in the analysis area: 

Grassland species include: Swainson’s hawk, Long-Billed Curlew, Loggerhead Shrike, Burrowing 

Owl. 

Sagebrush, shrub-steppe habitat species include: Ferruginous Hawk, Greater Sage-Grouse, Sage 

Sparrow. 

Pinyon-juniper forest habitat species include: Gray Vireo and Virginia’s Warbler. 

Sandy beaches, alkaline lakeshore, or wetlands species include: Yellow Rail, American GoldenPlover, Snowy Plover, American Avocet, Black-necked Stilt, Solitary Sandpiper, Whimbrel, Marbled 

Godwit, Sanderling, Long-billed Dowitcher, and Wilson’s Phalarope. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

227

Riparian hardwood species include: Yellow-Billed Cuckoo. 

Waterfalls in true fir/mountain hemlock forests species: Black Swift. 

The following species from Table 3-73 remain to be discussed based on the presence of potentially 

suitable habitat in the analysis area. 

Prairie Falcon

Ecology and Existing Condition 

Gilligan et al. (1994) described prairie falcons as an uncommon to locally fairly common permanent 

resident in open country east of the Cascade Mountains and a rare fall and winter visitor west of the 

Cascades. Marshall et al. (2003) describes breeding habitat throughout the open country east of the 

Cascades Mountains in Oregon wherever cliffs and outcrops provide opportunities for nesting. A 

combination of rimrock or other outcrops and adjacent open country provides ideal breeding habitat and 

they usually nest on cliffs. However, they will also nest using natural depressions and old nests of other 

birds, most often those of the common raven. Small mammals and birds are the most common prey 

species. 

Within the analysis area prairie falcons have been observed stooping Belding ground squirrel colonies 

on privately owned meadows along the Little Deschutes River in Crescent, Oregon. Potential nesting 

habitat may be present on rock cliff faces west of Hemlock Butte in the upper Little Deschutes River 

canyon. There are no known prairie falcon eyeries in the analysis area. 

Effects Common to All Alternatives 

At the present time there are no known prairie falcon nesting eyries in the planning area. The nearest 

harvest units to potential suitable nesting habitat are located approximately one mile east of rock cliff 

faces near Hemlock Butte and the Little Deschutes River. If a nest eyerie for prairie falcons is 

confirmed in the area and has the potential to be negatively impacted by project activities, a limited 

operating period would be in effect from February 15 to August 15 to coincide with nesting and 

fledging season. With this measure in place there would be no direct, indirect, or cumulative effects 

expected to this species. There is no known nesting habitat for this species on private land in the 

analysis area and no additive effects are anticipated. 

The Landbird Strategic Plan 

The Forest Service has prepared a Landbird Strategic Plan (January 2000) to maintain, restore, and 

protect habitats necessary to sustain healthy migratory and resident bird populations to achieve 

biological objectives. The primary purpose of the strategic plan is to provide guidance for the Landbird 

Conservation Program and to focus efforts in a common direction. On a more local level, individuals 

from multiple agencies and organizations within the Oregon-Washington Chapter of Partners in Flight 

participated in developing a publication for conserving landbirds in this region. A Conservation 

Strategy for Landbirds of the East-Slope of the Cascade Mountains in Oregon and Washington was 

published in June 2000 (Altman 2000). This strategy has been used since its development in planning 

and project analysis. 

The BLT analysis area falls within the Central Oregon subprovince. The species selected in the 

conservation strategy represent focal species for habitats types or features considered at risk. 

Consistency with the Altman habitat recommendations are disclosed for those species listed in this 

section. Table 3-74 shows the focal species for the habitats that occur within the analysis area. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

228

Table 3-74. Landbird Focal Species for Central Oregon 

Habitat Habitat Feature Focal Species for Central 

Oregon 

Large patches of old forest with large 

trees White-headed woodpecker 

Large trees Pygmy nuthatch 

Open understory with regenerating pines Chipping sparrow 

Ponderosa Pine 

Patches of burned old forest Lewis’ woodpecker 

Large trees Brown creeper 

Large snags Williamson sapsucker 

Interspersion grassy openings/dense 

thickets Flammulated owl 

Multi-layered/dense canopy Hermit thrush 

Mixed Conifer 

Late-Successional 

Edges and openings created by wildfire Olive-sided flycatcher 

Lodgepole pine Old growth Black-backed woodpecker 

Meadows Wet/dry Sandhill crane 

Aspen Large trees with regeneration Red-naped sapsucker 

Subalpine fir Patchy presence Blue grouse 

Whitebark pine Old growth Clark’s nutcracker 

Existing habitat conditions and potential impacts to the white-headed woodpecker and Lewis’ 

woodpecker are discussed in the Threatened, Endangered, and Sensitive species section, and the pygmy 

nuthatch and flammulated owl are discussed in the Sensitive and Strategic species section. The blackbacked woodpecker and Williamson sapsucker are discussed in the Management Indicator Species 

section. The remaining species to be discussed from Table 3-74 are: 

Open Habitats/Open Understories with Regenerating Pine – Chipping Sparrow and Brewer’s 

Sparrow

Ecology and Existing Condition 

Both species are summer residents preferring open habitats with a shrub or grass component. Chipping 

sparrows occupy successional habitats after logging, burning and have an affinity for open stands, older 

stands of western mixed conifer forest (DeGraaf and Rappole 1995). In central Oregon they can be 

found in open coniferous forests or stands of trees interspersed with grassy openings or low foliage and 

are found in good numbers in central Oregon in juniper, ponderosa pine, and lodgepole pine forests 

(Marshall et al. 2003). Both species seem to be associated with higher elevations with the Brewer’s 

sparrow occupying the widest elevational band, up to 6,000 feet in the Cascades. The primary plant 

association used by the Brewer’s sparrow is big sagebrush however they are not limited to sagebrush 

habitats and utilize a variety of shrub habitats (Marshall et al. 2003). Brewer’s have also been observed 

along the Cascade summit in stunted mountain hemlock (Marshall et al. 2003). Breeding bird surveys 

have shown an annual 2.6 percent population decline in Brewer’s populations from 1966-1998. The 

reasons for the decline are unknown, but habitat loss to agriculture, cattle grazing and invasion of exotic 

plants have been implicated. Annual population declines of Chipping sparrow have averaged 3.9 

percent annually in Oregon due to decrease in wildfire to maintain open woodlands, but also due to 

cowbird brood parasitism and competition with house sparrows and house finches (Marshall et al. 

2003). District observation records do not have either species as documented but both species are 

assumed to occur in the analysis area. 

The majority of private lands along the analysis area boundary were managed as industrial timberlands. 

Currently, they are held in trust with much reduced harvest activity. This activity along the interface 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

229

with National Forest system lands is assumed to have created suitable habitat, providing foraging 

habitat in close proximity to nesting habitat on Federal lands. 

 

Alternative A – No Action 

Direct and Indirect Effects 

Selection of Alternative A would have no direct effects on the chipping sparrow and Brewer’s sparrow, 

at least in the short-term. Both species are associated with habitats of relatively open overstories with 

regenerating pine trees and patches of grasses or shrubs. In the longer term, in the absence of 

disturbance processes, suitable habitat within the analysis area would likely gradually decrease because 

of increased tree growth and a correlating increase in canopy, converting openings to more closed forest 

conditions. However, this alternative is likely on the shortest path to a future disturbance event that 

potentially would convert large areas to an early successional stage, which would remove tree structure 

necessary for some life processes. 

Effects Common to All Action Alternatives 

The Viable Ecosystem model was used to estimate acres of suitable habitat. The model used a 

definition for open canopied stands of lodgepole pine, ponderosa pine, white fir, and mountain hemlock 

with tree diameters 10-15 inches or larger. This definition resulted in an estimated 20,932 acres of 

potentially suitable nesting habitat that is well distributed and includes lands under private ownership. 

These lands have been managed for timber production. The selection of an action alternative would 

result in improved habitat conditions for both species in the short and long-term. In the short-term, tree 

thinning activities would open tree canopies, especially in the mid- and understory tree layers. 

Prescriptions for underburning in the ponderosa pine would especially provide those conditions most 

favorable - grassy openings and/or pockets of low shrubs. It is assumed this would be maintained 

through time. Because Alternative B proposes the most activity in current nesting habitat (1,947 acres), 

it would provide the greatest benefits over time. This is followed by Alternatives C and D (1,550 and 

743 acres), respectively. These activities are consistent with recommendations for chipping sparrows 

from Altman (2000), providing an interspersion of herbaceous ground cover with shrub and 

regenerating pine patches in ponderosa pine forests. As a conservation strategy, Altman (2000) also 

recommended thinning and/or understory removal occur to provide suitable open conditions. These 

same actions would also benefit the Brewer’s sparrow, which occurs in similar habitat conditions. 

It is possible that any operations conducted during the nesting season may impact breeding pairs of 

chipping sparrows and Brewer’s sparrows. This may result in pairs being displaced into adjacent 

habitats. However, the 743 to 1,947 acres of activity in existing nesting habitat represents only 4 to 9 

percent of the total available in the entire 5th field watershed. Because not all sales or activities would 

be active at the same time, undisturbed nesting habitat would be present and widely distributed. 

The Viable program projected all alternatives would result in an increasing trend in suitable nesting 

acres for these species. Modeling indicated there would be less than 240 acres difference between 

alternatives within each decade. 

 

Cumulative Effects 

Table 3-1 was reviewed for projects that, in combination with the BLT, would have the potential for 

overlap in time and space and result in additive effects. The zone of influence is defined as the 80,000-

acre 5th field watershed because it represents an area large enough to evaluate landscape processes. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time Baja West, Critter, and 

the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. These activities would be considered to increase suitable 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

230

habitat. As disclosed in direct and indirect effects, the activities conducted during breeding season may 

affect pairs of either species and it may result in pairs being displaced into adjacent habitats. However, 

this would be considered a very small portion of the 20,932 acres in the watershed and activities would 

be staged, providing ample and well distributed areas for undisturbed nesting habitat. For these 

reasons, the analysis of past actions other than those listed in this section is based on current 

environmental conditions. 

Chipping and Brewer’s sparrow populations are not expected to decrease as a result of the BLT or any 

additive effects. Proposed vegetation activities have been designed to reduce the risk of loss of late and 

old-forests and maintain this habitat over the long-term for LOS associated species. This is consistent 

with the recommendations stated by Wisdom to restore forest conditions that are more resistant to 

catastrophic fire, insect and disease problems. Project implementation would not lead to a trend toward 

Federal listing. 

Activities designed in the activities would be consistent with the Landbird Strategic Plan and 

conservation strategies because it maintains habitat features on the landscape that are considered at 

risk. 

Mixed Conifer, Large Trees – Brown Creeper

Ecology and Existing Condition 

The brown creeper is a common but inconspicuous permanent resident in most of Oregon (Gilligan et 

al. 1994). The brown creeper is the only North American bird that relies on both the trunk and bark of 

trees for nesting and foraging. It is found predominately in the coniferous forests but can also be 

located in oak woodlands, cottonwood stands, and in urban areas during the winter (Marshall et al. 

2003). Altman (2000) stated the brown creeper shows a preference for Douglas-fir, which offers better 

foraging opportunities in the deeply fissured bark. It nests under loose sloughing bark of large diameter 

snags with little to moderate decay. Nesting in Oregon can occur from near sea level to high in the 

mountains (Gilligan et al. 1994). Marshall et al. (2003) reported the diameters of nest trees in the Coast 

Range varied from 16 inches to 42 inches dbh with the mean diameter increasing as stands mature. 

Threats to this species include the loss of large diameter snags and live trees. Altman (2000) stated 

there was a non-significant short-term (1980-1998) increasing trend of 3.1 percent per year for the 

brown creeper in the Cascade Mountains Breeding Bird Survey Physiographic Region. This species 

has been observed in the older mixed conifer forests of the analysis area. 

The Viable Ecosystem model was used to determine an approximate number of nesting habitat acres. 

The definition used was all PAGs with tree diameters exceeding 15 inches with an open or closed 

canopy condition. This resulted in approximately 8,519 acres of nesting habitat which included some 

on private lands, likely because of scattered mid- and late-successional sized trees. The majority of the 

nesting habitat is widely distributed across National Forest lands particularly at the higher elevations 

such as the buttes and in the mixed conifer forests of the Oregon Cascades Recreation Area and Mt. 

Thielsen Wilderness. 

Alternative A 

Direct and Indirect Effects 

The selection of this alternative would have no immediate effect on the brown creeper and their 

habitats. All Plant Association Groups with trees greater than 15 inches diameter live trees and snags 

would continue to provide habitat for this species within the analysis area, particularly on the buttes, 

Oregon Cascades Recreation Area, and wilderness. However, in the long-term, stands and particularly 

the large trees would be at an elevated risk to a stand replacement event due to competition for scarce 

site resources. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

231

Effects Common to All Action Alternatives 

Direct and Indirect Effects 

All three action alternatives propose activities such as commercial and small tree thinning, disposal of 

slash, and additional prescribed underburning in ponderosa pine dominated stands. Outside of 

commercial harvest units, “fuels only” activities would include removal of live trees up to 8 inches in 

diameter. The amount of suitable nesting habitat affected by active management varies from 8 percent 

in Alternative B (705 acres), 7 percent in Alternative C (614 acres), and 2 percent in Alternative D (205 

acres). It is assumed prescribed burning would have no effect to habitat. 

Altman (2000) stated several studies have shown that 60 cm (24 inch) diameter was the mean nest tree 

diameter used by brown creepers. Vegetative prescriptions would maintain this size structure on the 

landscape. There would be no removal of live trees larger than 21 inches diameter on 2/3 of the lands 

managed under the Regional Forester’s Amendment #2. Within the boundary of the Northwest Forest 

Plan, removal of trees greater than 21 inches in diameter would be characterized as infrequent. Based 

on trees removed in similar stands on Seven Buttes, Baja, and Seven Buttes timber sales, less than 5 

percent of the trees were greater than 21 inches diameter. 

Wisdom (2000) and Altman (2000) listed some management recommendations for the brown creeper. 

The retention of blocks of late-successional habitat and retention of snags particularly those greater than 

21 inches in diameter snags would be appropriate. All snags would remain, although some may be 

felled for occupational safety, or where landings and temporary roads are placed. Burn plans are 

written to require the protection of snags to the greatest extent possible which may include handlining 

snags to prevent loss from fire (Chapter 2, Project Design Feature). Wisdom (2000) also recommended 

the retention of sufficient habitat to support this species while restoring forest conditions that are more 

resistant to catastrophic fire, insect and disease problems. This could require management activities, 

including prescribed fire, that reduce the dominance of shade-tolerant tree species and increase the 

presence of shade-intolerant tree species (i.e., those most resistant to catastrophic fire and insect and 

disease problems). The actions proposed in the BLT project would be consistent with these 

recommendations by conducting thinning to reduce the amount of fire intolerant tree species (e.g. true 

fir and lodgepole pine), retain the largest trees on the landscape and provide blocks of habitat suitable 

for the brown creeper. 

It is possible that any activity (thinning or underburning) conducted during the nesting season may 

affect breeding pairs of brown creepers. This may result in pairs being displaced into adjacent habitats. 

However, the 205 to 705 acres of activities planned represents a small portion of the suitable nesting 

habitat in the analysis area. Not all sales would be active at the same time leaving undisturbed nesting 

habitat widely distributed across the 80,000-acre watershed.

The Viable program projected an increasing trend of suitable nesting acreage for the brown creeper 

over each decade that was modeled (1, 2 and 5 decades) with all three action alternatives showing more 

nesting acreage than the no-action (Alternative A). After 5 decades modeling shows 21,383 acres in 

Alternative A, 21,584 acres in Alternative B, 21,550 acres in Alternative C, and 21,481 acres in 

Alternative D. Existing nesting acreage is 8,519 acres. 

Cumulative Effects 

Table 3-1 was reviewed for projects that, in combination with the BLT, would have the potential for 

overlap in time and space and result in additive effects. The zone of influence is defined as the 80,000-

acre 5th field watershed because it represents an area large enough to evaluate landscape processes. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No Significant 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

232

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. It is assumed brown creeper nesting capability was 

maintained on those acres. While the Viable program showed some suitable nesting habitat on private 

lands currently, they are held in trust with much reduced harvest activity. There are no other past, 

present or foreseeable actions with potential to overlap in space and time. 

Brown creeper populations are not expected to decrease as a result of the BLT project or result in any 

additive effects. Proposed vegetation activities have been designed to reduce the risk of loss of late and 

old-forests and maintain this habitat over the long-term for LOS associated species including the brown 

creeper. This is consistent with the recommendations stated by Wisdom to restore forest conditions that 

are more resistant to catastrophic fire, insect and disease problems. 

Activities designed in the activities would be consistent with the Landbird Strategic Plan and 

conservation strategies because it maintains habitat features on the landscape that are considered at 

risk. 

Mixed Conifer, Multi-layered/Dense Canopy – Hermit Thrush

Ecology and Existing Condition 

The hermit thrush is a summer resident preferring mid to high elevation mature and old growth forests. 

It breeds in mature forests of all types especially those with a shaded understory of brush and small 

trees ranging from aspen groves to juniper woodlands to moderately open coniferous forests. Gilligan 

et al. (1994) described the hermit thrush as a fairly common summer resident in the Cascades, Siskiyou 

and Blue Mountains and uncommon in the Coast Range of Oregon. Hermit thrushes nest on the 

ground, in brush or small trees. It is an opportunistic ground forager, feeding on insects and an 

occasional reptile or amphibian (Marshall et al. 2003). During the winter months, they are rarely seen 

east of the Cascades and tend to winter in the west-side lowlands and foothills along the coast. They 

are considered S4, apparently stable in Oregon (NatureServe 2008). There appears to be no serious 

conservation problems at this time (Marshall et al. 2003). 

The Viable Ecosystem model was used to approximate acres of suitable nesting habitat in the analysis

area. All existing activities, including past timber sales were included into the data input, up to 

September 2004. This is the most informative way to display effects. Using a definition of all PAGs 

with tree diameters exceeding 10-15 inches with a dense canopy resulted in an estimated 14,237 acres 

of nesting habitat. Private lands were included in the modeling and virtually all of the suitable acres are 

on National Forest lands, primarily in the very upper reaches of the Little Deschutes River of the Mt. 

Thielsen Wilderness and the Oregon Cascades Recreation Area. Smaller blocks of suitable nesting 

habitat are also present along the western analysis area boundary and the southern slope of Odell Butte. 

There are no hermit thrush occurrence records in the planning area but are assumed to be present. 

There have been no surveys conducted to determine species presence but they have been documented 

outside the analysis area near Crescent Creek Campground (Shunk 2001). 

Alternative A 

Direct and Indirect Effects 

The selection of this alternative would likely have no effect on the hermit thrush and their habitats in 

the short-term. Nesting habitat would be maintained and well distributed in the multi-layered, dense 

canopy stands of ponderosa pine and mixed conifer forests found on the buttes and within the streamside riparian zones of the Little Deschutes River, Basin Creek, Rabbit Creek, and Swamp Creek. 

However, this alternative has the highest risk from loss associated with competition for scarce site 

resources and future disturbance events that potentially lead to large scale loss of the largest trees which 

the hermit thrush is dependent upon. 

 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

233

Effects Common to All Action Alternatives 

All three action alternatives propose silvicultural and/or fuels treatments to improve overall stand health 

and maintain the presence of the dominant large overstory trees of Douglas-fir, ponderosa pine, sugar 

pine, Shasta red fir, white fir, and mountain hemlock. The acres of currently suitable nesting habitat 

potentially affected would vary by alternative from 1,270 acres (9 percent) of the total in Alternative B, 

followed by 1,016 acres (7 percent) for Alternative C and 378 acres (3 percent) Alternative D. 

Management actions in each alternative would result in the removal of smaller diameter trees 

(commercial and non-commercial) plus underburning in the ponderosa pine PAGs that would tend to 

decrease canopy layering and the vertical structure to a species that shows a positive association with 

areas of dense understory shrubs and small trees. The East Slope Cascade Mountains Land Bird 

Conservation Plan (Altman 2000) recommended as a conservation strategy to “retain tracts of forest 

unmanaged or lightly managed to ensure structural diversity” in mixed conifer forest. While this 

strategy is not specific to the hermit thrush, it would also benefit other species associated with multilayered, dense canopy stands with vertical cover such as the varied thrush, chestnut-backed chickadee, 

winter wren, and Townsend’s warbler (Altman 2000). Fuels treatments including underburning and the 

removal of small diameter green trees would affect habitat by also reducing stand layering and tree 

density but would also result in more resilient landscapes less susceptible to uncharacteristic 

disturbance events. 

A minimum of 15 percent of each activity unit would be retained and managed in a passive 

management scenario and where dense, multi-layered stands exist, would provide habitat for the hermit 

thrush. These areas would maintain dense shrub layers, where available. These areas are included in 

every activity unit regardless of management allocation and would be consistent with the strategy 

proposed by Altman (2000). 

The Viable program projected an increasing trend of suitable nesting acreage for the hermit thrush over 

each decade that was modeled (1, 2 and 5 decades) with all three action alternatives showing more 

nesting acreage than the no-action (Alternative A). This is due to trees becoming larger as competition 

is reduced and canopies becoming fuller. After 5 decades, modeling shows 35,321 acres in Alternative 

A, 36,950 acres in Alternative B, 36,625 acres in Alternative C, and 35,751 acres in Alternative D. For 

comparison, existing nesting acreage is 14,237 acres. 

Cumulative Effects 

Table 3-1 was reviewed for projects that, in combination with the BLT project, would have the 

potential for overlap in time and space and result in additive effects. The zone of influence is defined 

as the 80,000-acre 5th field watershed because it represents an area large enough to evaluate landscape 

processes. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. It is assumed these 1,310 acres in addition to the active 

management alternatives ranging from 378 to 1,270 acres, would remove hermit thrush nesting habitat. 

However, the effects discussed for direct and indirect effects would not change. The 15 percent 

passively-managed areas associated with each harvest unit and habitat provided in the adjacent Oregon 

Cascades Recreation Area and wilderness would provide for a network of suitable habitat for this 

species. For these reasons, the analysis of past actions other than those listed in this section is based on 

current environmental conditions. 

 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

234

No other past, present, and foreseeable actions overlap in time and space, or they avoided activity in 

hermit thrush habitat. The Viable modeling did not show any potentially suitable nesting habitat on 

private lands in the analysis area, likely due to tree size and limited canopy cover. 

 

While hermit thrush populations in the analysis area would likely decline in the short-term from 

activities in BLT and the overlap of the Baja, Critter, and Lower timber sales, populations would 

stabilize as unsustainable conditions of stands become more resilient to disturbance processes and 

larger trees become more dominant on the landscape. The Viable Ecosystem modeling showed an 

increasing trend of suitable nesting acres. Planned activities are consistent with Wisdom, 2000 

recommendations to limit disturbance processes to endemic levels and restoring wildlife habitat, and 

also with conservation strategies recommended by Altman (2000) for the hermit thrush and other mixed 

conifer associated species. 

Activities designed in the activities would be consistent with the Landbird Strategic Plan and 

conservation strategies because it maintains habitat features on the landscape that are considered at 

risk. 

Mixed Conifer, Edges and Openings Created by Wildfire – Olive-sided Flycatcher

Ecology and Existing Condition 

The Olive-sided flycatcher inhabits montane and northern coniferous forests up to 3,000 meters in 

elevation, especially in burned-over forest areas with tall standing dead trees (DeGraaf and Rappole 

1995). In Oregon, the flycatcher is a summer resident that breeds in low densities throughout 

coniferous forests. The olive-sided flycatcher is an aerial insectivore that prefers forest openings or 

edge habitats where forest meets meadows, timber harvest units, rivers, bogs or marshes (Marshall et al. 

2003). This species has not been documented to occur in the analysis area, but is assumed to be 

present. 

Alternative A 

Direct and Indirect Effects 

This alternative would have no direct or indirect effects on the olive-sided flycatcher. The flycatcher is 

considered a contrast species using old forests for nesting and either openings or gaps in old forests for 

foraging. Olive-sided flycatchers are positively associated with recent burns (Hejl 1994 cited by 

Wisdom et al. 2000). Habitat conditions in the 80,000 acre watershed would not change, at least in the 

short-term. Early-seral conditions within existing plantations would successionally progress as trees 

grow and increase in canopy cover. The Muttonchop Fire would continue to provide foraging habitat 

and nesting capability would be available in older stands adjacent to the fire. Breeding bird surveys 

(Sauer et al. 1996 cited in Wisdom et al. 2000) indicated a significant decline from 1966 to 1994 for 

olive-sided flycatchers in eastern Oregon and Washington of 2.5 percent per year. Marshall (1988 

cited by Wisdom 2000) suggested that changes in winter habitat have had a negative effect on olivesided flycatchers. However, Hann and others (1997 cited by Wisdom 2000) stated late-seral montane 

forest which provide source habitat for this species was tending to increase in more than 50 percent of 

the watersheds in the Southern Cascades - which includes the BLT analysis area. 

Effects Common to All Action Alternatives 

The Viable Ecosystem model was used to estimate acres of suitable habitat for these species and 

accounts for all past activity, including timber sales, up to September, 2004. The modeling definition 

used was for open canopied stands of lodgepole pine, ponderosa pine, white fir, Shasta red fir, and 

mountain hemlock with tree diameters 5 -10 inches or larger in the lodgepole PAGs and greater than 10 

inches in the remaining Plant Association Groups. This definition resulted in an estimated 25,469 acres 

of potentially suitable nesting habitat in the analysis area, including lands under private ownership. It is 

generally well distributed across the entire watershed. Action alternatives propose a combination of 

commercial thinning, non-commercial thinning, and fuels reduction activities to maintain stand health 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

235

and reduce the risk of large scale loss of large trees to wildfire, insects and disease. The selection of 

any of the action alternatives would improve habitat conditions, because this species prefers forest 

openings or edge habitats. 

Active management would result in a decrease in tree canopy cover, especially in the mid- and 

understory tree layers. Because Alternative B proposes 3,451 acres of treatment in current nesting 

habitat as opposed to 2,563 and 1,302 acres for Alternatives C and D, respectively, it would provide 

greater benefits to this species for a longer period of time. These activities would be consistent with 

strategies of thinning from below, burning and uneven-aged management cited by Wisdom (2000) to 

help accelerate the development of old-forest conditions and the juxtaposition of early-seral and lateseral habitats used olive-sided flycatchers. Wisdom (2000) stated that changes in fire regime has 

resulted in fewer, larger, and more destructive fires, thereby reducing the areas of juxtaposed early- and 

late-seral forests. Altman (2000) recommended the use of underburning to promote a shrubby 

understory for insect production, retention of standing dead or diseased trees where they occur, and that 

selective logging can be used to increase suitability of habitat as long as sufficient large living and dead 

trees are retained. These conditions would be promoted in each action alternative and would result in 

improving habitat conditions throughout the watershed. 

It is possible that activities conducted during the nesting season may impact breeding pairs. This may 

result in pairs being displaced into adjacent habitats. However, the 1,302 to 3,451 acres of treatments 

planned represents a small portion of the 25,469 acres of nesting habitat in the analysis area and not all 

sales or activities would be active at the same time. Regardless of the active management scenario 

chosen, undisturbed nesting habitat would be present and widely distributed across the planning area. 

The Viable program projected an increasing trend of suitable nesting acreage over each decade that was 

modeled (1, 2 and 5 decades) for all alternatives. Alternatives A, B and C show more suitable acres 

after each decade as compared to Alternative D. Projected nesting acreage after 50 years showed 

28,694 acres for Alternative A, 28,141 acres for Alternative B, 28,272 acres for Alternative C, and 

28,456 acres for Alternative D. Since this species prefers openings and edge habitat, this increase in 

habitat is due to existing plantations maturing and providing the structure necessary for nesting. For 

comparison, existing suitable acres are 25,469. 

Cumulative Effects 

Table 3-1 was reviewed for projects that, in combination with the BLT project, would have the 

potential for overlap in time and space and result in additive effects. The zone of influence is defined 

as the 80,000-acre 5th field watershed because it represents an area large enough to evaluate landscape 

processes. 

Viable Ecosystems modeling has accounted for all active management that has occurred in the BLT 

area (Upper Little Deschutes Watershed) up to September 2004. Since that time, Baja West, Critter, 

and the Lower timber sales from the Baja 58 Environmental Assessment and Finding of No Significant 

Impact have been completed (1,310 acres). These sales are characterized as understory thinning in 

mixed conifer, retaining the largest trees. Ongoing projects include 800 acres of prescribed burning in 

stands of ponderosa pine. For the olive flycatcher, these activities created additional suitable habitat 

conditions by opening forested stands. No other past, present, and foreseeable actions overlap in time 

and space. 

The majority of the private lands in the analysis area boundary are former industrial timberlands that 

are currently held in trust. Recent commercial thinning harvests on the interface with national forest 

system lands may have created more suitable habitat for the olive-sided flycatcher. The more open 

private lands would permit foraging habitat in close proximity to nesting habitat on Federal lands which 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

236

tend to have a greater densities of standing dead trees. This habitat condition may last for several 

decades or more depending on forest growth on private lands. 

In spite of some potential disturbance during the nesting season, not all activities would be occurring at 

the same time and undisturbed nesting stands would be available to this species on both National Forest 

and privately owned timberlands in the planning area. BLT implementation with overlapping projects 

is not expected to result in a decreasing population trend. Nesting habitat is being improved through 

thinning and underburning consistent with recommendations by Altman (2000). Viable modeling also 

shows an increasing trend in acres of nesting habitat. The BLT project is consistent with the Landbird 

Strategy. 

 

Activities designed in the activities would be consistent with the Landbird Strategic Plan and 

conservation strategies because it maintains habitat features on the landscape that are considered at 

risk 

Meadows – Sandhill Crane and Solitary Sandpiper

Ecology and Existing Condition 

Both species are rare residents associated with freshwater, high elevation meadow/marsh habitats. The 

sandhill crane utilizes floating nests while the solitary sandpiper is the only arboreal nesting sandpiper 

using other bird species nests. Both feed on aquatic and terrestrial invertebrates as well as small 

vertebrates. Little is known about the solitary sandpiper due to its solitary nature and limited 

occurrence on the landscape. Conversion of wetlands and predation of eggs and flightless young by 

coyotes, ravens, and other predators and loss of habitat on wintering grounds in California continue to 

be major threats to the sandhill crane (Marshall et al. 2003). Nesting sandhill cranes have been 

documented to occur in Big Marsh and pairs and individuals have been observed at Davis Lake during 

the breeding season. Both sites are located outside the BLT planning area. There are no documented 

sightings of solitary sandpipers on the Crescent Ranger District. 

Effects Common to All Alternatives 

There would be no direct, indirect, or cumulative effects to the sandhill crane or solitary sandpiper. 

Neither species have not been documented to occur on National Forest system or private lands in the 

analysis area, nor is there suitable habitat present. 

Aspen – Red-naped Sapsucker

Ecology and Existing Condition 

The red-naped sapsucker is a common summer resident from the eastern slopes of the Cascades 

eastward throughout the Blue Mountains and Wallowa Mountains but very rare west of the Cascades 

(Gilligan et al. 1994). It winters in the southern United States to central Panama, including southern 

California (DeGraaf and Rappole 1995). In western montane riparian habitats, the red-naped is the 

most abundant woodpecker and is a key provider of nest sites for secondary cavity nesters (DeGraaf 

and Rappole 1995). It breeds in deciduous and mixed deciduous-coniferous forests especially in 

woodlands with aspen. Dead or live trees with a central decay column are needed to excavate cavities. 

Threats to this species include long-term degradation of aspen and other riparian forest habitats from 

fire suppression and the lack of hardwood regeneration (Marshall et al. 2003). 

 

There is one 2-3 acre patch of aspen trees in the analysis area located south of the Little Deschutes 

River near harvest units #165 and #175. Red-naped sapsucker presence has not been documented in 

this location, although they have been documented to nest in several aspen stands east of the Two 

Rivers housing subdivision just outside the eastern extent of the analysis area boundary. Beginning in 

1999, the district began aspen regeneration and enhancement projects that have reduced conifer 

encroachment, fenced out big game and have conducted small scale underburns to enhance aspen 

sprouting on sites across the district. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

237

Effects Common to All Alternatives 

No alternative would affect this species because there would be no activity within aspen stands. The 

one known aspen site is located within the riparian reserves where Project Design Features avoid 

activity. Consequently, there would be no direct, indirect, or cumulative effects to this species from 

project implementation. It is unknown if aspen stands are present on private lands within the analysis 

area boundary. 

Because the Crescent District is currently conducting aspen restoration work, there should be a longterm increasing trend in habitat capability for the red-naped sapsucker District-wide. This would be 

consistent with recommendations from Altman (2000) for habitat objectives for the species. 

Subalpine Fir – Blue Grouse

Ecology and Existing Condition 

The blue grouse is the largest of the three forest grouse found in Oregon and is fairly common in the 

coniferous forests from the Cascade crest to the coast, but also found in the Blue and Wallowa 

Mountains of eastern Oregon. They utilize a variety of habitats in the spring and summer months with 

insects, berries and seeds of various forbs and shrubs providing the bulk of their diet. Pelren (1996 

cited in Marshall et al. 2003) stated open park-like stands of mature ponderosa pine and Douglas-fir 

were selected for wintering habitat where the grouse eat needles and buds. Pelren (1996) also stated 

that prescribed burning and other methods that maintain open park-like stands would likely benefit this 

species. Other winter range habitats include stands dominated by spruce, lodgepole pine, limber pine, 

western hemlock, and mountain hemlock (Zwickel 1992 cited in Marshall et al. 2003). Nesting habitat 

ranges from nearly bare ground with no overhead cover to dense vegetation beneath full forest canopies 

(Zwickel 1992, Pelren and Crawford 1999 cited in Marshall et al. 2003) with most successful nests 

beneath logs. 

While blue grouse are not common on the Crescent District, they can be observed in the analysis area 

along the upper Little Deschutes River canyon, Hemlock and Spruce Creeks, Beals Butte, Chinquapin 

Butte, Hemlock Butte, and Muttonchop Butte. The Viable Ecosystem model was used to determine 

estimated acres of nesting and wintering habitat for this species. For nesting and brood rearing habitat, 

the modeling definition used was all Plant Association Groups with open canopies and trees averaging 

less than 5 inches in diameter. This resulted in an estimated 67,965 acres of potential nesting and 

rearing habitat. For wintering habitat, all Plant Association Groups were used with tree diameters 

greater than 10 inches diameter and an open or closed canopy. This resulted in an estimated 35,169 

acres. There is likely some overlap in nesting and wintering habitat. 

Alternative A 

Direct and Indirect Effects 

This alternative would likely have little effect on blue grouse summer or wintering habitats at least, in 

the short-term. Mid- and late-seral stands in all Plant Association Groups would continue to provide 

winter habitat for this species. Nesting and brood-rearing lands would also not appreciably change. 

Current vegetative openings would experience natural successional development and increased levels of 

shade tolerant species, if conifers are present. Riparian zones would continue to provide buds and 

berries from native shrubs such as serviceberry, snowberry, bunchberry, wild strawberries and wild rose 

hips. 

Effects Common to All Action Alternatives 

Each alternative proposes activities that would open tree canopies. Post-harvest activities may include 

post and pole removal, non-commercial thinning, slash treatments and underburning which would occur 

within the ponderosa pine Plant Association Groups. Project activities would occur in summer range 

nesting and brood-rearing habitat on 6,758 acres in Alternative B, followed by 5,101 and 2,355 acres 

(Alternatives C and D, respectively). Project activities would occur in wintering habitat on 3,217 acres 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife- Birds of Conservation Concern 

238

in Alternative B, followed by 2,566 and 1,121 acres (Alternatives C and D, respectively). All actions 

maintain the largest diameter trees on the landscape. This would maintain wintering habitat. Wisdom 

et al. (2000 Vol. 2 p. 37) described wintering habitat as old-forest single story, old-forest multi-story, 

and understory re-initiation stages of interior Douglas-fir, western larch, Sierra Nevada mixed conifer, 

Pacific ponderosa pine, and interior ponderosa pine and mixed conifer woodlands. While Wisdom et 

al. (2000 Vol. 2. p. 38) noted that almost 40 percent of the watersheds in the southern Cascades 

experienced greater than 60 percent decline in wintering habitat from historical periods, implementation 

of the BLT project would not change wintering habitat conditions. He recommended the following 

strategies to improve wintering habitat for blue grouse: (1) retention of interior ponderosa pine, interior 

Douglas-fir and western larch old forests, (2) management of early-seral and mid-seral montane and 

lower montane forests to accelerate restoration of late-seral conditions of the previous species 

groupings and (3) retain remnant, large trees in all seral stages of montane forests. Pelgren (1996 cited 

in Marshall et al. 2003) stated in eastern Oregon, prescribed burning and other methods that maintain 

mature park-like stands would likely benefit the species. All of these strategy recommendations would 

be conducted in the BLT Project. 

Blue grouse during the summer months are considered a contrast species, typically found at the 

interface of forest and open areas (Zwickel 1992 cited in Wisdom et al. 2000 Vol 2. p.82). In the 

southern Cascades, summer range is on an increasing trend (Wisdom et al 2000). The following 

strategies were recommended to address summer habitat: (1) maintain and restore late-seral montane 

and lower montane forest, (2) increase the representation of shrub dominated early seral forests, (3) 

restore fire as an ecological process in the montane and lower montane community groups, and (4) 

maintain and restore riparian shrubland habitats (Wisdom et al. 2000). Activities prescribed in the BLT 

project would likely have little effect on summer habitat, since no regeneration harvest is proposed and 

the largest structure remains. The BLT activities proposed in both summer and winter habitat is also 

consistent with Altman’s (2000) recommendations to retain patches of subalpine forest with multilayered structure and shrub and herbaceous cover for hens and their broods. Incidental disturbance to 

nesting blue grouse may occur if activities happen to be conducted near nest sites in late spring (late 

April – through early June). Project implementation would be staged and would not occur at the same 

time, retaining ample areas for undisturbed nesting. 

The Viable program projected a decreasing trend in the amount of suitable nesting acreage for the blue 

grouse over each decade that was modeled (1, 2 and 5 decades) with all alternatives. This is the result 

of forested stands growing into a closed canopy condition and exceeding 5 inches diameter that no 

longer meet the nesting and rearing habitat definition. All three action alternatives show less reduction 

in nesting habitat than alternative A, although the difference is less than several hundred acres between 

alternatives. Current nesting habitat is projected at 67,965 acres and would decrease to 60,444 acres in 

Alternative A to 60,695 in Alternative D after 50 years. For wintering habitat all alternatives show an 

increasing trend in wintering habitat defined as forested stands with tree diameters greater than 10 

inches. While existing wintering habitat is 35,169 acres, projected increases range from 57,142 acres in 

Alternative A to 57,393 acres in Alternative D after 50 years. 

Cumulative Effects 

Table 3-1 of the BLT DEIS was reviewed for projects may overlap spatially and temporally that may 

result in an additive effect. Viable Ecosystems modeling has accounted for all active management that 

has occurred in the BLT area (Upper Little Deschutes Watershed) up to September 2004. Since that 

time, Baja West, Critter, and the Lower timber sales from the Baja 58 Environmental Assessment and 

Finding of No Significant Impact have been completed (1,310 acres). These sales are characterized as 

understory thinning in mixed conifer, retaining the largest trees. For the blue grouse, this was not 

considered to alter habitat. Ongoing projects include 800 acres of prescribed burning in stands of 

ponderosa pine which would be consistent with recommendations made by Wisdom et al. (2000) to 

restore summer range and maintain park-like stands for wintering habitat. For these reasons, the 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Birds of Conservation Concern 

239

analysis of past actions other than those listed in this section is based on current environmental 

conditions. 

Private lands (26,463 acres) were included in the modeling for the blue grouse and they have been 

managed for industrial timber production. Late-successional habitat would be described as rare on 

these lands, although individual trees or clumps of larger diameter trees are present. At the present 

time, private lands probably provide better nesting and brood-rearing habitat, although understory tree 

growth is rapidly occurring in the lodgepole pine dominated forests. 

Overlapping projects in addition to BLT would not result in any loss of wintering or summering habitat 

for the blue grouse; therefore no additive effects would occur. 

Clark’s Nutcracker 

Ecology and Existing Condition 

The Clark’s nutcracker is a resident along the crest of the Cascade Mountains, usually above 4,000 feet, 

although lower on the east slopes. They breed in open coniferous forests of pine, spruce-fir and 

adjacent Douglas-fir and less often in juniper and ponderosa pine east of the Cascades (Marshall et al. 

2003). In Oregon, their diet includes ripe and unripe seeds of whitebark, limber, Jeffrey, and ponderosa 

pines, and Douglas-fir and Shasta red fir plus spiders, insects, and small mammals. Large wingless 

seeds of white pines are preferred (Lanner 1996, Tomback 1998 in Marshall et al. 2003). Clark’s 

nutcrackers provide the sole mechanism of primary seed dispersal for whitebark pine (Hutchins and 

Lanner 1982 cited by Lorenz 2007). 

Clark’s nutcrackers are commonly seen during late summer and early fall at the higher elevations of the 

Crescent Ranger District, including the BLT planning area. District records do not list any known nest 

sites. 

Effects Common to All Alternatives 

The Viable Ecosystem model was used to estimate acres of suitable nesting habitat for this species. 

The definition used to model was Shasta red fir and mountain hemlock with tree diameters greater than 

15 inches with an open or closed canopy. This resulted in a total 2,363 acres all on National Forest 

system lands in the upper Little Deschutes River canyon and the upper reaches of Rabbit Creek and 

Basin Creek of the Oregon Cascades Recreation Area. None of the alternatives propose any 

silvicultural or fuels treatments in these stands; consequently there are no direct, indirect, or cumulative 

effects. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

240

Big Game - Deer and Elk 

The 80,000 acre BLT analysis area provides summer range habitat for mule deer and Rocky Mountain 

elk. Summering mule deer in the BLT area primarily migrate easterly across Highway 97, detouring 

north or south around Walker Rim to winter ranges in the desert beyond the district and Deschutes 

National Forest boundary. Rocky Mountain elk that summer in the analysis area scatter to several 

winter ranges including moving westerly into the Umpqua and Willamette River drainages and easterly 

across Highway 97 into the desert. Depending on weather conditions, the animals usually return to 

summer range beginning in March and April. Approximately 90 percent of the BLT analysis is within 

the Ft. Rock Big Game Management Unit. The northern most portion of the BLT analysis area is 

within the Upper Deschutes Big Game Management Unit. 

Big game management objectives (MO) for the Ft. Rock management unit are 11,200 deer. Counts in 

April 2007 concluded the estimated population was 5,800 deer which equates to 52 percent of the 

Management Objective. At the present time, the MO for deer in the Ft. Rock unit is believed to be 

close to the actual carrying capacity of the land (Hedricks, Oregon Department of Fish and Wildlife 

Habitat Biologist, pers comm. 2008). The MO for the Upper Deschutes unit is 2,200 deer and the 2007 

population was 1,100 or 50 percent of the MO (Ardt, Oregon Department of Fish and Wildlife habitat 

Biologist, pers comm. 2008). The elk MO for the Upper Deschutes unit is 700 animals. The estimated 

2007 population was 500 animals and the population is on a slow decline. The population decline for 

big game in central Oregon is likely attributable to a combination of several factors. These include 

residential development, disturbance from an increase in motorized and mechanized recreation, and an 

emphasis on forest policy to return the landscape to a more sustainable condition which ultimately 

reduces cover and forage availability. In addition, altered migration patterns due to an increase in 

highway traffic, poaching, and predation also contribute. Enforcement of prohibited motor vehicle 

access and violation of game laws has not kept up with the increase in population in central Oregon. 

The Deschutes National Forest Land and Resource Management Plan (Forest Plan) provides habitat 

management direction for big game animals. Mule deer summer range hiding areas must be present 

over at least 30 percent of each National Forest implementation unit. For this analysis, road densities 

and hiding cover are analyzed by subwatershed because they range 5,000-20,000 acres, they are large, 

and represent a reasonable area to analyze for hiding cover. To be a suitable hiding area, forested 

stands must meet one of several conditions: six acres or larger capable of hiding 90 percent of a 

standing adult deer from view of a human at a distance of 200 feet, six acres or larger with an average 

height of 6 feet and which has not been thinned in 15 years, or residual clumps of trees one half acre or 

larger within areas with advanced regeneration. This can include damaged or trees with poor vigor up 

to 7 inches in diameter and at least 12 trees greater than 7 inches per acre remaining after harvest 

(Forest Plan WL-54). Target open road densities are 2.5 miles per square mile to achieve deer summer 

range habitat effectiveness targets, unless impacts on deer can be avoided or the proposed project would 

result in a net benefit to deer habitat. The density will be applied as an average for the implementation 

unit and will be used as a threshold requiring further analysis. The final judgment on open road density 

will be based on the “further evaluation” rather than the density guideline (Forest Plan WL-53). 

 

The Forest Plan specifies habitat conditions to be provided for elk and identified key habitat areas 

across the forest. Portions of two Key Elk Areas (KEAs) are within the BLT planning area, Hemlock 

and Fly. Located south and west of the Two Rivers subdivision, the Hemlock KEA totals 2,511 acres, 

of which 2,342 acres are within the analysis area. Located at the western most portion of the analysis 

area, the Fly KEA overlaps 26 acres. Because no activity is planned within this KEA, the analysis will 

focus on the Hemlock KEA. 

Similar as for mule deer, the Forest Plan specifies road densities should not exceed an overall average 

between 0.5 – 1.5 miles per square mile within each KEA, unless impacts on elk can be avoided or the 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

241

proposed project would result in a net benefit to elk habitat. The road density will be applied as an 

average over a KEA and will be used as threshold for further evaluation. The final judgment on open 

road density will be based on the further evaluation rather than the density guideline (Forest Plan WL46). Hiding areas must be present over at least 30 percent of each KEA. To be a suitable hiding area, 

forested stands must meet one of several conditions: six acres or larger capable of hiding 90 percent of 

a standing adult elk from view of a human at a distance of 200 feet, six acres or larger with an average 

height of 10 feet and which has not been thinned in 20 years, or residual clumps of two acres or larger 

stands within units with advanced regeneration. This can include damaged or trees with poor vigor up 

to 7 inches in diameter and at least 12 greater than 7 inch trees per acre remaining after harvest (Forest 

Plan WL-47). In addition, thermal cover must be present over at least 20 percent of KEA in blocks at 

least 10 acres in size and have an average height of at least 40 feet. As a minimum, canopy cover must 

be at least 40 percent (Forest Plan WL-50). 

Existing Condition 

Roads 

Roads have long been identified as having adverse effects on big game populations. Recent studies at 

the Starkey Project in northeast Oregon (Wisdom 2005) have disclosed even more information on the 

effects of roads and road densities on deer and elk. Rowland et al. (2005) summarized the direct 

impacts of roads and associated traffic on elk, in addition to outright mortality from vehicular collisions 

as follows: (1) Elk avoid areas near open roads but it varies in response to traffic rates; (2) Elk 

vulnerability to mortality from hunter harvest, both legal and illegal, increases as open road density 

increases; and (3) In areas of higher road density, elk exhibit higher levels of stress and increased 

movement rates. Rowland (2005) also noted that elk use increased as distance from open roads 

increased and suggested that judicious closing of certain road segments, particularly road spurs, may 

retain or create blocks of habitat that serve as security areas for elk while allowing sufficient road 

access for other management needs. Hillis et al. (1991 cited in Wisdom 2005) suggested security areas 

be a non-linear block of hiding cover at least 250 acres in size and at least one-half mile from roads 

open to motorized traffic. 

Table 3-75 displays road densities in the BLT analysis area expressed in miles of road per square mile 

of land base within each subwatershed. This is the most informative and useful way to display effects 

from access. Open road densities within the analysis area can be expressed as either “objective” or 

“operational”. For example, the Seven Buttes Environmental Assessment Decision Notice and Finding 

of No Significant Impact overlaps the BLT analysis area and closed almost 100 miles of roads as part of 

the decision. Many of the roads have been closed, but not all due to budget and opportunity. That 

number is reflected in the “Operational Open Road Density”. A plan has been put in place on the 

District to alleviate this situation and physically close roads by priority. In addition, roads listed in this 

category do not receive maintenance and become effectively closed over time as vegetation returns. 

Total road density is expressed as all roads which are open or closed for each category. 

The objective open road density is the desired density that would be achieved if all roads were in their 

desired opened or closed status; the operational road density is a reflection of the current opened or 

closed status of roads within a given sixth field subwatershed. It is the desired level based on an 

interdisciplinary approach for access, including wildlife objectives, vegetation management, fire 

suppression, and public right of entry. The analysis for big game will use the Objective Road Density 

column to determine consistency with the Forest Plan, because it is assumed the Operational Open 

Road Density would continue to be reduced, plus, the BLT project does not add any permanent roads. 

Further, implementation of the Travel Management Rule is expected in 2009, before BLT would be 

implemented. When central Oregon forests and grasslands finalize this process, travel on Maintenance 

Level 1 (physically closed, or waiting to be closed) roads and off designated trail travel would be 

prohibited. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

242

Table 3-75. BLT Road Densities by Subwatershed Expressed in Miles per Square Mile 

Subwatershed 

Name

Operational Open 

Road Density

Objective Open 

Road Density

Total 

Road Density

Bunny Butte 

(All Roads) 3.99 2.86 4.15 

Bunny Butte 

(FS Roads Only) 2.14 1.02 2.31 

Clover Butte 

(All Roads) 1.82 1.29 1.84 

Clover Butte 

(FS Roads Only) 1.17 0.64 1.19 

Gilchrist 

(All Roads) 5.66 5.63 5.89 

Gilchrist 

(FS Roads Only) 1.30 1.31 1.57 

Gilchrist Junction 

(All Roads) 5.90 5.09 6.03 

Gilchrist Junction 

(FS Roads Only) 2.85 2.05 2.90 

Hemlock Creek 

(All Roads) 2.73 1.81 3.18 

Hemlock Creek 

(FS Roads Only) 2.09 1.16 2.53 

Little Odell Cr.

(All Roads) 4.95 3.24 5.64 

Little Odell Cr. 

(FS Roads Only) 3.72 2.03 4.43 

The road density levels displayed in Table 3-75 reflect conditions averaged over entire subwatersheds. 

Some watersheds include areas with very low road densities because they include wilderness, the 

Oregon Cascades Recreation Area (OCRA), and/or seasonally wet/riparian influenced vegetation where 

access is non-existent or limited. The overall high objective open road density (for all roads) in some 

subwatersheds is related to the amount of privately owned commercial timberlands currently under 

management by Cascade Timberlands. Although Table 3-75 also displays private ownership and roads 

that are present in each subwatershed, only National Forest system roads are used to calculate the 

standard. For example, two subwatersheds (Gilchrist Junction and Little Odell Creek) currently have 

operational (open) road densities on National Forest lands that exceed the 2.5 mile/square mile target 

for big game summer range. However, all subwatersheds have an objective open road density 

below the 2.5 mile/square mile target for summer range on National Forest lands and therefore 

meets the Forest Plan standard and guideline WL-53. 

Table 3-76. Open Road Densities within the Hemlock Key Elk Area 

Key Elk Area Operational Open 

Road Density

Objective Open 

Road Density

Total 

Road Density 

Hemlock Key Elk Area 5.24 2.35 5.90 

As displayed in Table 3-76, the road density for the Hemlock KEA exceeds the Forest Plan 

recommendation of 0.5 -1.5 miles per square mile of land. This is due to two major collector roads 

(5825 and 5830) that provide primary access to a considerable amount of National Forest system land. 

They also bisect the relatively small Key Elk Area, contributing to the high open road density. Based 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

243

on the objective open road density of 2.35 miles per square mile, the threshold density of 0.5 – 1.5 is 

unlikely to be attainable based on the current configuration of the Key Elk Area. Therefore a 

“further evaluation” is required. 

Current Vegetative Condition 

Subwatersheds 

In general, cover and forage areas are well distributed within each subwatershed and cover conditions 

exceed the minimums specified in the Forest plan in all six subwatersheds (Table 3-75). The majority 

of the Gilchrist subwatershed is under private ownership dominated by the Cascade Timberlands 

Corporation and extensive commercial timber harvest has occurred in this subwatershed. The Forest 

Service acquired some former private timber company lands in a land exchange in 1999 within the 

Gilchrist Junction and Bunny Butte subwatersheds. In spite of past timber harvest while under private 

ownership, extensive regeneration of lodgepole pine is contributing to a high level of hiding cover in 

each subwatershed. The remaining subwatersheds, while they have experienced regeneration and 

commercial thinning timber harvests, still have extensive tracts of hiding cover primarily dominated by 

lodgepole pine either as the dominant Plant Association Group or as a the major understory species. 

Antelope bitterbrush is the dominant browse species for mule deer in this area. This shrub is most 

commonly found in the lodgepole pine plant association but may also be found in stands of mixed 

ponderosa pine and lodgepole pine. Riparian habitat is found along the perennial streams in the 

analysis area including the Little Deschutes River and Hemlock, Spruce, Rabbit, Basin, and Swamp 

Creeks. 

While mule deer can be found virtually over the entire analysis area, the greatest densities tend to occur 

in the lodgepole pine or mixed lodgepole pine/ponderosa pine plant associations at lower elevations. 

The bands of elk in the project area tend to be closely associated with riparian habitats and wet meadow 

complexes. Small groups of elk can be found along the stream drainages, in the Oregon Cascades 

Recreation Area, and on the buttes east of Big Marsh. Table 3-77 displays the current cover/forage 

conditions within the Hemlock KEA. 

 

Table 3-77. Current Forage and Cover Conditions within the Hemlock Key Elk Area 

Key Elk Area Forage Cover 

Total 

Acres Acres % of Area Acres % of Area 

Hemlock Key 

Elk Area 2,511 1,250 50 1,261 50 

Hemlock Key Elk Area 

The cover column in Table 3-77 includes stands that meet both hiding and thermal cover definitions. 

Generally, thermal cover is located in the central and western portion where mixed conifer sites or 

ponderosa with a lodgepole understory provide the minimum 40 percent canopy and trees greater than 

40 feet tall. Hiding cover was defined as forested stands with greater than 190 tree stems per acre and 

between 1.2 inches and 10 inches in diameter. This may underestimate the actual number of acres 

(particularly in the larger tree classes) because the density of trees greater than 10 inches in diameter 

may compensate for stands that do not have 190 smaller stems per acre but still provide effective 

screening cover. The cover analysis was completed using the GNN (Gradient Nearest Neighbor) 

program. For more detail, a discussion of this technique is provided in Appendix B. Hiding cover is 

generally well distributed across the entire KEA. Forage areas include areas of beetle-killed lodgepole 

pine that was salvaged in the late 1990s in the eastern half that do not have the minimum trees per acre 

or tree height to provide hiding cover. In addition, the Spruce Creek/Hemlock Creek wet meadow 

complex in the center of the Key Elk Area is dominated by grasses and sedges. It is assumed hiding 

cover acreage would gradually increase and provide better screening over time as the lodgepole pine 

stands grow horizontally and vertically. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

244

 

Environmental Consequences 

Table 3-78 displays the expected change in deer hiding cover condition by subwatershed and alternative 

for National Forest System lands. 

Table 3-78. Change in Cover Condition by Subwatershed by Alternative on National Forest 

lands 

Clover Butte Subwatershed Hiding Cover 

(12,245 ac. National Forest) 

Alternative Hiding Cover 

Acres (%) 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining (%) 

A 8,982 (73%) 0 8,982 (73%) 

B 8,982 (73%) 358 8,624 (70%) 

C 8,982 (73%) 249 8,733 (71%) 

D 8,982 (73%) 203 8789 (72%) 

Hemlock Creek Subwatershed Hiding Cover 

 (16,867 ac. National Forest) 

Alternative Hiding Cover 

Acres (%) 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining (%) 

A 12,230 (73%) 0 12,230 (73)% 

B 12,230 (73%) 1,352 10,878 (65)% 

C 12,230 (73%) 1,060 11,170 (66)% 

D 12,230 (73%) 205 12,025 (71%) 

Gilchrist Junction Subwatershed Hiding Cover 

(4,659 ac. National Forest) 

Alternative Hiding Cover 

Acres (%) 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining (%) 

A 3,159 (68%) 0 3,159(68%) 

B 3,159 (68%) 1,100 2,059 (44%) 

C 3,159 (68%) 994 2,165 (47%) 

D 3,159 (68%) 427 2,732 (59%_ 

 Gilchrist Subwatershed Hiding Cover 

 (2,465 ac. National Forest) 

Alternative Hiding Cover 

Acres % 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining % 

A 1,592 (65%) 0 1,592 (65%) 

B 1,592 (65%) 330 1,262 (51%) 

C 1,592 (65%) 131 1,461 (59%) 

D 1,592 (65%) 161 1,431 (58%) 

Bunny Butte Subwatershed Hiding Cover 

 (8,518 ac. National Forest) 

Alternative Hiding Cover 

Acres (%) 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining (%) 

A 6,161 (72%) 0 6,161 (72%) 

B 6,161 (72%) 1,019 5,142 (60%) 

C 6,161 (72%) 814 5,347 (63%) 

D 6,161 (72%) 246 5,915 (69%) 

 Little Odell Subwatershed Hiding Cover 

 (9,349 ac. National Forest) 

Alternative Hiding Cover 

Acres (%) 

Hiding Cover 

Acres Reduced 

Hiding Cover Acres 

Remaining (%) 

A 6,898 (74%) 0 6,898 (74%) 

B 6,898 (74%) 1,718 5,180 (55%) 

C 6,898 (74%) 1,192 5,706 (61%) 

D 6,898 (74%) 621 6,277 (67%) 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

245

Table 3-79. Change in Cover Condition for Hemlock Key Elk Area 

 Hemlock Key Elk Area (2,511 acres) 

Alternative Hiding Cover 

Acres 

Changed31

Hiding Cover 

Acres 

Remaining 

Thermal 

Cover Acres 

Changed 

Thermal 

Cover Acres 

Remaining 

A 0 1,261 (50%) 0 713 (28%) 

B 223 1,038 (41%) 96 617 (25%) 

C 92 1,169 (47%) 52 661 (26%) 

D 0 1,261 (50%) 0 713 (28%) 

Alternative A 

Direct, Indirect, and Cumulative Effects 

Roads 

Under Alternative A, the existing road system would experience no changes in its current status and 

condition. Roads that are currently in custodial status (Maintenance Level 1) would remain closed and 

open roads would continue to provide access for recreational, commercial, and administrative functions 

in the same manner they currently do. Roads that have been scheduled to be closed under previous 

decisions would continue to be decommissioned according to the District-wide road closure plan. 

Vegetation 

Implementation of this alternative would result in no immediate change in the current cover condition 

within each subwatershed and key elk area. Within a ten year period, there would be a gradual increase 

in the amount and distribution of cover present within most subwatersheds. This is the result of 

increased tree growth in young forested plantations and also within older stands with multiple canopy 

layers that would provide increased capability to hide deer and elk from view. This alternative would 

remain at an elevated risk of a large disturbance process, particularly from insects and disease. An 

event of this magnitude has the potential to remove cover over large portions of the landscape. 

Effects Common to All Action Alternatives 

Roads - Subwatersheds 

None of the action alternatives would result in a change in permanent road access in the analysis area. 

No new permanent roads would be constructed. However, each action alternative will require the 

construction of temporary roads (9.7 miles Alt. B, 8.7 miles Alt. C, and 4.7 miles Alt. D) to facilitate 

economical removal of timber. These would be relatively short segments near the Little Deschutes 

River, Swamp Creek drainage, Bunny Butte, and east of Highway 58. Most are located within activity 

units. 

Temporary roads would be built in each of the six subwatersheds. In addition, some current 

Maintenance Level 1 roads that are in storage (closed) would be temporarily re-opened to provide 

access (22 miles Alt. B, 17 miles Alt. C, and 11 miles Alt. D). This temporary increase in open road 

density during project operations would likely result in elk moving away from open roads as noted by 

Rowland et al. (2005) in a study within the Blue Mountains of eastern Oregon. Because most sales 

generally operate for several years, this effect on elk may last several seasons. However, not all sales 

would be operating at the same time nor would every herd or band of elk in the analysis area be 

impacted since many tens of thousands of acres are not being affected by vegetation manipulation 

activities. The short-term increase in open roads is not expected to have an adverse effect on deer 

populations. Temporary roads, by their nature, are constructed to a low standard and are not intended 

for mixed vehicle use, nor are they intended to remain as identifiable facilities after the administrative 

need for their use has ended. At the completion of harvest and post-harvest activities (treatment of 

 

31 Some stands may possess both hiding and thermal cover 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

246

residual slash), all temporary roads would be barricaded to eliminate motor vehicle access and would be 

subsoiled as part of post-harvest soil remediation activities to facilitate their return to proper hydrologic 

function and vegetative productivity. Consequently, there would be no net increase in open road 

densities in any subwatershed after project work has been completed and roads have been re-closed. 

To minimize disturbance to deer and elk during the fawning/calving season, a limited operating period 

would be applied to activities near water sources during the period of May 1 through June 30 (Project 

Design Features, Chapter 2). This measure would eliminate the risk of calf and fawn abandonment 

and/or mortality related to disturbance if activities were conducted during the critical calving/fawning 

season. The efficacy of this measure is considered high forest-wide. 

Roads - Key Elk Area 

Alternative B would construct approximately 0.7 miles of temporary road to access unit 1130 in the 

Hemlock Key Elk Area. Some temporary displacement of elk may occur during the period when 

construction would occur and during timber harvest operations. After the completion of harvest 

operations and all post-sale activities, the temporary road would be closed to vehicle access. The 115 

acres of unit 1130 could be harvested in approximately 2-3 months depending on the operator and 

harvest schedules. There is unlikely to be any long-term disruption of elk use patterns as a result of the 

temporary road construction needed in Alternative B. Alternatives C and D do not include unit 1130 as 

a harvest unit. Consequently, there would be no change in road use in the Hemlock Key Elk Area with 

either of these alternatives. 

Road Density Further Evaluation and Direct/Indirect Effects to the Key Elk Area 

Based on the objective open road density of 2.35 miles per square mile for the Hemlock Key Elk Area, 

and the threshold density of 0.5 – 1.5 is unlikely to be attainable based on the current configuration, a 

“further evaluation” is required for Alternatives B and C. No activity would occur in Alternative D. 

Alternative B would construct approximately 0.8 miles of temporary road to access treatment unit 1130, 

although this unit is not part of actions proposed in Alternatives C and D. This would result in some 

additional motorized access in the area while the commercial harvest and post-sale activities are 

occurring. The estimated duration is for 2-3 years. The timing and method of restoration is as 

disclosed for the subwatersheds. While this may result in some elk displacement during the timeframe 

activities are occurring, animal use would likely shift to the center and southern portion of the area. 

This is where the majority of the wet meadows and stringer lodgepole pine and spruce stands are 

located and where past road construction has been avoided because of the concentration of riparian 

habitat. This would allow elk use of several hundred acres of foraging and cover habitat free of 

disturbance and greater than 1/2 mile from an open road consistent with recommendations made by 

Hillis et al. (1991 cited in Wisdom 2005). 

 

Actions designed in Alternatives B and C would have a net benefit to the Hemlock KEA. Because the 

project’s purpose and need is to reduce the risk of large-scale loss of forest, the proposed activities 

would be consistent with managing big game habitats for the long-term. Maintaining a well distributed 

mix of forage and cover blocks for the long-term in the Key Elk Area is a desired objective, as is 

reducing risk of losing these habitat components in another large event similar to the mountain pine 

beetle epidemic in the 1980s. Although much of the area was affected, many mature stands of 

lodgepole pine avoided the epidemic and now are susceptible to another wide-scale disturbance. Also, 

the Hemlock Key Elk Area is adjacent to Two Rivers Subdivision, a populated area with homes. While 

commercial harvest and fuels reduction activities would result in an overall short-term loss of hiding 

and thermal cover, they would be proactive measures, and reduce the risk of long-term loss of forest, 

benefiting adjacent homeowners. As shown from Table 3-79, even with planned thinning actions, the 

post-harvest cover conditions would exceed Forest Plan minimums for hiding and thermal cover 

objectives. Because the majority of the area is dominated by lodgepole pine stands, reduction of cover 

in activity units may last for several decades until the understory regenerates to a height providing 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

247

effective hiding cover. However, this is offset by stands in the Key Elk Area where a passive 

management scenario continues to advance successionally and bring additional cover online. 

This evaluation concludes that the net effect of the BLT proposed activities on the Hemlock KEA is 

consistent with Forest Plan wildlife objectives for the following reasons. 

1. While the Hemlock KEA may exceed the 0.5 – 1.5 miles per square mile target there are areas 

within the KEA with lower road densities and capable of providing large security blocks of 

cover. 

2. The temporary roads will be obliterated after the completion of all harvest and fuels related 

activities. 

3. All currently closed roads re-opened for access to treatment units would be closed to vehicular 

traffic after the completion of forest management activities. 

4. Implementation of the BLT would result in no net increase in open road densities after project 

completion. 

5. While Alternatives B and C propose 223 acres and 92 acres of activities (respectively) that 

would result in a short-term loss of hiding and thermal cover, they would be proactive 

measures, and reduce the risk of long-term loss of forest, benefiting the Key Elk Area and 

adjacent homeowners. 

Vegetation Effects 

Subwatersheds 

Each action alternative proposes a combination of commercial thinning and post-sale activities 

including non-commercial thinning, post and pole sales, and fuels treatments (firewood removal and 

underburning) that will change the vegetative character of affected stands. In most instances the 

reduction in tree densities would open the forested stands resulting in increased visibility and less 

effective hiding cover for big game. Conversely, opening these stands would increase the amount of 

sunlight reaching the forest floor and result in increased potential growth to forage species, particularly 

Antelope bitterbrush. In those harvest units where the desired condition is to move toward a latesuccessional single story habitat (e.g. ponderosa pine-dominated plant associations), viewing distances 

into affected stands would generally be greater than where a multi-story forest would be maintained 

post-harvest. Because Alternative B would have activities over the greatest number of acres that 

provide hiding cover (5,877 acres) as compared to Alternative C (4,440 acres) and Alternative D (2,103 

acres), it would create more foraging habitat for at least several decades. Because Alternative B also 

proposes more underburning in ponderosa pine plant associations than Alternatives C and D, there 

would be less bitterbrush retained within burned units. To retain more forage in this situation, 

prescribed burn plans would be required to leave 30-40 percent of the shrub component unburned in 

each unit for big game browse and nesting habitat for birds (Project Design Features, Chapter 2). This 

measure has proven to be effective, given the challenge of rapidly changing weather conditions 

following ignition. 

Table 3-79 displays the change in cover conditions as a result of implementing each action alternative. 

None of the subwatersheds would fall below the 30 percent cover level objective specified in the Forest 

Plan. For this analysis, it is assumed all silvicultural treatments within stands that formerly provided 

hiding cover would be converted to a foraging classification. Although this is a conservative 

assumption and some stands may continue to provide cover following harvest, most would not, 

especially where the site-specific objective for the stand is to maintain an open condition (e.g. 

ponderosa pine-dominated plant association groups). In this scenario, it would be considered a longterm effect. Because a minimum of 15 percent of each activity unit would be managed in a passive 

management condition regardless of Northwest Forest Plan or Eastside Screen allocation, welldistributed patches of hiding cover would be maintained in each harvest unit. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

248

Cumulative Effects 

There are no additive effects as a result of past, present, and foreseeable projects identified. Table 3-1 

was reviewed for past and foreseeable projects that have the potential to overlap in time and space, 

resulting in a cumulative impact. The zone of influence used was the 80,000 acre analysis area because 

it is large, and represents a reasonable area to analyze for effects to a big game herd. The current 

existing condition accounts for all past actions on Federal lands because that is the format most 

informative and useful for the public and Deciding Official. In addition, natural events such as 

windstorms, lightning and human-caused wildfires, and bark beetle attacks have also contributed to the 

current forage and cover distribution across the analysis area. 

There are no foreseeable actions except the small diameter thinning program which overlap the zone of 

influence. Small tree thinning is an annual activity and was accounted for up to the present. Beyond 

2008, it is not considered a foreseeable action because details for future small tree thinning are 

unknown and no scoping has occurred. 

The Deschutes National Forest is currently in the process of conducting a Forest-wide Travel 

Management Plan to review and make recommendations to our current motorized access system. This 

process will do three things: 

• Designate specific conditions, if any, under which existing routes or areas will continue to 

provide for sustainable motorized use considering a variety of societal and resource factors 

• Identify existing roads, trails, and areas that will continue to support sustainable motorized use 

• Identify potential motorized routes and/or areas that could be added to the forests and grassland 

transportation system for motorized use. 

This process will also consider the Forest Plan guidelines for open road densities on big game summer 

range. 

Approximate 26,463 acres of private land in the analysis area is industrial timber production lands and 

has been accounted for in the existing condition. Industrial timberlands tend to have high open road 

densities unless closed to reduce liability issues, illegal dumping or other issues. The private industrial 

timberlands are located in the northern portion of the BLT area. The current high open road density on 

private lands likely lowers the effectiveness of this land use for big game, especially elk. However, the 

in-growth of younger aged trees on these lands will rapidly develop into large areas of hiding cover for 

deer and elk. This may result in reduced big game harvest on these lands when visibility is reduced 

over the next couple years, dependent upon small tree thinning. 

Connectivity and Fragmentation 

Existing Condition 

Late and old successional (LOS) habitat is an element of the “Interim Management Direction 

Establishing Riparian, Ecosystem and Wildlife Standards for Timber Sales in the Regional Forester’s 

Eastside Amendment #2” (Screens). This amendment requires the identification of connectivity 

corridors designed to connect designated old growth areas and LOS habitat types across the landscape. 

These corridors are to allow movement and interaction of adults and dispersal of young of LOS or old 

growth associated species. Corridors do not necessarily meet the same description of “suitable” habitat 

for breeding, but allow free movement between suitable breeding habitats. It is important to insure that 

blocks of habitat maintain a high degree of connectivity between them and that blocks of habitat do not 

become fragmented in the short-term. Connectivity corridors are considered stands in which medium to 

larger trees are common, and canopy cover are within the top-third of site potential. Stand widths 

should be at least 400 feet wide at their narrowest point, unless it is impossible to meet the 400 foot 

with current vegetative conditions. If stands meeting these descriptions are not available, the next best 

available habitat would be identified. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

249

Removal of trees within connectivity corridors is permitted if all the criteria in the above can be met 

and if understory is left in patches or scattered to assist in supporting stand density and cover. 

Understory removal, stocking control, and salvage are potential activities that can occur. In stands that 

do not currently meet LOS standards, non-regeneration or single tree selection activities should proceed 

only if the prescription moves the stand towards LOS conditions as soon as possible (USDA 1995). 

Connectivity corridors have been identified and mapped and shown as Figure 3-25. The placement of 

the corridors reflects habitat conditions currently present, regardless of management allocation and 

considering past timber harvests including salvage operations from the mountain pine beetle epidemic 

of the 1980s. Medium and large size trees are present in most of the corridors although small diameter 

trees likely comprise the majority of the stems per acre. Most of the corridor acreage has multiple 

canopy layers regardless of the Plant Association Group. There are at least two connectivity corridors 

between allocated old growth areas. Within the BLT planning area there are approximately 53,518 

acres (National Forest System lands and private ownership) within the Eastside Screens. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

250

Figure 3-25. Connectivity Corridors 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

251

Environmental Consequences 

All alternatives are consistent with the Eastside Screens by maintaining the size, composition and 

number of connections between late and old stands. Also, no trees over 21 inches in diameter within 

the boundary of the Eastside Screens would be harvested (Project Design Criteria, Chapter 2). 

Alternatives A 

Direct and Indirect 

Implementation of this alternative would result in no active management within the 1,616 acres that 

have been mapped as connectivity corridors. The structural complexity and existing canopy cover 

within the corridors would remain unchanged, at least in the short-term. On many stands of drier 

ponderosa pine and lodgepole pine plant associations stocking densities would remain above desired 

levels. Vegetation successional processes would continue to occur that may include an increased 

overstory canopy cover and tree height and the formation of multiple canopy layering favorable to some 

species. However, over the long-term this alternative may also increase the risk of overstocked stands 

becoming susceptible to large tree loss from wide-scale disturbance events. 

Alternative B 

Direct and Indirect Effects 

Alternative B would implement commercial timber harvest and post-sale activities on 257 acres of the 

1,616 acres (16 percent) of the connectivity corridors in the planning area. Active management would 

reduce the tree density on overly dense late-successional stands and advance the growth and 

development of younger-aged stands toward late-successional conditions. Standards and Guidelines for 

the East-Side screens for snag retention, down woody debris, and unthinned areas would apply and 

provide habitat continuity for woodpeckers, songbirds, mammals, and other wildlife species. Activities 

would be consistent with the Screens by maintaining the medium to large trees. While canopy cover 

would be reduced, it would remain above the top third for site potential as prescribed for the Screens. 

Project implementation may result in even fewer acres of corridors being actively managed because 

portions of wildlife retention areas may be incorporated into the corridors. Overall, tree thinning to 

alleviate competition for scarce resources would likely result in an increased ability to maintain 

medium and large trees within the corridors. 

Alternative C 

Direct and Indirect Effects 

Alternative C would implement commercial timber harvest and post-sale activities on 202 acres or 13 

percent of the acres identified and mapped as connectivity corridors in the planning area. Similar 

commercial thinning and post-sale activities would occur in this alternative as described for Alternative 

B. While canopy cover would be reduced, it would remain within the top third of site potential 

depending on the plant association and site specific conditions. This would result in a more open 

condition favorable to some species that prefer less canopy, but would provide adequate cover and 

structure to facilitate travel by most species likely to use corridors. Thinning would promote the 

development of larger trees by reducing stand density and competition for scarce resources and improve 

forest resilience where actively managed. Where thinning occurs within young stands, thinning 

designed to promote the development of large trees would likely improve habitat conditions within the 

corridors in the long-term. Underburning may occur in the ponderosa pine plant associations although 

clumps of multi-layered stands, where they occur, may also be retained. Similar to Alternative B, the 

placement of wildlife retention areas may result in fewer actual acres of the corridors being treated than 

the 202 acres predicted. Site specific wildlife retention areas would not be known until sale layout. 

Alternative D 

Direct and Indirect Effects 

Alternative D would implement commercial timber harvest and post-sale activities on only 25 acres, or 

2 percent of the total connectivity corridor acreage mapped in the planning area. Similar to Alternatives 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

252

B and C, there would be an expected decrease in canopy cover where commercial thinning and postsale activities (non-commercial thinning, piling and burning of slash generated) would occur. While 

canopy cover would be reduced the level of retention would still provide adequate cover and structure 

to facilitate species travel. Where thinning would occur within young stands, thinning designed to 

promote the development of large trees would likely improve habitat conditions within the corridors in 

the long-term. 

Cumulative Effects Common to All Action Alternatives 

The zone of influence is the BLT analysis area and connections made to LOS stands outside the Screen 

boundary. All past and present timber sales and activities, including Baja EA were accounted for when 

mapping connectivity corridors (Figure 3-25) because it is the most informative way to display 

connections rather than cataloguing each individual activity. For these reasons, the analysis of past 

actions other than those listed in this section is based on current environmental conditions. Foreseeable 

actions were reviewed from Table 3-1. There are no foreseeable actions that overlap the connections in 

space or time; therefore, there are no cumulative effects expected. 

Forest Fragmentation 

Li and Reynolds (1999) defined forest fragmentation as the processes of increasing the number of 

landscape pieces, decreasing interior habitat area, increasing the extent of forest-opening edges, or 

increasing isolation of residual forest patches. The primary force causing changes in the fragmentation 

patterns are human-caused disturbances (Butler et al. 2003). Since the late 1800s, timber harvesting 

and fire suppression have replaced natural disturbances as the primary forces shaping forest landscapes 

(Rochelle 1999). In low-elevation forest land in western-Washington and Oregon, a significant 

proportion of the forest has been converted to other uses such as agriculture and suburban development, 

resulting in long-term or permanent habitat loss and forest fragmentation (Rochelle 1999). In 

November 1998, a scientific conference was held in Portland, Oregon entitled “Forest Fragmentation: 

Wildlife and Management Implications”. The conference was convened to provide a synthesis of the 

current state of knowledge related to fragmentation in managed forests of the Pacific Northwest. 

Rochelle (1999) synthesized key points from the authors’ papers and conference presentations. Some 

of the key findings from the conference included: 

 Northwest forests were naturally fragmented by disturbances such as fire and disease; small 

patches dominated east-side forests; larger patches characterized west-side forests. In drier 

east-side forests over time, fire suppression “de-fragments” patterns of fuel distribution and 

increasing the potential for large wildfires. 

 Fragmentation usually co-occurs with habitat loss and the response of vertebrate populations 

differs, and for most species the effects of habitat loss are more significant than changes in 

habitat pattern. 

 Both positive and negative effects of forest “edge” have been documented in recent research. 

Leaving relatively small amounts of habitat structure (e.g. shrubs, snags, decaying wood, live 

conifers and hardwoods) after harvest apparently makes the areas (matrix) between habitat 

patches more hospitable, so that movement and dispersal of many species may be enhanced. 

 In the east and Midwest, many studies document increased predation and parasitism near edges; 

in the Pacific Northwest, researchers have found little effect of patch area or negative edge 

effects, nor does there appear to be strong evidence of bird species requiring only forest interior 

habitat (Kremsater and Bunnell 1999, Bunnell et al. 1997 cited in Rochelle et al. 1999) 

 In western forests there is little evidence of negative edge effects (Kremsater and Bunnell 1999 

in Rochelle 1999) and reflects the fact that stands of different ages do not act as habitat islands, 

are not surrounded by agricultural habitat and exist in a mosaic where edges are continually 

changing. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Wildlife – Deer and Elk 

253

Existing Condition: The 80,000-acre BLT analysis area could be described as a relatively contiguous 

forested block broken only by several meadow complexes, the Little Deschutes River, and several 

housing subdivisions. Large lakes, reservoirs or lava formations are not present in this planning area, 

which can interrupt a connected forested landscape. There is a noticeable difference however, in forest 

types as a result of changes in physiography, geology, soil types, and aspect that affect which tree 

species are best suited to the growing condition. Human induced fragmentation has occurred through 

the design and placement of a forest road network and regeneration timber harvest program that began 

in the 1950s and ended in the early 1990s. Private land holdings, some of which are rural housing 

subdivisions, have also created to the fragmentation present within the watershed. Road access to 

recreation areas and blocks where timber stands were regenerated, generally less than 40 acres in size, 

have cumulatively created a currently fragmented (increased amount of edge) forest landscape over 

many of the buttes and lowlands outside designated wilderness and the Oregon Cascades Recreation 

Area. However, the only permanent loss of forest stands is those that were removed for permanent road 

access and for housing subdivisions on private lands. The regeneration harvest blocks have been replanted with trees and would - over the next several decades - result in a much reduced fragmented 

landscape with less edge, as stands become mid-successional aged (greater than 40 years). During the 

interim, early-seral associated wildlife species benefit from a landscape that provides some of this 

habitat type. 

Future fragmentation would likely be the result of disturbance events such as wildfire, forest loss to 

insects or diseases or small openings created by partial cut timber harvest. Kremsater and Bunnel (1999 

cited by Rochelle et al. 1999) stated there is little available data on potential edge effects in the small 

openings created by partial cutting in the Pacific Northwest, or on edges between old growth and older 

second-growth stands. Neither of these effects is likely to be large because openings may be too small 

and the structural contrasts are also relatively small. 

Private lands within the analysis area are primarily industrial forest timberlands which have 

experienced several commercial thinning entries over the last 6-7 years. However, most of this acreage 

remains stocked with trees at varying densities and sizes. Long-term and/or permanent forest 

fragmentation on these lands is unlikely as long as these lands remain as industrial forestlands and not 

converted to other uses. There are also several housing subdivisions scattered within the analysis area 

with undeveloped lots generally less than several acres in size. Potential conversion of these lots to 

home construction is likely but would not appreciably contribute to forest fragmentation because of 

their small size and the amount of fragmentation that has already occurred in the subdivisions. The 

subdivisions are located along the Little Deschutes River above and below Highway 58. 

Environmental Consequences 

Alternative A 

Direct and Indirect Effects 

Implementation of this alternative would result in no immediate change from the current vegetative 

condition in the analysis area. The regenerated stands of forest would continue to grow resulting in less 

edge habitat in the planning area. This would benefit wildlife species generally associated with 

increasing levels of canopy cover and larger tree diameter by providing a more connected forest 

landscape. Those wildlife species more closely associated with early-seral forests would gradually 

decrease in population and distribution as these stands mature. In addition, stands would be at greater 

risk to fragmentation as a result of wide-scale disturbance processes. 

Effects Common to All Action Alternatives 

Proposed activities would not create additional habitat fragmentation to mid- or late-seral forested 

stands in the analysis area. Implementation of an active vegetation management scenario would 

generate little change to the current condition in the analysis area. While no regeneration timber 

harvest is proposed, active management (thinning and fuels reduction work) would reduce the risk of 
BLT Project Environmental Impact Statement 

Chapter 3 – Wildlife – Deer and Elk 

254

another event with potential to fragment the analysis area (“Fire and Fuels” and “Forested Vegetation” 

Chapter 3). Silvicultural and fuels prescriptions have been designed to maintain forest structure for the 

short- and long-term resulting in no increase of forested lands being converted to other uses such as 

commercial development. While commercial timber harvest would occur from forest thinning, LOS 

habitat conditions would be maintained. Within non-LOS stands, the objective is to advance the growth 

of the younger aged or smaller diameter stands. Agee (1999 cited in Rochelle et al. 1999) stated that 

most forest restoration strategies are specifically designed to fragment the continuous fuel across the 

interior West landscapes. Fragmentation in this context discussed by Agee does not necessarily affect 

interior habitat area or create edge effect. 

There would not be any permanent road construction. However, to facilitate efficient removal for 

timber harvest, temporary road construction would be needed. Approximately 9.7 miles would occur 

for Alternative B, 8.7 miles for Alternative C, and 4.7 miles for Alternative D. This would equal 20 

acres converted to temporary road (Alt. B), 17 acres (Alt. C) and 9 acres for (Alt. D). Temporary roads 

are generally less than 16 feet in width and would be restored to proper hydrologic function after their 

intended use, usually within five years (or less) of the initial activity. Natural re-vegetation of subsoiled 

roads would occur as shrubs and tree species begin seeding in. On the Crescent Ranger District, due to 

available seed source, vegetative recovery on subsoiled roads is usually established within 5 years 32. 

Temporary road construction has effects that have been disclosed for other resources in this analysis 

(“Soils”, “Threatened and Endangered Species”, “Big Game”, “Fisheries,” ”Hydrology and Water 

Quality,” “Cultural Resources,” and “Irreversible and Irretrievable Commitment of Resources” in 

Chapter 3). However, these effects are considered temporary and short-term in nature (less than 5 

years). This activity would not be considered to change the existing continuity of the forest or result in 

any long-term edge habitat throughout the 80,000-acre planning area. Also, the potential for 

introduction of invasive plants associated with temporary road construction is discussed in the section 

titled “Invasive Plants” in Chapter 3 of this EIS. 

Cumulative Effects Common to Action Alternatives 

There have been no past, present, or foreseeable actions identified that have the potential to create 

additional habitat fragmentation to mid- or late-seral forested stands in the analysis area. All past and 

present timber sales and their potential to create habitat fragmentation were reviewed using the latest 

activity layer in Geographical Information Systems. 

 

32 Ken Kittrell, Transportation Manager for the Crescent Ranger District, June, 2006. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Old Growth Management 

255

Old Growth Management ______________________________ 

Existing Condition 

There are four designated Old Growth Management Areas (OGMAs) that total 1,172 acres in the 

analysis area (Figure 3-26). 

Little Odell OGMA (348 acres) is located southwest of Little Odell Butte. This OGMA is 

predominantly lodgepole pine with focal species of three-toed woodpeckers and marten. District 

records do not list any marten or three-toed woodpeckers sightings in or near this OGMA. 

Muttonchop OGMA (361 acres) is located on Muttonchop Butte with focal species of goshawk and 

marten. This OGMA is dominated by sugar pine and ponderosa pine on the lower slopes transitioning 

to mixed conifer at the higher elevations. The upper part of the butte provides goshawk nesting habitat. 

District records do not list either species within the OGMA boundary, although marten have been 

observed within a half mile of the OGMA. 

The 5825 OGMA (313 acres) is located north of the 5825 road and west of Highway 58. This OGMA 

is dominated by lodgepole pine with emphasis species of three-toed woodpeckers, goshawk and marten. 

District observational records show a three-toed sighting in 1997 and a marten sighting in 2001 just 

outside the OGMA boundary. 

Little Deschutes River OGMA (150 acres) is located east of the Two Rivers North subdivision and is 

bisected and bordered by 2 railroad tracks (potentially a source of ignition) and near the Little 

Deschutes River. This OGMA is primarily mid-successional ponderosa pine with an understory 

composed of lodgepole and ponderosa pine. South of one set of railroad tracks is an isolated section of 

pure lodgepole pine. The focal species for this OGMA is the goshawk although there are no recorded 

observations in this vicinity as of June 2008. 

Assessments for each OGMA have been completed and can be found on file at the Crescent Ranger 

District. 
BLT Project Environmental Impact Statement 

Chapter 3 – Old Growth Management 

256

Figure 3-26. Old-Growth Management Areas within the BLT Analysis Area R. 8 E. R. 7 E. T. 25 S. T. 24 S. 570 200 175 420 65 310 635 785 115 575 350

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The USDA is an equal opportunity provider and employer

Action AlternativeOld Growth Area

BLT Boundary
Environmental Impact Statement BLT Project 

 Chapter 3 – Old Growth Management 

257

Alternative A 

Direct and Indirect Effects 

Implementation of this alternative would result in no immediate vegetative change within any of the 

four designated Old Growth Management Areas (OGMAs) within the project. Habitat capability would 

be maintained for the designated species although overstocked stands would continue to be at risk of 

large tree loss from disease, insects, and uncharacteristic fire events. For more information, reference 

sections titled “Fire and Fuels” and “Forested Vegetation” in Chapter 3 of this EIS. 

Effects Common to All Action Alternatives 

The activities proposed within each OGMA have been found to be consistent with the assessments 

and the requirement of the Deschutes LRMP because: 

1. All vegetation manipulations are designed to “enhance and perpetuate old growth 

characteristics” Deschutes LRMP (M15-4) and provide habitat for the focal species. . 

2. The goal of the activity is to retain the largest diameter trees in each OGMA for the longest 

period possible and no tree over 21 inches in diameter would be harvested. 

3. No standing or downed dead trees would be removed except those for occupational safety. 

4. Prescriptions are designed to meet the minimum habitat needs of the focal species and 

maintain vegetative species diversity. 

5. No temporary roads would be constructed and interior habitat and edge effect would not 

change. 

All four OGMAs are located outside the Northwest Forest Plan but within lands managed through the 

East-Side Screens. Alternative B proposes active vegetative management within each OGMA in the 

BLT analysis area. Alternative C would actively manage Little Odell, Muttonchop, and Little 

Deschutes River OGMAs, and Alternative D would manage Little Odell Butte and Muttonchop 

OGMAs. While large diameter trees would be retained where they occur in each OGMA, some stands 

may not provide habitat needs for all life conditions for the focal species. For example, canopy cover 

may be reduced below levels typically used for nesting, roosting, or denning, but stands would still 

provide habitat for some elements of life functions such as foraging or dispersal. In addition, 

replacement trees of the appropriate species would be left including ponderosa, white and sugar pines, 

Doug-firs and Shasta firs in the 15-21 inch diameter range where available to function as future LOS 

trees as existing trees fade out. These actions would improve the resiliency of treated stands to 

withstand disease and beetle attacks. There would be no removal of trees greater than 21 inches in 

diameter or temporary road construction. 

Commercial thinning is proposed within each OGMA to reduce stocking density stress and lessen the 

risk of large scale loss of old forest to wide-scale disturbance processes. Within the lodgepole pine 

dominated OGMAs (Little Odell and 5825) variable density thinning would be applied that would result 

in reduced canopy cover ranging from 20-30 percent post-harvest depending existing condition and 

density of tree marking. In all cases the largest diameter trees would be retained. There would also be 

no removal of down logs as part of the timber sales or as personal use or commercial firewood (see 

PDFs, Chapter 2). Multi-story forested conditions would remain where they occur. In the ponderosa 

pine and/or ponderosa pine and sugar pine OGMAs (Muttonchop and Little Deschutes River) 

understory thinning would also occur favoring the retention of the largest diameter pines on each site. 

Underburning is also proposed to reduce ground fuels (less than 3 inches in diameter down wood and 

pine needles in the ponderosa or sugar pine dominated OGMAs but would retain down wood to the 

levels prescribed in the Project Design Features in Chapter 2). Post-harvest canopy cover would likely 

range from 30-35 percent in ponderosa pine or sugar pine OGMAs. 

While commercial thinning would occur in each OGMA within suitable habitat for each focal species 

(three-toed woodpecker, American marten and northern goshawk) this is not the only habitat available 
BLT Project Environmental Impact Statement 

Chapter 3 – Old Growth Management 

258

for the species in the analysis area. The Viable Ecosystem Model estimated there are approximately 

57,107 acres of suitable nesting habitat for three-toed woodpeckers, 15,003 acres of denning habitat for 

the American marten, and 14,211 acres of nesting habitat for the northern goshawk. Figures 3-21, 3-22 

and 3-23 display the current distribution of suitable habitat for each focal species in the analysis area.. 

Alternative B 

Direct and Indirect Effects 

Implementation of this alternative would result in silvicultural activities prescribed to reduce stand 

density and return a frequent fire regime where (appropriate) within all four OGMAs. A total of 438 

acres of the total 1,172 acres of OGMAs would have silvicultural and fuels treatments. Of the 438 

acres, 214 acres would occur in the Little Odell OGMA, 72 acres in the Muttonchop OGMA, 6 acres in 

the 5825 OGMA, and 146 acres on the Little Deschutes River OGMA. 

Little Odell OGMA 

Three-toed woodpecker: A total of 214 acres of the 348 acre OGMA would have commercial thinning 

treatments. It is estimated post-harvest canopy cover would range from 20-30 percent and be within the 

range of mature lodgepole pine stands used by nesting three-toed woodpeckers described by Goggans et 

al. (1989). However they also concluded that they are less likely to use logged stands as nesting habitat 

as compared to unlogged sites. They also determined that three-toed woodpecker foraging occurred 

most often in uncut stands with canopy cover less than 60 percent and the species selected against 

multi-story stands for foraging and roosting. Goggans study took place on the Deschutes National 

Forest including sites on the Crescent Ranger District. Because approximately 134 acres would remain 

untreated, these more densely stocked acres would continue to provide nesting, foraging and roosting 

habitat. 

Marten: In a 1997 study on the Chemult Ranger District on the Winema National Forest, Raphael and 

Jones concluded the average canopy cover at denning sites was 30 percent and that resting sites were 

selected with greater canopy cover (average 36 percent) when snow cover was present as compared to 

snow-free times. Based on predicted post-harvest canopy cover, the portion of the OGMA that is 

thinned would probably not function as marten denning and winter resting except where the thinning 

density is variable with higher canopy cover. Denning and winter resting habitat however would be 

provided in the remaining 134 acres where no active management occurs. In winter, most of the small 

mammals that marten prey upon live in subnivean spaces formed by vegetation and coarse woody 

debris near the snow-ground interface. Because large diameter wood would not be removed, subnivean 

access to this prey habitat would be maintained. While some marten denning and resting habitat may 

be temporarily removed through stand density reduction activities, the largest diameter trees and down 

wood (the most critical habitat structures) would be more likely to stay on the landscape and not 

removed through disturbance processes. 

Over time, as canopy cover returns to 30 percent, larger average stand diameters would provide greater 

snow intercept during times when marten tend to select stands. 

Muttonchop OGMA 

Goshawk: There would be a total of 72 of 361 acres of commercial thinning and underburning 

proposed in the Muttonchop OGMA. Post-harvest canopy cover would likely range from 30-35 percent 

and below the minimum 40 percent level the Crescent Ranger District uses to define goshawk nesting 

habitat, however, greater than 30 acres remains on top of the butte managed in a passive management 

scenario. Where active management occurs, canopy cover is estimated to increase approximately five 

percent per decade (Five Buttes EIS, USDA 2007) which could allow goshawk nesting capability to 

return in one to two decades. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Old Growth Management 

259

Marten: The 72 acres of active management are not situated in an area likely to have a long-term effect 

on marten habitat because the species is more likely to utilize the mixed conifer stands at the upper 

elevations of the OGMA. 

5825 OGMA 

The 6 of 313 acres proposed for commercial thinning in this OGMA is likely to have little impact to 

nesting goshawks because of the scale of active management. The stands that are thinned would 

continue to function as foraging habitat and the remaining 297 acres would provide nesting habitat. For 

the 2 other focal species, black-backed woodpeckers and marten, because the remaining acres managed 

in a passive management scenario would provide the decadence and canopy closure necessary for all 

life stages. 

Little Deschutes River OGMA 

Goshawk: Nearly all (146 of the 150 acre OGMA) is proposed for density reduction and prescribed fire 

to return it to a frequent fir regime. Nesting habitat would be provided as a 30-acre block of no 

treatment in an area best suited for the goshawk on the south side of the railroad tracks where there is an 

isolated patch of pure lodgepole pine (Project Design Features, Chapter 2). Where active management 

has occurred, foraging habitat would remain. 

Although the northern goshawk is the focal species, they are not known to occur in this area at the 

present time. If they are discovered during sale operations, a limited operating restriction would be 

placed on all activities with potential for disturbance (Project Design Features, Chapter 2). 

Alternative C 

Direct and Indirect Effects 

The selection of this alternative would result in active management to reduce stand density and return a 

frequent fire regime (where appropriate) in three OGMAs on 264 acres of the total 1,172 acres. A total 

of 46 acres would occur in the Little Odell OGMA, 72 acres in Muttonchop OGMA, and 146 acres in 

the Little Deschutes River OGMA. 

Little Odell OGMA 

Marten: The 46 acres of the 348-acre OGMA proposed for commercial thinning would result in the 

majority of the OGMA functioning for all life stages. While actively managed acres are greatly 

reduced from Alternative B (214 versus 46 acres), a passive management scenario on 302 acres would 

place the OGMA at greater risk to large tree loss (and a larger block of habitat) to disturbance 

processes. 

Three-toed woodpecker: The 46 acres thinned would continue to provide nesting habitat for the threetoed woodpecker based on expected post-harvest canopy cover, although the Goggans et al. study 

(1989) indicated that logged stands are less likely to be used for nesting purposes as compared to 

unlogged stands. The tradeoff of greater risk for large tree loss on 302 acres would be to function as 

habitat capable of providing nesting, foraging and roosting habitat for this species. 

Muttonchop OGMA 

Goshawk: As described in Alternative B, there would be a total of 72 of 361 acres of commercial 

thinning and prescribed underburning. It would continue to provide foraging habitat, although activities 

would likely result in the short term loss of nesting habitat. Thirty (30) acres of nesting habitat remain 

on top of the butte, managed in a passive management scenario. Nesting capability is expected to 

return in one to two decades. 

Marten: Active management is not situated in an area likely to have a long-term effect on marten 

habitat. 
BLT Project Environmental Impact Statement 

Chapter 3 – Old Growth Management 

260

Little Deschutes River OGMA 

As disclosed for Alternative B, goshawks are not known to be present. However, suitable habitat for all 

life stages would be provided. 

Alternative D

Direct and Indirect Effects 

A total of 118 acres of the total 1,172 acres of OGMAs would have active management to reduce stand 

density and return a frequent fire regime where appropriate. Of the 118 acres, 46 would occur in the 

Little Odell OGMA and 72 acres in the Muttonchop OGMA. 

Little Odell OGMA 

Similar to Alternative C, 46 acres of the 348-acre OGMA proposed for commercial thinning would 

result in the majority of the OGMA functioning for all life stages for the marten and three-toed 

woodpecker. 

Muttonchop OGMA 

As described in Alternatives B and C, there would be a total of 72 of 361 acres of commercial thinning 

and prescribed underburning. It would continue to provide foraging habitat, although activities would 

likely result in the short-term loss of nesting habitat for the goshawk. Thirty (30) acres nesting habitat 

remains on top of the butte managed in a passive management scenario. For the marten, active 

management is not situated in an area likely to have a long-term effect on marten habitat. 

Cumulative Effects To All Action Alternatives 

The zone of influence is the 80,000-acre Upper Little Deschutes Watershed because a 5th field 

watershed is ecologically significant in functioning as refugia for a host of old-growth related species, 

particularly those with limited dispersal capabilities that are not able to migrate across larger landscapes 

(Northwest Forest plan Record of Decision, C-44). All past and present timber sales were accounted 

for in the existing condition and none overlap into Old Growth Management Areas. Also, there are no 

foreseeable actions that have the potential to overlap into the 5th field watershed and reduce Old Growth 

or Late and Old Structured characteristics. For these reasons, the analysis of past actions other than 

those listed in this section is based on current environmental conditions. The Forested Vegetation 

section in Chapter 3 discloses “No activities planned in the BLT project would reduce LOS. Actually, 

LOS characteristics may be increased in stands classified as “mid” because the large structure would 

become more dominant after thinning”. Therefore, there are no additive effects identified. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

261

Fisheries and Aquatic Resources _______________________ 

A Biological Assessment (BA) was prepared to document the review and findings of the BLT analysis 

for possible effects on species listed or proposed for listing by the USDI Fish and Wildlife Service 

(USFWS) as Threatened or Endangered and designated by the Pacific Northwest Regional Forester as 

Sensitive. The BA is prepared in compliance with the requirements of Forest Service Manual (FSM) 

2630.3, FSM 2672.4, and the Endangered Species Act of 1973, as amended (ESA) (Subpart B; 402.12, 

Section 7 Consultation). The determination in the BA was that implementation of this project will have 

No Effect to bull trout or their habitat. The project will have No Impact on redband trout or their 

habitat. The following table displays the threatened, endangered, and sensitive (TES) species 

considered in the analysis of the BLT Vegetative Management Project, including an effects 

determination. 

 

Table 3-80. Threatened, Endangered, and Sensitive Fish Species 

Aquatic Species Scientific Name Status Occurrence 

Effects 

Determination 

Columbia River Bull 

Trout 

Salvelinus confluentus T HD NE 

Interior Redband 

Trout 

Oncorhynchus mykiss 

ssp.

S HD NI 

Status 

E Federally Endangered

T Federally Threatened 

S Sensitive species from Regional Forester’s list 

C Candidate species under Endangered Species Act 

MS Magnuson-Stevens Act designated Essential Fish Habitat 

Occurrence

HD Habitat Documented or suspected within the analysis area or near enough to be 

impacted by project activities 

HN Habitat Not within the analysis area or affected by its activities 

D Species Documented in general vicinity of project activities 

S Species Suspected in general vicinity of project activities 

N Species Not documented and not suspected in general vicinity of project activities 

Effects Determinations 

Threatened and Endangered Species 

NE No Effect 

NLAA May Effect, Not Likely to Adversely Affect 

LAA May Effect, Likely to Adversely Affect 

BE Beneficial Effect 

Sensitive Species 

NI No Impact 

MIIH May Impact Individuals or Habitat, but Will Not Likely Contribute to a Trend 

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

WIFV Will Impact Individuals or Habitat with a Consequence that the Action May 

Contribute to a Trend Towards Federal Listing or Cause a Loss of Viability to the 

Population or Species 

BI Beneficial Impact 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

262

The following information addresses the potential effects of implementing the BLT Project on 

threatened, endangered, and sensitive fish species. This determination, required by the Interagency 

Cooperation Regulations (Federal Register, January 4, 1978), ensures compliance with the ESA. 

Changes to the R-6 Regional Forester’s Sensitive Species List were instituted in 2008. There are no, 

threatened, proposed, candidate or sensitive species within the BLT planning area. Discussions on 

invertebrate species are included in the wildlife section. Project activities are consistent with the Clean 

Water Act (CWA 1977), Aquatic Conservation Strategy (ACS) objectives and the Little Deschutes 

River Wild and Scenic Plan. 

Existing Condition for Fisheries 

This system (see Hydrology Section) is dominated by the non-native brook trout and brown trout. It is 

believed these two species have displaced redband trout from the Upper Little Deschutes River. Brook 

trout are numerous in the headwaters and large predatory brown trout are numerous in the lower 

sections of the system. These two species would provide much difficulty in establishing a bull trout 

population in the headwater streams of the Little Deschutes River (USFWS, 2003). 

The integration of native fish species and the available habitat in the upper Little Deschutes River 

drainage is very poor. Native fish species may have become completely replaced by non-native species 

such as brook trout and brown trout. Redband trout and bull trout have not been documented in the 

upper drainage in many years. It is suspected that competition with non-native species, passage barriers, 

degraded habitat, and increased stream temperatures have all contributed to the demise of native fish in 

this area. There is no connectivity for refounding the native fish populations as a substantial barrier 

exists at the Gilchrist mill pond which most likely prevents native fish in the lower river system from 

moving upstream. The existing fish ladder over the dam is steep with high velocity water and jumps. If 

a fish did negotiate the ladder and enter the mill pond, it would face elevated water temperatures as 

water used to cool mill operations equipment is released back into the stream channel at this location. 

The BLT analysis area overlaps the Northwest Forest Plan and lands east of the owl line. The Inland 

Native Fish Strategy applies on approximately 2/3 of the analysis area. PACFISH and the MagnusonStevens Fishery Conservation Act (MSA) do not apply because there is no anadromous fishery, nor a 

hydrologic connection. Also, there is no overlap with the Upper Big Marsh Creek Tier 1 key 

watershed. Streams within the planning area of the BLT project are generally low gradient (less than 1 

percent), highly sinuous, and due to their spring origin, their hydrograph is relatively stable. These 

streams tend to be relatively stable, and typically do not experience the flashy flows that occur in other 

areas. 

Flows in Crescent Creek are greatly influenced by the operation of an irrigation dam at Crescent Lake. 

Therefore, low flow levels are higher than they would be in the absence of dam operations and similarly 

high flows are lower than would occur under natural flow patterns. 

The Little Deschutes River is the main water body within the analysis area. The Little Deschutes River 

is a National Wild and Scenic River from its headwaters in the Mt. Thielsen Wilderness to the private 

property boundary at the Two Rivers subdivision (a distance of approximately 12 miles). A Wild and 

Scenic River Plan has been developed by the Crescent Ranger District (2002). Although the Little 

Deschutes stream bank condition is recovering from past management practices, such as livestock 

grazing and harvest (prior to 1994) in riparian buffers, it is generally considered as functioning 

properly. 

In the Draft Bull Trout Critical Habitat designation, the Little Deschutes was identified as critical 

habitat, however the final USFWS determination removed critical habitat from all USFS managed 

lands. The designation in the Little Deschutes subwatershed was 29,743 acres and three 5th field 

subwatersheds. The area drains the east side of the Cascade Range. The Mount Thielsen Wilderness 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

263

and the Oregon Cascades Recreation Area Management Areas comprise the headwaters of the Little 

Deschutes River. Over 95 percent of the three sub-watersheds are within the Northwest Forest Plan 

Land Management designation. 

Table 3-81. Subwatersheds within the BLT Analysis Area 

Subwatershed 

Name 

Subwatershed 

Number Acres Orientation to Owl Line 

Clover Butte 170703020105 12,580.9 Split 

Hemlock Creek 170703020101 17,215.3 Split 

Gilchrist Junction 170703020106 8,517.7 East of 

Gilchrist 170703020302 17,714.6 East of 

Bunny Butte 170703020104 13,366.8 Split 

Little Odell 170703020103 10,629.7 Split 

Table 3-82. Perennial Streams within the BLT Analysis Area 

Stream Name Subwatershed 

Little Deschutes River Gilchrist, Gilchrist Junction, Clover Butte 

Hemlock Creek Hemlock Creek 

Spruce Creek Hemlock Creek 

Rabbit Creek Hemlock Creek 

Basin Creek Hemlock Creek 

Swamp Creek Hemlock Creek 

Fish species found within the analysis area include non-native brook trout, brown trout, and possibly 

redband trout. 

Table 3-83. Streams in BLT Planning Area and Fish Found Within 

Stream Name Fish Species 

Little Deschutes River Brook Trout (SAFO), Brown Trout 

(SATR), possibly redband trout (ONMY) 

Hemlock Creek SAFO, SATR 

Spruce Creek SAFO, SATR 

Rabbit Creek SAFO 

Basin Creek SAFO 

Swamp Creek SAFO 

Little Odell Creek None 

Redband trout and bull trout were historically present in the Upper Little Deschutes River drainage. 

Bull trout have been extirpated during the past century and redband trout, if still present; exist at a much 

depressed state. The most recent management plan conducted by ODFW found redband trout to be 

scarce within the Little Deschutes River. During sampling of the river conducted in 1992, only ten 

redband were found within the entire river, with only one upstream of La Pine (Upper Deschutes River 

Subbasin Management Plan, 1996). No redband trout were found upstream of Gilchrist. The following 

text is from the USFWS Joint Programmatic Biological Opinion (2006) describing baseline conditions 

in the Upper Little Deschutes. 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

264

Natural, Physical, and Biological Character

The Upper Little Deschutes River subwatershed is comprised of three main drainages: Clover, Hemlock 

and Swamp Creeks. These three are the only perennial tributaries to the Little Deschutes River except 

Crescent Creek which enters the Little Deschutes River 17 miles down stream from Gilchrist. The Little 

Deschutes River flows nearly 100 miles from its headwaters in the Mt. Thielsen Wilderness to its 

confluence with the Deschutes River near Sunriver, Oregon. 

Riparian Plant Community Conditions 

Riparian vegetation varies. The Little Deschutes consists of a grass/forb floodplain varying in width to 

about 500 ft. from the stream banks. Hemlock Creek has a marsh that consists of grass/forb and 

willow/shrub component. Typical overstory species are lodgepole pine in the lower ends of the 

streams, changing to mountain hemlock and Engelmann spruce toward the headwaters. 

Riparian areas and the reserves around them are important in maintaining stream structure and 

temperature as well as buffering the stream from disturbance. As recommended in the Northwest 

Forest Plan and INFISH, riparian reserves have been developed at two mature tree lengths (300 feet) 

from fish-bearing streams/lakes and one mature length (150 feet) from non fish-bearing streams and 

wetlands. Streams such as the Little Deschutes River lie within a broad floodplain with riparian 

vegetation extending up to several hundred feet beyond the edge of the stream channel. Riparian 

reserves insulate water bodies and riparian areas from disturbances by maintaining a cool, moist 

microclimate, maintaining shade and a source of large wood recruitment, and intercepting/slowing 

sediment transport from upslope. 

Some Off Highway Vehicle (OHV) traffic is occurring around the community of Two Rivers along the 

Little Deschutes River. Although some inappropriate access in riparian areas is evident, it is considered 

low compared to other watersheds on the forest around more populated areas. The BLT analysis area 

would not increase potential for additional OHV access, and existing effects from this use is included in 

the existing condition descriptions. The Travel Management Rule is due to be in place in 2009 to 

designate trails and close off-trail travel. 

Upslope Plant Communities 

Upslope plant communities change with elevation. In the headwaters of the Little Deschutes watershed, 

mountain hemlock, and lodgepole dominate. In moister areas at mid elevations, the plant communities 

change to Douglas fir and Engelmann spruce. 

Watershed Condition 

Nearly 18 percent of the Crescent Watershed is designated as wilderness. Another 3,500 acres are 

classified as Wild and Scenic river corridor, and 33,000 acres are in the OCRA (Oregon Cascades 

Recreation Area). Road density is relatively low at less than 1.5 miles per square mile. 

A Roads Analysis was completed for the BLT analysis area. The Roads Analysis involved an 

interdisciplinary review of the transportation system in the watershed, including access and travel 

management. Implementation of the proposed action would include approximately 9.7 miles of 

temporary road construction. These are considered temporary in nature (less than 5 years) and they 

would be restored to proper hydrologic function after their intended use. Only one mile lies outside of 

unit boundaries with the remainder being part of the interior harvest system. 

There are six perennial streams within the analysis area boundary. These streams are the Little 

Deschutes River, Hemlock Creek, Spruce Creek, Rabbit Creek, Basin Creek, and Swamp Creek. 

The Little Deschutes River is a low gradient, 303(d) listed river (temperature and dissolved oxygen) 

meandering greatly for 95 miles through a forested, willow, and grassland floodplain. The river begins 
Environmental Impact Statement BLT Project 

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265

in the Mt. Thielsen Wilderness with the upper 12 miles designated as a “Wild and Scenic” River. There 

is one pond/impoundment on the river, at approximately river mile 62. The Little Deschutes River 

merges with the Deschutes River near the community of Sunriver, Oregon. Ten units in Alternative B 

lie within the Wild and Scenic boundary of the Little Deschutes River. 

Hemlock Creek is the most significant tributary to the Upper Little Deschutes River. It is also 303(d) 

listed for temperature. Bank stability in Hemlock Creek was described as “excellent” in the 1989 

stream survey report. The only noted exceptions were areas of overturned trees and resulting scour 

around obstructions in the creek or from denuded banks as a result of past livestock grazing practices. 

The stream originates on the lower slopes of Burn Butte. Three tributaries feed into Hemlock Creek. 

They are Spruce Creek, Basin Creek, and Swamp Creek. 

Spruce Creek is a low gradient stream with a sand and pumice substrate. As with the other streams in 

the analysis area, bank stability is quite high along Spruce Creek post grazing. During the most recent 

stream survey (1998) bank stability was measured at 99.6 percent. Areas of instability were attributed 

to elk crossings. 

Although the bank stability in Spruce Creek is considered “high”, past grazing practices have altered 

the stream causing it to become downcut and entrenched in several areas. Spruce Creek is showing 

signs of recovery since livestock grazing was discontinued. Active beaver dams are no longer 

abundant, which has likely resulted in a lowered water table, reduced side channel area, and facilitated 

lodgepole encroachment into the meadows. 

Rabbit Creek is a small, spring-fed, stream which flows into Spruce Creek. As with the other streams 

in the area, past timber harvest projects have entered the riparian area and reduced future wood 

recruitment and shade. The last stream survey completed on Rabbit Creek was in 1991. The survey 

reports that only a few small areas of raw banks were noted. “Otherwise stream bank ground-cover 

approached 100 percent” (USFS 1991). 

The 1989 Basin Creek stream survey report notes that stream bank protection is “high” with the 

exception of areas of clear-cuts adjacent to the stream channel or from banks exposed from fallen 

timber. 

A stream survey report has not been completed on Swamp Creek and data is not available describing 

the bank stability. From personal observations, it is comparable to the other area streams with very 

high bank stability. Due to the high percentage of existing willow and the saturated valley bottom, the 

hydrology and health of Swamp Creek appears to be the best of the streams within this planning area. 

Existing Condition for Water Quality 

Water Temperature 

Water temperature is the measured result of heat energy inputs and losses. The elements involved in 

determining net heat energy of a water body include solar energy, long wave radiation, evaporation, 

convection, conduction, and exchange (Boyd and Sturdevant 1997). Each element is influenced by 

climatological and geological factors. Mean pool depth, percentage of pools making up the channel and 

riparian shade all affect substrate conduction, evaporation, and solar radiation, which are correlated 

with maximum daily water temperatures (Hawkins et al. 1997). Latitude, basin elevation, and slope of 

a stream effects long wave radiation, convection and evaporation and have been correlated with 

minimum and mean daily water temperatures (Hawkins et al. 1997). Any increase in solar radiation 

during daytime conditions will directly increase stream temperature (Brown et al. 1972). 

Water temperature is a fundamental parameter affecting a water body’s ecology (Minshall 1978; 

Vannote et al. 1980). As a stream moves from headwaters to mouth, exposure to solar radiation 
BLT Project Environmental Impact Statement 

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increases and water warms to near the ambient air temperature (Bartholow 1989). Lakes at the 

headwaters of streams can have a dramatic effect on the physical, chemical, and biological composition 

of streams that form below them (Gore 1994). Lakes releasing warm surface water into streams can 

hasten a stream system’s community ecology to resemble communities further down stream, as 

compared to other headwater streams (Ward and Stanford 1983; Gore 1994). 

Land management activities have the potential to considerably affect water temperature. Vegetation 

manipulation by overstory removal or altering the water table to allow encroachment of upland 

vegetation into the riparian zone can affect the shade, cover, and the amount of solar radiation input to 

the water surface. Flow modification is another land management activity that can significantly affect 

water temperature. Reducing water volume in a river channel normally developed to maintain a larger 

water volume will increase the normal width to depth ratios that creates a larger surface area to volume 

ratio. This condition increases the rate in which water temperatures increase. 

303(d) Water Quality Limited 

The Clean Water Act requires the State of Oregon to develop water quality standards that protect the 

beneficial uses of the water within the Upper and Little Deschutes sub basins. The act also requires the 

state to establish a list of water bodies that do not meet such standards and develop a management plan 

to meet these standards. Currently, the State of Oregon has postponed identification of the Total 

Maximum Daily Load effort until 2009 and the Deschutes National Forest is working on the draft 

Water Quality Management Plan. Beneficial uses and the associated water quality standards are 

generally applicable drainage wide. At a minimum, uses are considered attainable wherever feasible or 

wherever attained historically. 

The State of Oregon, as directed by the Clean Water Act and the Environmental Protection Agency, is 

responsible for the protection of rivers and other bodies of water in the public interest. Oregon 

Administrative Rules, Chapter 340, lists the beneficial uses in the analysis area as: 

• Public Domestic Water Supply 

• Private Domestic Water Supply 

• Industrial Water Supply 

• Irrigation Water Supply 

• Livestock Watering 

• Fish and Aquatic Life 

• Wildlife and Hunting 

• Fishing and Boating 

• Water Contact Recreation 

• Aesthetic Quality 

The Forest Service responsibilities under the Clean Water Act are defined in a 2002 Memorandum of 

Understanding between DEQ and the Forest Service. The MOU designates the Forest Service as the 

management agency for the State on National Forest System Lands. 

Utilizing Best Management Practices (BMPs) in project implementation is a requirement of the Clean 

Water Act, which requires the State of Oregon to develop a statewide water quality management plan 

and to set standards for water quality. The BMPs are reviewed periodically to see if state standards are 

being met. The current BMPs have been determined to meet or exceed state requirements (USDA 

Forest Service, 1988). BMPs that apply to this project are identified in Appendix A. 

Regular monitoring of stream temperatures in the sub-basin during the past decade has identified two 

streams in the BLT analysis area that are water quality limited. The Little Deschutes River was listed on 

the Oregon DEQ’s 2004 303(d) “Water Quality Limited Streams” list for exceeding standards for 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

267

temperature and dissolved oxygen (river mile 0 to 68.8). Dissolved oxygen is a parameter related to 

temperature. The warmer the water, the less oxygen it can hold. Hemlock Creek (river mile 0-5.9) is 

listed for elevated summer stream temperatures. Activities must improve conditions in the stream, or at 

least ensure that the conditions are not further degraded. 

To assess the current stream temperature and the conditions contributing to these problems, channel 

form and evolution, riparian condition, stream flow and source type were evaluated. All water 

temperature limited streams within the Little Deschutes Subbasins are perennial, fish-bearing streams 

and provide habitat for bull trout33, redband trout, brook trout, brown trout and other native and nonnative game and forage fish (USFS, 2004). 

Little Deschutes River: The Little Deschutes River flows for nearly 95 miles from its headwaters in the 

Mt.Thielsen Wilderness to its confluence with the Deschutes River near Sunriver, Oregon. The terrain 

is mixed with a dendritic drainage pattern from its headwaters to about the crossing of Highway 58. 

The Little Deschutes River then flows through a long, flat, low gradient plain with two tributaries along 

the remaining 82 miles of stream before entering the Deschutes River. Walker Irrigation District has 

one permitted canal withdrawing 17 percent of the monthly summer discharge from the Little 

Deschutes River at RM 26 (Breuner 2003). The Little Deschutes River flows through Deschutes 

National Forest, Bureau of Land Management, and private lands on its way to the Deschutes River. On 

private land near Gilchrist, Oregon, Interfor Pacific lumber company operates a dam and the Gilchrist 

millpond on the Little Deschutes River. 

The Little Deschutes River warms significantly by the time it reaches the confluence with Hemlock 

Creek (RM 78.2). The wide and shallow stream channel along with a relatively poor riparian condition 

allows solar radiation to significantly increase stream temperatures during the daylight hours. 

Conversely, the wide open sky above the stream allows the water temperatures to quickly cool during 

the night. 

The Upper Deschutes Watershed Council provides a temperature characterization for the Little 

Deschutes River (Breuner 2003). Their analysis shows relatively consistent water temperatures of 

about 22-24 degrees centigrade for over 55 miles before entering the Deschutes River. Hemlock 

Creek, a headwater tributary was found to discharge slightly warmer water than the Little Deschutes. 

Water discharged from the Gilchrist millpond is also warmer water than the river (Watershed Sciences 

2001). There is a very steep increase in water temperatures located between river mile 82 (Hwy 58) 

and 62.4 at the Gilchrist millpond dam. At this stage the river transitions from higher gradient mixed 

conifer forest environment to a low gradient willow and alder dominated riparian ecosystem with 

lodgepole forest uplands. 

Water temperatures from the Gilchrist millpond come in almost 3.5 degrees C warmer than the Little 

Deschutes River at river mile 62 (Watershed Sciences 2001; Figure 23). Within two miles downstream 

of the millpond, water temperatures reduce to the background water temperature. 

Consistent water temperatures are maintained from the confluence of Crescent Creek to the Deschutes 

River. 

Spruce Creek is a tributary to Hemlock Creek and Hemlock Creek is a tributary to the Little Deschutes 

River at RM 78. Only one year of thermograph (temperature data recorded hourly) data is available for 

this tributary. This data was recorded at the FS 5830 road crossing, which is approximately a mile and 

 

33 There is Habitat Documented or suspected within the project area or near enough to be impacted by project 

activities, but bull trout have been extirpated in the Little Deschutes River drainage over the past century. 
BLT Project Environmental Impact Statement 

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268

a half upstream of the confluence with Hemlock Creek. Spruce Creek appears to maintain cool 

temperatures throughout the summer months. 

Thermograph data is unavailable for Basin, or Rabbit Creeks. Stream temperatures were recorded 

during USFS level II stream surveys. Water temperatures were cool in Rabbit Creek, with a maximum 

temperature of 10 degrees centigrade being recorded (Meyer, 91). Stream temperatures recorded in 

Basin Creek ranged from 11.5 to 14 degrees centigrade (Platz, 89). Temperature data is unavailable for 

Swamp Creek. 

Direct and Indirect Effects 

Alternative A 

Temperature 

Implementation of Alternative A would have no effect on stream/water temperatures as baseline 

conditions would remain unchanged. 

Several past management activities have likely contributed to a general warming trend in the Little 

Deschutes River and it’s tributaries within the analysis area, including livestock grazing and timber 

harvest practices. Livestock grazing has been discontinued on Forest Service managed lands with the 

most recent allotment being operated in 1993. Prior to that, nearly a century of livestock grazing along 

these meadows reduced the density and composition of riparian vegetation as well as sheering of banks 

due to hoof stress, which potentially can contribute to a wider, shallower channel. Isolated areas of 

bank erosion that currently exist are most often attributed to elk use/crossings. Also, timber harvest 

practices prior to the implementation of the Aquatic Conservation Strategy and INFISH removed tree 

canopies that provided shade, contributing to an increase in temperature, evaporation and drying of the 

soil. 

Loss of shade, widening and loss of depth and a larger surface area exposed to solar radiation, all are 

factors that have contributed to warming. However, the passing of time and some recovery of 

vegetation has reversed the decline and stream banks are showing signs of improvement. A small 

restoration project that placed approximately 400 whole length trees within the Little Deschutes River 

stream channel and riparian area may have a small, but immeasurable effect on temperatures as a result 

of increased shade at the microclimate scale. 

This alternative has the greatest risk of a watershed scale disturbance event with potential to remove 

shading and elevate stream temperatures above baseline levels. 

Action Alternatives B, C, D 

Temperature 

Implementation of action alternatives should have no measurable effect on stream temperatures as most 

activities except for small diameter fuels reduction in Unit 1061 would be conducted outside of riparian 

reserve buffers (300 feet). Therefore stream shade would be unchanged and 303(d) parameters for 

impaired water quality (temperature and dissolved oxygen) in the Little Deschutes and Hemlock Creek 

would not be further degraded. 

Unit 1061 lies within the riparian area of Hemlock Creek adjacent to the community of Two Rivers. 

This is a “fuels only” unit where small diameter (less than 3 inch) lodgepole pine would be thinned to 

restore meadow vegetation and decadent willow clumps spot burned to invigorate their growth. The 

only shading potentially provided by vegetation that would be altered are the dead and defoliated 

branches of the willows. Due to the scale of the project and retention of most vegetation that provides 

shading, this project would not result in a detectable or measurable increase in temperature in Hemlock 

Creek. Any potential effects would be short-term (two growing seasons or less). From a longer term, 

prescribed burning would stimulate willow growth and improve potential for shading after two years. 
Environmental Impact Statement BLT Project 

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269

Restoration of the riparian-influenced vegetation would also contribute to a reduction of risk in the 

Wildland Urban Interface for Two Rivers subdivision. 

Existing Condition 

Sediment/Turbidity: 

The sediment in Hemlock Creek is composed mostly of pumice sands with gravel being sub-dominant. 

The upper Little Deschutes River substrate is comprised of sands 35-60 percent and gravels depending 

on reach. Sand dominates Spruce Creek averaging over 60 percent of the substrate. 

Within the wilderness boundary upstream of the analysis area, there is slope void of vegetation (natural 

landform) along the Little Deschutes River that contributes considerable amounts of fine sediment 

during peak discharge events. During a recent rain on snow event (December 2004), The Little 

Deschutes River was carrying a high amount of fine sediment. Silt sized material was deposited along 

the banks downstream throughout the analysis area. 

Commercial timber harvest and roads construction in particular (Rice et al 1972, Beschta 1978) have 

great potential to lead to additional sediment delivery to area streams. Reid and Dunne (1984) suggest 

that unpaved roads in particular can yield high volumes of sediment input for streams. Reid and Dunne 

found (western Washington) that a heavily used road segment contributes 130 times more sediment 

than an abandoned road and a paved road segment produces less than 1 percent as much sediment as a 

heavily used gravel road. They showed that the rate of erosion of gravel roads is extremely sensitive to 

the rate of use. In their study, they found heavily used (four or more loaded trucks per day) gravel 

roads contribute 7.5 times as much sediment as the same road when not in use. It should be noted that 

erosion in their study was associated with rain events. This scenario has not been evident on the 

Deschutes National Forest because of high infiltration rates and relatively flat terrain. 

Erosion of gravel road surfaces is of concern because most sediment from this source is finer than 

2mm; this fine-grained material is the size most harmful to fish and water quality (Reid and Dunne, 

1984). Eaglin and Hubert (1993) showed a positive correlation between the density of stream crossings 

and the proportion of a drainage that was logged to the amount of fine sediments found in streams and 

the level of embeddedness of the substrate. The BLT project has 8 stream crossings (Table 3-84) and 

would harvest 9.4, 7.2, and 3.3 percent of the watershed for Alternatives B, C, and D (respectively). 

Also, the BLT Project has a Project Design Feature (Chapter 2) to use native grass seed applied to areas 

lacking in vegetation near stream crossings and haul roads that have the potential to contribute to 

sedimentation. 

Fine sediment contributions degrade fish habitat by increasing embeddedness, which reduces the 

interstitial spaces between gravels and cobble that make up the stream bed. Embedded streams provide 

poor spawning habitat as the bed is difficult to spawn in and eggs have a tendency to get buried beneath 

fine sediment, suffocating them. In addition to the negative impacts fine sediments have on spawning, 

they also inhibit a fish’s ability to breath, and see, (find food and avoid predation). 

Studies indicate that the ability of salmonids to capture food may be impaired at turbidity values in the 

range of 25 to 70 Nephelometric Turbidity Units (NTU). Growth may be reduced and gill tissues 

damaged after 5 to 10 days exposure to turbidity of 25 NTU, and some species may be displaced at 50 

NTU (MacDonald, 1991). Turbidity is a result of suspended clay or silt particles in the water column 

and typically occurs during storm runoff events. Oregon administration rules state, “No more than 10 

percent cumulative increases in natural streams turbidities shall be allowed, as measured relative to a 

control point immediately upstream of the turbidity causing activity” (OAR Chapter 340, Division 41-

DEQ). 
BLT Project Environmental Impact Statement 

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270

The road density in the Little Deschutes Watershed is about 1.5 miles per square mile. Land slopes are 

low and soils excessively well drained, preventing severe impacts of network increases due to roads on 

streams (USFWS, 2003). 

In forested lands of the Central Cascades, modification of surface flow results from roadbeds being 

constructed perpendicular to natural water flow patterns. This occurs on hill slopes or in valley bottoms 

when soils are saturated with water, frozen or when soil structure inhibits water absorption. Road 

interception of subsurface flow occurs mainly on steep hillsides where the roadbed is cut deep enough 

into the hillside to intercept some or all of the subsurface flow. Ditches associated with these roads are 

an extension of the channel system and transport the water more efficiently, increasing the potential of 

storm runoff, magnitude of peak flows, and sediment delivery to larger stream channels (Wemple et. al 

1990 in Upper Little Deschutes Roads Analysis, 2002). There are very few steep midslope roads in the 

BLT analysis area. 

The road systems are often an extension of the channel network (Wemple et al. 1996). Channels are 

formed from routing the concentration of water along road ditches to established stream channels. 

Wemple et al (1996) found roads alone advanced the timing of peak discharge and slightly increased 

discharge. These functions of the road network ultimately affect the hydrograph of a stream increasing 

bankfull discharges and larger events. Due to the high infiltration rates of the volcanic soils in the 

watershed, these increases in discharges would be slight (USFS Upper Deschutes Watershed Analysis 

2002). 

High flow events at stream crossings pose a high risk of large sediment inputs if: the culverts become 

plugged, flows exceed the culvert capacity, or the stream overtops the road causing the road fill to erode 

and causing it to fail (USFS Upper Deschutes Watershed Analysis 2002). 

Road density has been linked to a series of negative effects to the aquatic environment including, 

increasing drainage miles and altering water chemistry. Snyder et al. (1975) found precipitation runoff 

leached nutrients from the exposed soil, and provided increased nutrient concentrations directly to the 

stream. Wemple et al. (1996) demonstrates how road systems can increase peak flow and that drainage 

ditches can form gullies that lead to streams. 

 

Road densities are relatively low within the BLT planning area at about 1.5 miles per square mile in the 

Little Deschutes subwatershed. The location of some of these roads has contributed to riparian 

degradation by providing motorized access for recreation. Forest Service road 5825300 which provides 

access to the Mt. Thielsen Wilderness and parallels the upper Little Deschutes River is partially within 

the riparian reserve. This road provides access to dispersed recreation sites which affects riparian 

vegetation along the river and allows OHV access to the meadow/floodplain. Although the dispersed 

camping and OHV use is relatively low (less than one percent of the riparian corridor) compared to 

more popular areas along riparian resources on the adjacent Bend-Ft.Rock Ranger District, there is 

some trampling of vegetation, soil compaction/displacement, and rutting within the riparian area. 

Implementation of the Travel Management Rule in 2009 is expected to reduce potential for 

inappropriate access and associated effects in the future. 

High infiltration rates of the soil and generally flat topography limit the amount of surface flow in the 

planning area. Likewise, subsurface flow interaction with roads is rare for the same reasons, but might 

occur in isolated areas during extreme storm events. There is a small amount of user-created roads and 

dispersed campsites that may contribute runoff and sediment to the Little Deschutes River in the upper 

reaches along FS Road 5830300 (USFS Upper Little Deschutes Roads Analysis 2002). Road drainage 

culverts can increase hydrologic connectivity affecting surface hydrology. 
Environmental Impact Statement BLT Project 

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271

Surface erosion from road surfaces is dependant upon the erodability of the soil, infiltration rates of the 

soil, slope of the road and the amount of precipitation. In the Upper Little Deschutes Watershed, soils 

have high infiltration rates and water storing capacity. Slopes are generally flat and annual precipitation 

is low (18-24 inches), with most falling as snow between October and May. These factors make 

surface erosion potential for roads in the Upper Little Deschutes Watershed limited to small-dispersed 

campsites adjacent to the Little Deschutes River. The soils in these areas have been compacted, 

decreasing infiltration rates and may increase overland flow (Upper Little Deschutes Roads Analysis 

2002). 

There are 8 stream crossings in the BLT analysis area and they are all perennial. Three are paved at 

Hemlock Creek on 5830, Highway 58 at Little Deschutes River, and County Road 61 at Crescent 

Creek. Table 3-84 displays stream crossings by road type: 

Table 3-84. Stream Crossings in the BLT Analysis Area 

Road Number Stream Road Surface Type 

Highway 58 Little Deschutes River Pavement Bridge 

County Road 61 Crescent Creek Pavement Bridge 

5830 Hemlock Creek Pavement 2 Culvert 48” 

5830 Hemlock Creek Native 1 Culvert 36” 

5830 Swamp Creek Native 1 Culvert 48” 

5830 Basin Creek Native 1 Culvert 48” 

5830 Spruce Creek Native 1 Culvert 48” 

5828 Spruce Creek Native 1 Culvert 36” 

The bridges at the Little Deschutes River crossing (State Route 58) and Crescent Creek crossing 

(County Road 61) are under the jurisdiction of the State of Oregon (administered by the Oregon 

Department of Transportation) and Klamath County. They both receive high amounts of traffic volume 

comprised of both private and commercial heavy haul vehicles. Log haul traffic generated by timber 

sale activity associated with the BLT analysis area would be negligible, representing roughly a few 

tenths of one percent increase in traffic volume. It is estimated approximately one quarter of the timber 

volume would be hauled on road 5830. 

Alternative A 

Direct and Indirect Effects 

Sedimentation/Turbidity 

Sediment delivery rates would remain unchanged from the current condition. No management 

activities with potential to cause sedimentation or turbidity above routine and custodial activities (such 

as road maintenance/culvert cleaning) would occur. As vegetation returns in areas affected by past 

management practices (timber harvest and grazing), there would be a reduction in potential for 

sedimentation. However, this alternative has the greatest risk for of a disturbance event from wildfire 

that would result in exposure of soil and the highest potential of the alternatives for sediment delivery. 

Action Alternatives B, C, D 

Direct and Indirect Effects 

Sedimentation/Turbidity 

Action alternatives would not result in an increase potential for sediment delivery above background 

levels. Turbidity levels would be within State of Oregon water quality guidelines. All activities 

(except fuels reduction in unit 1061) would be limited to areas outside of riparian reserves and/or 

riparian reserve habitat conservation areas. Unit 1061 activities will be implemented by hand crews and 

will not result in areas of exposed soil prone to mobilization to the stream channel. Additionally, the 

deep, highly drained pumice soils of the area are not prone to convey overland flow which could deliver 

sediment from upslope sources. This has been witnessed throughout the district within projects such as 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

272

the Davis Fire Recovery, Crescent Lake Wildland Urban Interface Fuels Reduction, Seven Buttes, and 

Seven Buttes return. This potential is further reduced by the relatively low stream densities within the 

planning area. 

Action alternatives would not result in an increase in the drainage network or road density as no 

permanent construction of roads would occur. However, approximately ten miles or less (Alternatives 

B, C and D) of temporary roads would be constructed. These roads would be outside of riparian 

reserves and would not be hydrologically connected to water bodies within the analysis area. 

Approximately 90 percent of temporary road construction would occur within the interior of harvest 

units, typically are used relatively short term for harvest operations (one to two years), and then are 

returned to a proper functioning hydrologic condition after their intended use. Although potential for 

sedimentation caused by activities outside the riparian buffers is characterized as extremely low, the 

buffers (which are relatively wide at 300 feet and flat) provide an area of intersect and filtration. In 

addition to the lack of proximately of operations to area waterways, water quality would also be 

preserved by the deep pumice soils in the area. These deep soils allow precipitation to be absorbed into 

the ground and transported down slope as subsurface flow, and generally not surfacing until reaching a 

valley bottom. This lack of surface flows on the hill slopes will reduce the possibility of transporting 

sediment to the stream channel. 

Temporary road construction has not been observed on the District or Forest to contribute to sediment 

delivery or increase in turbidity, particularly on the Davis Fire Recovery Project, Seven Buttes, or 

Seven Buttes Return harvest or salvage operations. This is because of the distance from water bodies, 

relatively flat terrain and porous soils. 

Roads 5835 (Hemlock, Spruce, and Swamp Creek), 5835/300 and 5830/300 (Little Deschutes River) 

would be the designated haul routes in the analysis area with potential for causing sedimentation and 

turbidity from dust. Log haul traffic generated by timber sale activity associated with the BLT analysis 

area would be negligible, representing roughly a few tenths of one percent increase in traffic volume. It 

is estimated approximately one quarter of the timber volume would be hauled on road 5830. Using 

factors such as low volumes of haul traffic in combination with porous soils and relatively flat terrain, 

potential sedimentation from any activity within the BLT analysis area is considered extremely low. 

If log hauling were to occur in the dry season (July to October) dust (fine particles) would not be 

expected to increase turbidity levels above 10 percent for two hours over natural levels set by the DEQ. 

Ten percent is a threshold set by the State of Oregon to maintain water quality. The duration would be 

for the life of timber haul operations, typically one to two years. 

Existing Condition 

Chemical Contamination/Nutrients: 

No significant chemical inputs have been noted in surveys of this basin (USFWS, 2003). 

The Oregon Department of Transportation (ODOT) uses one of two de-icing liquids on Highway 58, 

magnesium chloride or calcium magnesium acetate. There two stream crossings in the analysis area 

over the Little Deschutes River that could be potentially affected by these contaminates. One crossing 

is Highway 58, and the other is County Road 61. ODOT lists the following measures to reduce 

environmental impacts associated with their de-icing program. From the ODOT website, efforts to 

protect the environment include: 

• Researching anti-icer/deicer types and application rates to ensure there are no significant 

impacts to streams or fish. 

• Using anti-icers/deicers instead of sanding material to reduce air pollution. Sanding materials 

can increase particulate (small particles) air pollution. 
Environmental Impact Statement BLT Project 

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273

• Anti-icer/deicer products used are on the Pacific Northwest Snowfighters Association 

Qualified Products List. 

• Maintaining strict standards for winter anti-icers/deicers and sand to ensure products are clean 

and free of pollutants. 

• Applying the least amount of anti-icer/deicer and sand necessary to maintain the driving 

surface. 

• Minimizing the use of anti-icers/deicers and sand near environmentally sensitive areas. 

• Updating winter maintenance practices and policies, as new technologies become readily 

available. 

Alternative A 

Direct and Indirect Effects 

There would be no change chemical contamination or potential for nutrient input above those levels 

described in the existing condition. 

Action Alternatives 

Direct and Indirect Effects 

Chemical Contamination/Nutrients: 

Chemical contaminants would not increase in area water bodies. Project activities are limited to outside 

riparian reserve buffers (except unit 1061), decreasing the potential for contamination, such as 

petroleum products associated with logging equipment, to enter waterways. As standard operating 

procedure within riparian areas (unit 1061), prescribed burning is performed using propane torches. 

Existing Condition for Flow/Hydrology

Changes in Peak Flow/Base Flow: 

Discharges are within the natural range. No documented irrigation withdrawals or dams are located 

within the Upper Little Deschutes Watershed. There may be diversions and/or drawings from the Little 

Deschutes River on private property in the Two Rivers neighborhood, but this is not shown on the 

Oregon Water Resources, Water Rights map 

(http://map.wrd.state.or.us/apps/wr/wr_mapping/?TOC_CFG=WR). 

An undocumented diversion ditch exists on the left bank side of the Little Deschutes River 

approximately three miles upstream of the town of Crescent on Forest Service managed lands. This 

diversion ditch has been maintained by unknown persons and draws approximately 25 percent of the 

summer low flow. The Oregon Water Resources Division has been made aware of this diversion, but to 

date no actions have been taken to close this diversion. It is unknown if the diversion pre-dates the 

Forest Service. If the diversion does indeed pre-date the Forest Service, the diversion would be legal. 

Additional water withdrawal/storage rights are maintained downstream within the private property 

areas of Crescent and Gilchrist, OR. The largest water right is owned by the Crown Pacific timber 

company, which utilizes up to 3.0 cubic feet per second for mill operations and water is stored behind 

their log pond dam 

Alternative A 

Direct and Indirect Effects 

Changes in Peak/Base Flow 

There would be no changes to peak or base flows above those levels described in the existing condition. 

However, this alternative has the highest risk of increasing flows. If no active vegetation management 

occurs, a landscape-wide disturbance process to a scale that has potential to remove vegetation and 

increase flows is more likely. 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

274

Action Alternatives 

Direct and Indirect Effects 

Changes in Peak/Base Flow 

No harvest activities would occur within the riparian reserve under any of the alternatives and 

infiltration rates are high in the porous, ash soils of the planning area, changes in peak and/or base flows 

are not anticipated. 

Cumulative Effects 

There are no past, present, or foreseeable actions identified that are additive to indirect and direct 

effects discussed in the BLT project for fisheries or water quality. Foreseeable projects, such as the 

Spruce Creek Riparian Rehabilitation project, do not overlap the zone of influence for this project in 

time and space. In this case, discussions of past timber sales and how they incrementally affect water 

quality is not an informative process. The existing condition disclosure describes the aggregate of all 

past and present actions in context with how the various water quality parameters are currently 

functioning. Reference the soils report in this chapter for additional information on soil quality. 

Aquatic Conservation Strategy (ACS) 

The following documents consistency with the Aquatic Conservation Strategy (ACS) Objectives and 

Standards and Guidelines. This finding includes water quality protection found in Best Management 

Practices (BMPs), Standard and Guidelines listed in Appendix A, and management direction found in 

the soils and hydrology/fish section of this document. Beneficial uses of the streams in the analysis 

area would be protected in a manner consistent with the strategy outlined in the Northwest Forest Plan 

and the Clean Water Act of 1972. BMPS have been used numerous times on the Deschutes National 

Forest in contract provisions in addition to Project Design Criteria listed beginning in Chapter 2 and 

have been proven to be effective numerous times on recent projects such as the Davis Fire Recovery 

Project, Crescent Lake Wildland Urban Interface Fuels Reduction Project, and Seven Buttes Return. 

The following ACS discussion is at both the project and watershed scale. 

The BLT project is located within the Upper Little Deschutes (1707030201) 5th field watershed. This 

watershed includes the headwaters of the Little Deschutes River in the Mt Thielsen Wilderness and 

tributaries such as Hemlock Creek and Crescent Creek. Past disturbances such as grazing, insect 

infestation in lodgepole pine, subsequent timber harvest, and beaver removal has degraded stream and 

riparian habitats. These disturbances have reduced shade, habitat complexity and lengthened the 

timeline for wood recruitment. Also, they have caused an increase of fine sediment supply and widened 

stream banks. The loss or reduction in beaver activity resulted in the loss of beaver dams and the 

subsequent lowering of the ground water elevation, reducing hyporheic exchange and riparian 

vegetation. While beavers remain largely absent from the landscape, riparian reserve conservation 

measures and the discontinuation of grazing has allowed these streams to begin recovery. Private 

ownership on the Little Deschutes River mostly lies downstream from project activities. All existing 

condition discussions account for activities that are occurring on these lands downstream. 

The Little Deschutes River is the main water body in the watershed and planning area. The Little 

Deschutes River is characterized as a Rosgen E channel type (highly sinuous, low slope, and a deep, 

narrow channel) through most of the watershed, with small sections of B and C types. This highly 

sinuous channel has recovered quite well following the removal of livestock grazing. Downstream of 

the community of Two Rivers, the riparian area is largely dominated by dense and sometimes decadent 

willow thickets. Upstream of Two Rivers, the riparian area is largely open meadow dominated by 

sedges, grasses and rushes as well as wild flowers such as lupine and paint brush. There are pockets of 

lodgepole pine and spruce stands along the creek. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

275

Portions of the Little Deschutes River and Hemlock Creek are 303(d) listed for not meeting state of 

Oregon water quality standards. Water quality exceedences are for excessive temperature and reduced 

dissolved oxygen. 

Biologically, the Little Deschutes River and its tributaries are dominated by non-native brook and 

brown trout. Native redband trout are scarce to non-existent upstream of the Interfor/Gilchrist Mill 

Pond. 

1. Maintain and restore the distribution, diversity, and complexity of watersheds and landscape 

scale features to ensure protection of the aquatic systems to which species, populations and 

communities are uniquely adapted. 

Actions in Alternatives B, C and D are designed to limit the extent of disturbance processes on a project 

and landscape scale. There are no identified short term effects on a project scale. The Crescent Ranger 

District developed a Landscape Analysis Process, the priorities in upland vegetation identified retention 

of large trees on the landscape, development of replacement trees as large trees inevitably are lost, and 

to increase resilience of forest stands to disturbance agents (insects and fire). Proposed activities within 

the BLT Project were developed to address these priorities. 

By maintaining structural components within their Historical Range of Variability, particularly adjacent 

to riparian resources, distribution, diversity and complexity are maintained by reducing risk of a widescale event, setting the watershed back to an early seral and less complex condition. Aquatic systems 

would be avoided by active management on all stream reaches except Unit 1061 where small diameter 

thinning and prescribed burning is planned adjacent to homes in the Two Rivers subdivision. At the 

project scale, it moves toward restoring the features (riparian vegetation/willows) that make this 

watershed complex. At the watershed scale, the effects of the project maintaining and restoring 

complexity are very small. 

Prescriptions in the uplands have been designed to focus on understory removal in HTH and to improve 

overall stand health in lodgepole pine (HIM) resulting in a landscape-scale reduction of competition for 

scarce resources. Upland prescriptions maintain vegetative species diversity, and much of the analysis 

area is retained in a passive management scenario to provide species complexity. 

The Baja 58 timber sales conducted 2,878 acres of understory commercial thinning in areas that overlap 

with BLT, however, Viable Ecosystems modeling has accounted for all active management that has 

occurred prior to September 2004. Since that time, Baja West, Critter, and the Lower timber sales from 

Baja 58 EA and Finding of No Significant Impact have been completed (1,310 acres). These additional 

acres of thinning prescriptions were designed to maintain and restore the distribution, diversity, and 

complexity of watersheds and landscape scale features by retaining the largest trees and moving 

towards a more resilient landscape. Diversity of tree species is maintained by limiting the extent of a 

landscape scale event and keeping the appropriate mix of species for the site. There are no other past, 

present, or foreseeable actions that have potential to affect this objective at the project or watershed 

scale. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. 

Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope 

areas, headwater tributaries, and intact refugia. These lineages must provide chemically and 

physical unobstructed routes to areas critical for fulfilling life history requirements of aquatic 

and riparian dependent species. 

All alternatives maintain the existing riparian connectivity between watersheds by limiting almost all 

active management to outside riparian resources. There are no short-term effects to this objective on a 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

276

project or watershed scale. Spatial and temporal connectivity along stream drainages would be 

maintained through the implementation of the Forest Plan riparian reserve widths (USDA, 1994), 

Northwest Forest Plan and INFISH Riparian Habitat Conservation Areas. All fish bearing streams 

would have no-harvest buffers of two standard tree heights site potential (minimum of 300 feet). Nonfish bearing streams and ephemeral streams would have one standard tree height or 150 feet no-harvest 

buffer placed on either side of the stream. Seasonal and ephemeral drainages would be maintained with 

a 50 foot buffer on both sides. Riparian reserve buffers would be maintained at the greater of the 

distance from stream channel or from riparian vegetation. The Little Deschutes River lies within a 

broad floodplain with riparian vegetation extending up to several hundred feet beyond the edge of the 

stream channel. This is important in protecting systems such as the Little Deschutes River, where the 

floodplain/riparian area can be several hundred feet wide. These areas allow for connectivity between 

riparian areas and upland areas as well as maintain the micro-climate within the riparian area. 

In addition, connectivity between upland areas is maintained by identifying connectivity corridors 

between late and old structural stands (Figure 3-25) inside and outside the watershed. Vegetative 

prescriptions have been designed in consideration of those dependent species that would most likely use 

these areas. 

The Spruce Creek Riparian Restoration project overlaps the BLT analysis area and would improve 

aquatic connectivity by removing encroaching small diameter lodgepole pine, invigorating decadent 

willows and planting riparian vegetation. 

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, 

and bottom configurations. 

There would be no effect in the short- or long-term to the physical integrity of the aquatic system on a 

site specific and watershed scale. Physical integrity of the aquatic system would be maintained and 

preserved by adhering to the recommended riparian reserve widths outlined in the Northwest Forest 

Plan, INFISH, and by using Best Management Practices (BMPs) (USDA, 1988) on a project and 

landscape scale. There are no short- or long-term effects identified at the project or watershed scale for 

this objective. As described in ACS objective #1, maintaining vegetation in the uplands within the 

range of conditions that were likely present when fire played a more frequent role, the physical integrity 

of aquatic systems is protected by reducing the risk of a disturbance event entering the riparian areas. 

Although proposed harvest would physically disturb a portion of subwatershed upland areas, it is 

unlikely that detectable changes would occur within the streams or their riparian areas (Chapter 3, 

Aquatic Resources and Soil Quality). Area streams would experience no loss of instream woody 

material or potential for future recruitment. 

4. Maintain and restore water quality necessary to support a healthy riparian, aquatic, and 

wetland ecosystem. Water quality must remain in the range that maintains the system biological, 

physical, and chemical integrity and benefits survival, growth, reproduction, and migration of 

individuals composing aquatic and riparian communities. 

The primary parameters for water quality most likely affected as a result of active management are for 

increases in water temperature and sediment delivery. Water quality parameters regulated by the State 

of Oregon under the Clean Water Act include temperature, turbidity, and total dissolved solids in 

streams and temperature, pH, and chlorophyll a in lakes. Lower Hemlock Creek is 303(d) listed for 

exceeding bull trout spawning and rearing standards and the Little Deschutes River is listed for 

exceeding water temperature standards for bull trout rearing or red band salmonid water bodies and not 

meeting dissolved oxygen parameters from river mile 0-68.8. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

277

The reduction of shade is the primary concern related to increases in water temperature while increased 

erosion and sedimentation are the most likely to affect turbidity and total dissolved solids. The 

transport of nutrients to the streams as a result of sediment delivery can also affect water quality. 

Water temperatures and water quality within the analysis area and downstream into the Deschutes River 

are not expected to be affected as the result of active management. There would be no change to the 

303(d) parameters for which both streams are listed. No shade will be removed from water bodies. 

Activities in Unit 1061 are designed to improve the health and vigor of riparian vegetation, including 

willows. Currently, small lodgepole pine seedlings are encroaching into meadow habitat and riparian 

vegetation, including willows which are in a very decadent condition. Approximately one year after 

prescribed burning, the willows are expected to respond by an increase in canopy and ultimately 

providing shading. All overstory trees with the ability to affect shading of the stream and riparian area 

would not be disturbed. All work would be implemented by hand crews to minimize disturbance of 

surface soils and reduce the probability of mobilizing sediment to the stream. 

For the upland activities, road construction, use and maintenance, and ground disturbance from timber 

harvest can potentially contribute to erosion and an increase in stream turbidity. It was determined that 

potential sedimentation and turbidity as a result of management activities would be indistinguishable 

from background levels (Chapter 3, Fisheries and Water Quality). Temporary roads would be restored 

to proper hydrologic function after their use is no longer required, and harvest activities would be 

restricted to times and locations appropriate for site conditions. The topography has minimal drainage 

features and high infiltration rates which minimizes potential overland flows capable of detaching 

sediment and carrying it directly into stream channels. This finding is also based upon professional and 

personal observation of recent projects of similar activities on the Crescent Ranger District, and the 

safeguards built into the project such as BMPs, standards guidelines found within the Forest plan as 

amended for water quality (ACS, INFISH), and maintenance of soil quality within Regional Guidelines 

(Chapter 3, Soil Quality). Therefore, reductions in shade/increases in stream temperature and increased 

sediment delivery are not expected. 

5. Maintain and restore the sediment regime under which the aquatic system evolved. 

Elements of the sediment regime include the timing, volume, rate, and character of the sediment 

input, storage, and transport. 

Proposed activities will not affect the flow regime or bed/bank stability and therefore would not have an 

effect on the sediment regime of the analysis area and downstream systems. 

Due to the spring origin of area streams, their hydrograph is relatively stable. Streams within the BLT 

area have generally well vegetated banks and sediment contributions from bank erosion is considered 

very low. The area has recovered from past grazing practices after nearly a decade. 

All action alternatives will maintain the sediment regime at current levels (see ACS #4 and Aquatic 

Resources in Chapter 3) and will allow the system to continue recovery. Although activities include 

actions that increase the potential contribution of sediment and generating concentrated flows, factors 

described in ACS #4 such as gentle terrain and porous soils reduce this risk considerably. Potential 

input of fine sediments to spring-fed streams is typically from hydrologic connectivity with roads. 

There would be no additional permanent roads constructed and temporary roads would not have 

hydrologic connectivity. 

Overlapping dispersed recreation and Off Highway Vehicle use in the area has affected less than one 

percent of the riparian system, trampling vegetation and some rutting from inappropriate access. The 

Travel Management Rule implementation in 2009 would lessen this potential for additional sediment 

input. Also, approximately 1,310 acres of understory thinning units in the Baja project are well away 
BLT Project Environmental Impact Statement 

Chapter 3 – Fisheries and Aquatic Resources 

278

from stream systems and have no potential for additive effects because of the relatively gentle terrain, 

well-drained soils, and Best Management Practices. 

6. Maintain and restore instream flows sufficient to create and sustain riparian, aquatic, and 

wetland habitat and to retain patterns of sediment, nutrient, and wood routing. 

The BLT analysis area can be categorized as highly porous soils resulting from the eruption of Mt. 

Mazama. This has resulted in very few surface water features and streams typically originate in the 

valley bottoms as springs, not higher up on the hill slopes – a condition more prone to disruption of 

sediment, nutrient, and wood-routing patterns. 

Project activities would not result in any direct changes to riparian habitats as riparian reserve buffers 

are being maintained on all stream channels as defined by the Northwest Forest Plan, INFISH, and the 

Deschutes National Forest Plan. For a description of unit 1061 on Hemlock Creek, see ACS #4. Unit 

1061 would not change this objective for a project scale short or long term, or from a watershed 

perspective. Riparian buffers are expected to protect area streams from decreased base flows as well as 

increased peak flows (Chapter 3, Aquatic Resources). 

None of the action alternatives would affect base flow conditions, nor instream flows, to an extent that 

would inhibit riparian, aquatic, and wetland habitats in the project or on a landscape scale. Also, the 

timing, magnitude, duration, and spatial distribution of flows contributed by storm events and 

associated overland runoff from areas within the analysis area would not be affected. 

7. Maintain and restore the timing, variability, duration of the floodplain inundation and water 

table elevation in meadows and wetlands. 

The area of influence to instream flows by the project is relatively minimal. Unit 1061 would not 

change this objective for a project scale short or long term, or from a watershed perspective. Seasonal 

peak flows occurring as a result of snowmelt are not likely to be affected by the BLT project, with the 

timing and duration of floodplain inundation from this mechanism not expected to change. Peak flows 

as a result of storm events occur as summer thunderstorms or more typically as rain on snow events. 

Higher flows capable of channel alteration are unlikely to occur and inundation that does occur would 

contribute fine sediment to floodplain areas. Most of the streams in the area have very good floodplain 

connectivity, with broad, well vegetated floodplains. Therefore, peak flows are easily released onto the 

floodplain and energy and sediment dissipated without damaging the stream channel. 

Fire exclusion and the loss of beaver colonies are the largest contributor to loss of meadows and 

wetlands in some areas where riparian vegetation (such as willow) have become decadent and 

lodgepole pine has encroached. Beaver have either been trapped or have left the area for better habitat. 

Beaver dams are key in using willows to construct beaver dams, which in turn, decrease stream energy 

and downcutting, and elevate water tables. Restoration activities, such as unit 1061 along Hemlock 

Creek and Spruce Creek Riparian Rehabilitation Project, would incrementally reverse this process and 

restore riparian vegetation, beaver habitat, and meadow hydrology. 

The 1,310 acres of understory thinning on the Baja project in addition to the BLT project are not 

expected to change the timing and duration of floodplain inundation. Understory thinning activities 

would leave the area in a fully vegetated condition and they are well away from water. No other past, 

present or foreseeable activity in the BLT analysis area would have an effect on floodplain inundation 

or water table elevations within the analysis area and downstream outside the watershed. Timing, 

variability, and duration of floodplain inundation and water table elevations would remain at current 

levels. 
Environmental Impact Statement BLT Project 

 Chapter 3 – Fisheries and Aquatifc Resources 

279

8. Maintain and restore the species composition and structural diversity of plant communities 

in riparian zones and wetlands to provide adequate summer and winter thermal regulation, 

nutrient, appropriate rates of surface erosion, bank erosion, and channel migration, and to 

supply amounts and distributions of large wood sufficient to sustain physical complexity and 

stability. 

The BLT project would not change species composition or structural diversity of plant communities in 

riparian zones or wetlands except on a very small project scale and short-term in unit #1061. There, the 

objective is to restore proper riparian function and riparian vegetation vigor in the long-term. On a 

landscape scale, the amount and distribution of coarse woody debris sufficient to sustain physical 

complexity and stability within the aquatic system will be unaffected by the implementation of this 

project and any other activities within the watershed. Riparian reserve buffers are being maintained for 

commercial timber harvest areas, therefore large woody material and future recruitment potential would 

remain unchanged. 

Implementation of action alternatives would not result in timber harvest disturbance within the riparian 

zones of streams in the analysis area. Trees with the potential to be recruited as future large woody 

debris would not be distributed. Appropriate rates of surface erosion, bank erosion, and channel 

migration are also not expected to be affected by proposed active management. Although coarse woody 

material would be removed in upland areas, there would be no decrease in the amount available to the 

stream channels and riparian areas locally or on a watershed scale. 

The only other overlapping riparian project is the Spruce Creek Rehabilitation project that is intended to 

restore riparian vegetation. No other past, present, or foreseeable action is within the riparian zone, or 

has potential to affect thermal regulation or downed wood distribution. 

9. Maintain and restore habitat to support well-distributed populations of native plant, 

invertebrate riparian-dependent species. 

Only one unit, (1061), will actively manage vegetation within the riparian zone. It promotes the 

restoration of riparian habitat conditions and meadow hydrology on a project scale in the short and 

long-term. Restoring populations of riparian vegetation such as willow, provides a food source for 

beavers that historically played a significant role in maintaining the hydrologic function. Maintenance 

of upland vegetative condition and its role in maintaining riparian habitat is discussed in ACS #1. 

The Spruce Creek Restoration Project has similar goals in restoring floodplain function and restore 

riparian vegetation. Although this project and Unit 1061 would contribute to restoring very important 

habitats for native plants and invertebrate riparian-dependent species, from a watershed scale, there 

would not be very much change from the current condition. There are no other past, present or 

foreseeable actions in the watershed that have potential to affect this objective. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wild and Scenic River 

280

Wild and Scenic River_________________________________ 

Figure 3-27. Wild and Scenic River Corridor 

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The USDA is an equal opportunity 

provider and employer

BLT Boundary

Potential Management Activity Units

T.26S. R.07E.

Existing Condition 

The Little Deschutes River is part of the National Wild and Scenic Rivers System from its headwaters 

to the Forest Service boundary with the community of Two Rivers encompassing 2,445 acres. 

Management allocations overlapping or included within this area are Riparian Reserves (NWFP), 

Riparian Habitat Conservation Areas (INFISH), Oregon Cascades Recreation Area (Congressionally 

designated and 1990 LRMP), and Mt. Thielsen Wilderness (Congressionally designated). The goal of 

the management plan is to protect and enhance the resource values for which the river is designated and 

maintain the character with an emphasis on identifying and rehabilitating degraded resources (Little 

Deschutes Wild and Scenic River Management Plan, 2001). 

There are three designation categories for Wild and Scenic Rivers; Wild Rivers (which tend to be very 

pristine with little evidence of human influence), Scenic Rivers and Recreational Rivers. The Little 

Deschutes has been classified as a Recreational River, with the focus on preserving the aesthetic values. 

The Outstanding Remarkable Values (ORVs) are Scenic/Vegetative and Geologic. Vegetative 

management activities are to be unobtrusive and blend with the natural landscape. 

The Wild and Scenic River corridor varies in width following section lines, but is generally greater than 

1⁄4 mile wide on each side of the river outside of the Oregon Cascades Recreation Area (OCRA) and 

Wilderness. 
Environmental Impact Statement BLT Project

 Chapter 3 – Wild and Scenic River 

281

The Little Deschutes Wild and Scenic section provides a variety of views. The upper portion reveals a 

deep canyon with steep walls and impressive views of craggy rock outcrops. This same physical 

character and topography that limits views also focuses attention on the river’s unique features, such as 

loop meanders, meander scars, and oxbow channels. Limited evidence of human influence exists in the 

form of one footbridge in the Oregon Cascades Recreation Area and some miscellaneous wire fencing 

in Cow Camp and near Two Rivers subdivision. These features are limited and do not detract from the 

overall pristine quality of the river corridor (Big Marsh Creek and Little Deschutes Wild and Scenic 

River Plans Decision Notice, Page DN-6). 

The riparian vegetation is recovering since livestock grazing was removed and the allotment was closed 

in 1994. Other impacts to vegetation include OHV use; however restrictions in place since the Wild 

and Scenic status have been successful in preventing damage to the riparian zone. The current Travel 

Management Rule process is expected to be finalized in 2009 and this should further protect Wild and 

Scenic values in the area. In addition, in 2007, there was a small restoration project along 2.5 miles of 

river downstream from the Oregon Cascades Recreation Area. Approximately 400 trees were placed 

instream to replace wood removed during livestock grazing operations. Overall, the river banks are 

improving, showing signs of stabilization, a rising water table, and the channel becoming narrower. 

The next zone, adjacent to the riparian vegetation, could be classified as “pine flats” which the Wild 

and Scenic Plan describes as imminently susceptible to a wide scale disturbance process. This area 

does not appear “pristine” because of the mortality associated with the mountain pine beetle and 

subsequent salvage activities. The Plan describes treatments as justified if the primary reason is to 

reduce the risk in the corridor. Prior to the Plan, in the 1990s, the corridor vegetation in both the 

riparian and lodgepole zone were modified by extensive mortality from pine bark beetle and subsequent 

blow-down events. Salvage of the dead and down material occurred throughout the corridor from the 

Oregon Cascades Recreation Area boundary to the Two Rivers subdivision. Since the 2001 Plan, other 

non-commercial activities, such as small diameter thinning and girdling of overstory diseased trees have 

occurred in areas that were salvaged previously. 

The third zone of vegetation is classified as ponderosa pine, Douglas-fir and true fir on the canyon 

slopes. Stands are characterized as high density, which also make them highly susceptible to 

disturbance processes, particularly fire. Given the condition of the lodgepole pine stands below them, 

thinning and burning in these stands was also identified as an appropriate activity. 

The following standards and guidelines have been developed for vegetative management in the Little 

Deschutes River Wild and Scenic River Management Plan (Page 12). These replace the interim 

management direction found in the Deschutes Forest Plan. 

• Project planning within the river corridor will use the Visual Quality Objectives (Scenery 

Management System) as a basis for analyzing scenic quality impacts of proposed management 

actions. 

• Although no programmed timber harvest can be scheduled within the corridor, it does not 

preclude harvesting as long as the volume does not count towards Allowable Sale Quantity 

(ASQ) calculations. 

• Vegetation management activities will aim to maintain the naturalness of the area, provide 

scenic diversity, maintain the health of vegetation, and reduce the risk of fire. Appropriate 

methods include prescribed fire, commercial harvest (including salvage), commercial fuel wood 

or other methods that have a minimal impact on river values and that provide a clear benefit of 

the long-term protection and enhancement of river values. 
BLT Project Environmental Impact Statement 

Chapter 3 – Wild and Scenic River 

282

• Fuel loads should be reduced wherever possible to reduce imminent susceptibility to 

catastrophic fire. 

• Created openings should not be more than three (3) acres in size, except salvaging areas of 

catastrophic damage. 

Direct and Indirect effects for All Action Alternatives 

All activities have been found to be consistent with the Little Deschutes Wild and Scenic 

Management Plan by maintaining activities subordinate to the landscape, maintaining an existing 

level of scenic integrity (short- term), improving the scenic integrity level in the long-term, and 

reducing risk of a wide-scale disturbance event. 

The BLT project includes eleven proposed units within the Wild and Scenic River corridor of the Little 

Deschutes River. These units have been identified for treatment to improve forest health conditions and 

promote the development of large trees by thinning small trees. This process would help improve stand 

condition and appearance as the result of the 1990 bark beetle infestation. Potential units within the 

Wild and Scenic River corridor by alternative with vegetative prescription are listed in the following 

table. 

Table 3-85. Units and Acres within the Wild and Scenic River Corridor by Alternative 

Alternative B Acres Alternative C Acres Alternative D Acres 

1185 *107 

1195 **10 **1195 10 **1195 10 

1200 *57 

1205 *68 1205 68 

1215 *128 *1215 128 *1215 128 

1240 *18 

1245 **47 **1245 47 **1245 47 

1246 **8 **1246 8 **1246 8 

1255 **14 **1255 14 **1255 14 

1265 **37 **1265 37 **1265 37 

1300 *47 *1300 47 

Total 541 Total 244 Total 359 

* = Improvement Cutting (HIM) primarily in lodgepole pine 

** = Thinning/Density Reduction (HTH) primarily in ponderosa pine and Douglas-fir 

All activity along the Little Deschutes River would occur outside the riparian buffers, which is a 

minimum of 300 feet on both sides of the river. Units 1195, 1245, 1246 and 1255 fall within the Wild 

and Scenic corridor, however, Units 1185, 1200, 1205, 1215, 1240, 1265, and 1300 border the riparian 

reserve buffer. The Little Deschutes Wild and Scenic River Plan adopted Visual Quality Objectives 

(VQOs) for Partial Retention from the Deschutes Forest Plan. Those VQOs for timely cleanup of slash, 

retention of large trees, and limited visibility of management actions have been incorporated into the 

Project Design Features (Chapter 2) that are integrated into the following discussion of effects. These 

features, in addition to silvicultural activities, are designed to maintain the naturalness of the area and 

provide scenic diversity, while limiting the extent of a disturbance event within the corridor. Most of 

the activity units would be visible from the Little Deschutes River due to generally flat topography of 

the valley bottom. Roads 5830-300 and 5835-300 are the key access through the corridor and effect to 

scenery is based upon visitors either on the river or traveling these two roads. Water quality is expected 

to remain at its current level due to the distance from the river, methods utilized to minimize overland 

flow and sedimentation (please refer to sections titled “Fisheries” and “Hydrology and Water Quality” 

in Chapter 3 of this EIS), topography, and the porous nature of the soils. 
Environmental Impact Statement BLT Project

 Chapter 3 – Wild and Scenic River 

283

Effects to the vegetation are primarily from two silvicultural prescriptions. One, HTH, is a cultural 

treatment made to reduce stand density of trees primarily to improve growth and enhance forest health 

(Helms 1998). This prescription would be performed within the zone above the lodgepole pine in the 

ponderosa and Douglas-fir. It is similar to commercial thinning prescriptions, however stands do not 

have the same level of trees to retain as in a healthier stand. It is not a regeneration cut. Stands 

prescribed for HIM are primarily lodgepole pine impacted by the mountain pine beetle outbreak of the 

1980s. The stands have already appeared altered by the insect epidemic and subsequent salvage 

operations. The proportion of their overstories exhibit poor crowns and/or heavy mistletoe infection 

(generally greater than 1/3 of crown volume in mistletoe brooms) would be removed. These trees have 

poor growth rates and potential for infecting the understory with mistletoe is high. Because of the lack 

of a healthy overstory, the understory would contribute considerably to future growth. 

Following harvest, these stands would appear healthier, fuller crowned, and younger trees. However, 

older trees would be retained to create visual diversity. 

The HTH prescription would thin to a density biologically capable of future growth within the 20 or 30 

years before the next likely entry. This would primarily be achieved by thinning from below – the 

removal of trees from the lower crown classes to favor those in the upper crown classes (Helms 1998). 

After thinning, stands will average as low as 20 percent canopy cover and 50 square feet of basal area in 

lodgepole. Large trees would be highlighted from sensitive viewer locations where this occurs. 

Although not many large diameter trees are present, they would be highlighted to be more dominate on 

the landscape. Thinning prescriptions ensure these large trees are likely to remain long-term. All size 

class of trees, where present, would add to visual diversity. Also where present, diversity of tree 

species would be retained. 

Especially in lodgepole pine, all management actions would be noticeable in the short-term (1-5 years) 

until post sale thinning of small diameter trees and slash cleanup is completed. Logging residue or 

other management actions would not be obvious to the casual forest visitor due to timely cleanup (2 

years following completion of harvest activities) and hand piling in visible areas. 

Both prescriptions include 15 percent retention of the stands in a decadent condition which add to the 

visual diversity of the area. 

One temporary road would be needed within the corridor to facilitate economical harvest access into 

units 1200 and 1300 for Alternative B, and 1300 in Alternative D. It is expected to be 0.8 miles in 

length and lie on the east side of the river corridor. It would be constructed using an existing network 

of previously disturbed soil. This temporary road may be visible from the river corridor as its location 

is estimated to be approximately 500 feet from the riparian area. It would be obliterated following 

harvest and post-sale operations and restored to a condition that is hydrologically functional and able to 

revegetate more quickly. 

In addition to the Outstandingly Remarkable Value associated with vegetation are the geologic features 

within the Deschutes River Canyon. There are no activities planned above the Oregon Cascades 

Recreational Area boundary within the canyon. 

The following is a description by unit of proposed activity: 

Unit 1185 is 108 acres and lies mostly on the west side (opposite of river channel) of FS road 5830300 

and adjacent to the riparian reserve. This unit is visible from the FS road 5830300 and likely visible 

from the Little Deschutes River. The prescription for unit 1185 is to select for the best appearing 

crowns for retention (HIM). Mechanical ground-based harvest systems would be utilized with a buffer 
BLT Project Environmental Impact Statement 

Chapter 3 – Wild and Scenic River 

284

maintained along FS road 5830300. Fuels treatments include grapple piling and underburning. Hand 

piling would be done in lieu of grapple piling within the view corridor of FS road 5830300. 

Unit 1195 is 39 acres and lies to the east of the Little Deschutes River along FS road 5835300. The 

prescription is to thin to highlight large trees (HTH). Mechanical ground-based harvest systems would 

be utilized with a buffer maintained along FS road 5835300. Fuels treatments include grapple piling. 

Hand piling would be done in lieu of grapple piling within the view corridor of FS road 5835300. 

Unit 1200 is 57 acres and is between FS road 5835300 and the riparian reserve buffer of the Little 

Deschutes River. The silvicultural prescription is for a harvest improvement cut (HIM). Mechanical 

ground-based harvest systems would be utilized with a buffer maintained along FS road 5835300. 

Fuels treatments would include grapple piling with the exception being within view of FS road 5835300 

where slash would be hand piled. 

Unit 1205 is 68 acres and lies to the east of the Little Deschutes River. The silvicultural prescription is 

for a harvest improvement cut (HIM). Mechanical ground-based harvest systems would be utilized 

with a buffer maintained along FS roads 5835300, 5835330 and 5835320. Fuels treatments would 

include grapple piling with the exception being within view of FS road 5835300 where slash would be 

hand piled. 

Unit 1215 is 128 acres and lies mostly to the west of FS road 5830300. The silvicultural prescription is 

for a harvest improvement cut (HIM). Mechanical ground-based harvest systems would be utilized 

with a buffer maintained along FS road 5830300. Fuels treatments would include grapple piling with 

the exception being within view of FS road 5830300 where slash would be hand piled. 

Unit 1240 is 18 acres and lies to the east of the Little Deschutes River. This unit borders the riparian 

reserve of the Little Deschutes and is bisected by FS road 5835300. The silvicultural prescription is for 

a harvest improvement cut (HIM). Mechanical ground-based harvest systems would be utilized with a 

buffer maintained along FS road 5835300. Fuels treatments would include grapple piling with the 

exception being within view of FS road 5835300 where slash would be hand piled. 

Unit 1245 is 69 acres east of the Little Deschutes River. The silvicultural prescription is to thin to 

highlight large trees (HTH) and mechanical ground-based harvest systems would be utilized with a 

visual buffer maintained along FS system roads. Hand piling of slash would occur within view of road 

5835300. 

Unit 1246 is 17 acres and lies to the east of the Little Deschutes River between FS roads 5835300 and 

5835330. The silvicultural prescription is to thin to highlight large trees (HTH). Harvest activities 

would be achieved using advanced harvest systems. Fuels treatments would be accomplished with 

hand piling. 

Unit 1255 is 46 acres and lies mostly to the west of FS road 5830300 and is within 800 feet of the 

riparian area of the Little Deschutes River. The prescription is to thin to highlight large trees (HTH). 

Mechanical ground-based harvest systems would be utilized with a buffer maintained along FS road 

5830300. Fuels treatments include grapple piling. Hand piling would be done in lieu of grapple piling 

within the view corridor of FS road 5830300. 

Unit 1265 is 37 acres and lies to the west of the Little Deschutes River between FS road 5830300 and 

the riparian buffer. The silvicultural prescription for unit 1265 is to thin to highlight large ponderosa 

pine trees (HTH). Mechanical ground-based harvest systems would be utilized with a buffer 

maintained along FS road 5830300. Fuels treatments would include grapple piling. Hand piling would 

be done in lieu of grapple piling within the view corridor of FS road 5830300. 
Environmental Impact Statement BLT Project

 Chapter 3 – Wild and Scenic River 

285

Unit 1300 is 48 acres and lies to the east of the Little Deschutes River between FS road 5835300 and 

the riparian reserve. This unit has been identified as potentially requiring a temporary road. The 

temporary road would be approximately 0.8 miles in length and may be visible from the river corridor. 

The silvicultural prescription is for a harvest improvement cut (HIM). Mechanical ground-based 

harvest systems would be utilized with a buffer maintained along FS road 5835300. Fuels treatments 

would include grapple piling with the exception being within view of FS road 5835300 where slash 

would be hand piled. 

Summary 

The proposed activities in each alternative do not change the Outstandingly Remarkable Geologic 

Value. For the Scenic/Vegetative Outstandingly Remarkable Values, activities are designed to 

maintain visual quality and vegetative health in the short- and long-term. Project Design Features 

from the Wild and Scenic River Plan have been incorporated to maintain the naturalness of the area 

with a focus on preserving the aesthetic values. Vegetative management activities would be 

unobtrusive and blend with the natural landscape. 

Cumulative Effects 

There are no additive (or incremental) effects associated with past, present, and foreseeable actions 

identified that overlap the river corridor in space or time. The existing condition was described in the 

2001 Wild and Scenic River Plan and updated in this document. All salvage activities are included in 

the existing condition discussions because that is the most informative way to display effects. There 

have been no other management activities that have occurred in the corridor since the signature of the 

Plan and closure of the allotment, beyond custodial activities such as suppression of wildfires, removal 

of allotment fencing, and small diameter thinning and non-commercial stand improvement activities 

described in the existing condition. For these reasons, the analysis of past actions other than those 

listed in this section is based on current environmental conditions. 
BLT Project Environmental Impact Statement 

Chapter 3 – Botany 

286

Botany _____________________________________________ 

Introduction 

The purpose of the biological evaluation is to comply with requirements of the Endangered Species Act 

of 1973, as amended. The Forest Service Manual (USDA Forest Service, 1995b) and the Land and 

Resource Management Plan for the Deschutes National Forest (Forest Plan) (USDA Forest Service, 

1990) both state that habitat for sensitive plant and animal species shall be Managed or Protected to 

ensure that the species do not become threatened or endangered. The Forest Plan also states that 

management guides (now referred to as Conservation Strategies) are to be developed and used. A 

conservation strategy is the Forest Service’s documentation for the management actions necessary to 

conserve a species, species group, or ecosystem. The Forest Service Manual (FSM) states that habitats 

for all existing native and desired non native plants, fish, and wildlife should be managed to maintain at 

least viable populations for each species (USDA Forest Service, 1995a). A viable population consists 

of a number of individuals adequately distributed throughout their range necessary to perpetuate the 

existence of the species in natural, genetically stable, self-sustaining populations (Phillips and Wooley, 

1994).

Prefield reviews were conducted in May 2003, November 2007, and January 2008 for the BLT Project 

units proposed for treatments. These reviews include a review of the local existing botany records to 

determine potential habitat for each Proposed, Endangered and Sensitive species (Regional Forester’s 

Sensitive Plant list). Then, habitat requirements of all PETS (Proposed, Endangered, Threatened, and 

Sensitive) plant species known or suspected to occur on the Crescent Ranger District, Deschutes 

National Forest were compared with habitats that occur within the planning area in order to target 

surveys, if needed. 

There are no Threatened, Endangered plants in or near the analysis area. 

The R6 Sensitive Plant List applies to all National Forest lands, including areas outside the Northwest 

Forest Plan. Changed and those changes were incorporated into the prefield reviews for BLT All 

survey protocols are consistent with the 1990 Deschutes National Plan, including plan amendments in 

effect on the date of decision. 

Survey Methods and Results 

Pre-disturbance plant surveys were conducted in 2003 for sensitive species (Table 3-88) and rare or 

uncommon plant taxa not on the R6 sensitive species list (Tables 3-86 and 3-87) that were documented 

or suspected to occur on the Deschutes National Forest, using methods in the survey protocols that were 

available at that time. Proposed activities that were determined to have suitable habitat for these nonvascular and vascular plant species were inventoried. Equivalent-effort surveys for vascular and nonvascular Category B species are to be done for project analyses in 2006 and later. Surveys are 

considered infeasible for fungi (Categories B, D, E, and F) except Bridgeoporus nobilissimus (Category 

A, perennial conk); the recommended protocol to determine presence/absence of fungal species is to 

survey a minimum of 3 times (every 2 to 3 weeks) for at least 3 years and preferably 5 years during the 

season in which each fungal species is expected to produce sporocarps. Equivalent effort surveys in 

potential habitats for fungal species in Category B are to be done for project analyses done in 2011 and 

later. 

After reviewing the Geographical Information System (GIS) Sensitive Plant layer and past survey 

information through the 2006 field season, no species on the current Region 6 Forester’s Sensitive 

Plant List were found to occur in the BLT analysis area. 

 At the time of the surveys Tritomaria exsectiformis, a Category B bryophyte, was not required to be 

surveyed for (analysis was prior to 2006). Reanalysis of the project in 2007-8 requires equivalent effort 
Environmental Impact Statement BLT Project

 Chapter 3 – Botany 

287

surveys for T. exsectiformis in potential habitat. No potential habitat exists in the units of any of the 

action alternatives, although potential habitat may occur within the boundary of the BLT analysis area. 

The following table reflects changes made to the Region 6 Sensitive Plant List (January 2008) for those 

species that are documented or suspected to occur on the Deschutes National Forest. Most plants that 

have been added to the R6 2008 Sensitive Species list known or suspected on Deschutes National 

Forest were determined to have marginal habitat, or were not present (last column). 

 Table 3-86. Prefield Review Summary (2008 Sensitive Plant List) 

R6 Sensitive Plant 

Species 

Documented or 

Suspected on the 

Deschutes 

National Forest 

Range Habitat 

Occupied 

Habitat 

in 

Planning 

Area?/On

Forest? 

Probability 

of 

Occurrence 

in Analysis 

Area 

Agoseris elata 

(vascular plant) 

Washington and 

Oregon Cascades 

Forest openings and forest edges 

adjacent to wet/moist meadows, 

lakes, rivers, and streams 

No/Yes Low; habitat 

marginal 

Alpova alexsmithii 

(fungus) 

Washington and 

Oregon Cascades 

Pine and mixed conifer forests, 

particularly hemlock. Below 

ground fruiting, primarily near 

Cascade crest. 

No/Yes Moderate 

Arabis suffrutescens 

var. horizontalis 

(vascular plant) 

South-Central 

Oregon 

Meadows, woods, summits, 

ridges, and exposed rock outcrops No/No Low; outside known range 

Arnica viscosa 

(vascular plant) 

South-Central 

Oregon Cascades, 

California 

Scree, talus gullies, lava flows 

and slopes w/ seasonal runoff. 

May be in moraine lake basins or 

crater lake basins 

No/Yes Low; habitat 

marginal 

Astragalus peckii 

(vascular plant) 

South-Central 

Oregon 

Basins, benches, gentle slopes, 

and meadows. No/Yes Low; habitat marginal 

Barbilophozia 

lycopodiooides 

(liverwort) 

Circumboreal, south 

to Oregon and Idaho High elevation peaks, peaty soil No/No 

Low, outside 

of habitat 

range 

Botrychium 

pumicola

(vascular plant) 

Central Oregon 

Alpine-subalpine ridges, slopes, 

and meadows. Montane forest 

openings, open forest in basins 

with frost pockets, pumice flats 

No/Yes Low; habitat 

marginal 

Brachydontium 

olympicum (moss) 

Alaska through 

Oregon, Cascade 

Mountains 

Subalpine to alpine boulder 

fields, moraines and cliff faces No/No 

Low, suitable 

habitat 

unlikely 

Calamagrostis 

breweri 

(vascular plant) 

Oregon North 

Cascades and 

California 

Non-forest moist-to-dry subalpine 

and alpine meadows, open slopes, 

streambanks, lake margins 

No/No Low; outside 

known range 

Carex abrupta 

(vascular plant) 

Oregon, California, 

Nevada 

Montane, forests, meadows and 

open slopes. Usually dry soils No/No Low 

Carex capitata 

(vascular plant) Circumboreal Wet meadows, fens and bogs No/Yes Low 

Carex diandra 

(vascular plant) 

Circumboreal, south 

to California 

Swamps, sphagnum bogs, lake 

margins No/No 

Low, no 

habitat in 

treatment area
BLT Project Environmental Impact Statement 

Chapter 3 – Botany 

288

R6 Sensitive Plant 

Species 

Documented or 

Suspected on the 

Deschutes 

National Forest 

Range Habitat 

Occupied 

Habitat 

in 

Planning 

Area?/On

Forest?

Probability 

of 

Occurrence 

in Analysis 

Area 

Carex lasiocarpa 

var. Americana 

(vascular plant) 

S Cascades of 

Washington, Idaho, 

Montana, Utah, 

irregularly to 

Oregon 

Mid elevation swamps and wet 

meadows No/Yes Low, outside known range 

Carex livida 

(vascular plant) 

Oregon 

Washington, 

California, Idaho 

In peatlands, including fens and 

bogs; wet meadows with still or 

channeled water 

No/No Low/habitat 

marginal 

Carex retrorsa 

(vascular plant) 

Nevada, Oregon, 

Washington, Idaho, 

to the north and east 

Bogs, swamps, wet meadows, 

stream margins No/No Low, edge of known range 

Carex vernacula 

(vascular plant) 

Washington, 

Oregon, California, 

Idaho 

Alpine, moist meadows, open 

slopes No/No Low, no habitat present

Castilleja chlorotica 

(vascular plant) 

Oregon east 

Cascades 

LP-PP, mixed conifer forest 

openings. PP at lower and LP at 

mid, and mixed conifer at highest 

elevations and eastside of the 

Ranger District. 

No/Yes 

Low; suitable 

habitat present 

on eastside but 

not 

documented in 

project 

Cheilanthes feei 

(vascular plant) 

Widespread western 

states, barely in 

Oregon 

Limestone rocky areas No/No Low, habitat 

marginal 

Chyloscyphus 

gimmiparis 

(liverwort) 

Oregon, Alaska, 

Utah 

High elevation montane streams, 

aquatic No/No 

Low, suitable 

habitat 

unlikely 

Collomia mazama 

(vascular plant) 

South-Central 

Cascades, Oregon 

Meadows (dry to wet, level to 

sloping); stream banks and bars, 

lakeshores and vernal pool 

margins; forest edges and 

openings; alpine slopes 

No/No Low; outside 

known range 

Conostomum 

tetragonum 

(moss) 

Circumboreal; from 

BC through 

California 

Subalpine to alpine boulder 

fields, moraines, and cliff ledges No/No 

Low, suitable 

habitat 

unlikely 

Cyperus acuminatus 

(vascular plant) 

Western states, west 

cascades Oregon Margins wet areas, lake edges No/Yes Low, habitat marginal 

Cyperus lupulinus 

ssp.lupulinus 

(vascular plant) 

Idaho, Eastern 

Washington, 

Oregon 

Rocky slopes adjacent to streams, 

low elevation No/No Low, habitat unlikely 

Dermatocarpon 

luridum 

(lichen) 

Oregon, 

Washington 

On rocks or bedrock in streams or 

seeps, usually submerged or 

inundated for most of the year 

No/No 

Low; suitable 

habitat 

present; 

sought, but not 

yet detected 

on DNF 

Elatine 

brachysperma 

(vascular plant) 

Washington, 

Oregon, California, 

Nevada 

Wet to drying muds No/No Low, habitat 

unlikely 

Eucephalus gormanii 

(vascular plant) 

Northern West 

Cascades 

Rocky ridges, outcrops, or rocky 

slopes No/Yes Low; outside 

known range 
Environmental Impact Statement BLT Project

 Chapter 3 – Botany 

289

R6 Sensitive Plant 

Species 

Documented or 

Suspected on the 

Deschutes 

National Forest 

Range Habitat 

Occupied 

Habitat 

in 

Planning 

Area?/On

Forest? 

Probability 

of 

Occurrence 

in Analysis 

Area 

Gastroboletus 

vividus 

(fungus) 

Rogue River NF, 

Crater Lake NP, 

CA. 

Higher elevation Shasta fir, 

Subalpine fir, mountain hemlock No/No Low; outside known range 

Gentiana newberryi

var. newberryi 

(vascular plant) 

Oregon east and 

west Cascades, 

California 

Wet to dry alpine, subalpine, and 

mountain mixed conifer zones, in 

forest openings and meadows, 

commonly with tufted hairgrass 

No/Yes Low; habitat 

marginal 

Helodium blandowii 

(moss) 

Circumboreal, south 

through Cascades to 

Sierra Nevada, and 

through Rockies to 

Arizona 

Montane fens with calcareous 

groundwater. No/Yes 

Low, suitable 

habitat 

unlikely 

Heliotropium 

curassavicum 

(vascular plant) 

Western United 

States 

Alkaline, saline playas, receding 

ponds and clay soils No/No Low, habitat unlikely 

Helvella 

crassitunicata 

(fungus) 

Oregon, 

Washington Montane forests, along trails No/Yes Low, outside range 

Hygrophorus 

caeruleus 

(fungus) 

Oregon, 

Washington 

Associated with roots of Pinaceae 

spp., melted snowbanks No/Yes Low, outside range 

Leptogium 

cyanescens 

(lichen) 

Oregon, 

Washington 

Generally riparian, but recently 

documented in upland settings on 

vine maple, big leaf maple and 

Oregon white oak 

No/No Low; habitat 

marginal 

Lipocarpha 

aristulata 

(vascular plant) 

Washington, 

Oregon, California, 

Idaho 

Low elevation streamsides, gravel 

bars No/No Low, habitat unlikely 

Lobelia dortmanna 

(vascular plant) 

Oregon East 

Cascades, 

Washington 

Shallow water at margins of 

lakes, ponds, and rivers or in 

standing water of bogs and wet 

meadows 

No/Yes 

Low; habitat 

marginal, 

outside 

proposed 

treatment units

Lycopodiella 

inundata 

(vascular plant) 

Oregon, Idaho, 

California, Montana 

– Circumboreal 

Deflation areas in coastal 

backdunes; montane bogs, 

including sphagnum bogs; less 

often wet meadows 

No/Yes Low; habitat 

marginal 

Lycopodium 

complanatum 

(vascular plant) 

Oregon, Idaho, 

Washington + 

Edges of wet meadows; dry 

forested midslope with >25% 

canopy cover 

No/No 

Low; outside 

known range, 

habitat 

marginal 

Muhlenbergia 

minutissima 

(vascular plant) 

Western United 

States 

Thin lava soils, associated with 

Typha, sedges No/No Low, habitat unlikely 

Ophioglossum 

pusillum

(vascular plant) 

Oregon, 

Washington, 

California, Idaho + 

Dune deflation plains; marsh 

edges; vernal ponds and stream 

terraces in moist meadows 

No/No 

Low; outside 

known range, 

habitat 

marginal 
BLT Project Environmental Impact Statement 

Chapter 3 – Botany 

290

R6 Sensitive Plant 

Species 

Documented or 

Suspected on the 

Deschutes 

National Forest 

Range Habitat 

Occupied 

Habitat 

in 

Planning 

Area?/On

Forest?

Probability 

of 

Occurrence 

in Analysis 

Area 

Penstemon peckii 

(vascular plant) 

Central Oregon east 

Cascades 

PP openings, open PP forests; 

mixed conifer openings; 

recovering fluvial surfaces 

No/Yes Low; outside 

known range 

Pilularia americana 

(vascular plant) 

Oregon, California 

+ 

Alkali and other shallow vernal 

pools, not recently used stock 

ponds, reservoir shores 

No/No 

Low; outside 

known range, 

habitat 

marginal 

Polytrichum 

sphaerothecium 

(moss) 

East Asia-Western 

North America 

through Alaska to 

Oregon; highest 

Cascade peaks 

Subalpine to alpine, forming 

green to brown sods on igneous 

rocks in exposed or sheltered 

sites. 

No/No 

Low, suitable 

habitat 

unlikely 

Potamogeton 

diversifolius 

(vascular plant) 

Oregon, Idaho, 

Nevada, California Aquatic, Pond edges, No/No 

Low, outside 

range, habitat 

unlikely 

Pseudocalliergon 

trifarium 

(moss) 

Circumboreal; 

British Columbia, 

Alberta, Montana, 

Oregon 

Montane fens, submerged to 

emergent or on saturated ground, 

usually in full sunlight 

No/No 

Low, suitable 

habitat 

unlikely 

Ramaria amyloidea 

(fungus) 

Oregon, 

Washington, 

California 

Mycorrhizal with true firs, 

Douglas fir, and western hemlock 

in humus or soil. 

No/Yes 

Moderate, 

suitable habitat 

present 

Rhizomnium nudum 

(bryophyte) 

Oregon, 

Washington + 

Moss found in moist coniferous 

forests. On DNF associates 

include lodgepole pine, 

Engelmann spruce, mountain 

hemlock, and western white pine 

No/Yes 

Moderate; 

suitable habitat 

present, not 

yet 

documented 

on Crescent 

Rorippa columbiae 

(vascular plant) 

Oregon, California, 

Washington 

Wet to vernally moist sites in 

meadows, fields, playas, 

lakeshores, intermittent stream 

beds, banks of perennial streams, 

along irrigation ditches, river bars 

and deltas, roadsides. 

No/Yes 

2 sites found 

on Crescent 

RD, not in 

analysis area. 

Moderate; 

suitable habitat 

present 

Rotala ramosior 

(vascular plant) 

Washington, 

Oregon, California, 

Idaho 

Low elevation low gradient 

shores, pond edges, river bars No/No Low, habitat unlikely 

Scheuchzeria 

palustris var.

americana 

(vascular plant) 

Oregon, 

Washington, 

California, Idaho + 

Open to canopied bogs, fens, and 

other wetlands where often in 

shallow water 

No/Yes 

Low; outside 

known range, 

habitat 

marginal 

Schistostega pennata 

(bryophyte) 

Oregon, 

Washington, 

circumboreal 

Mineral soil in crevices on lower 

and more sheltered parts of root 

wads of fallen trees near streams 

or other wet areas 

No/Yes 

Low; habitat 

marginal in 

proposed 

treatment areas
Environmental Impact Statement BLT Project

 Chapter 3 – Botany 

291

R6 Sensitive Plant 

Species 

Documented or 

Suspected on the 

Deschutes 

National Forest 

Range Habitat 

Occupied 

Habitat 

in 

Planning 

Area?/On

Forest? 

Probability 

of 

Occurrence 

in Analysis 

Area 

Schoenoplectus 

subterminalis 

(vascular plant) 

Oregon, 

Washington, 

California, Idaho + 

Generally submerged to emergent 

in quiet water 2-8 decimeters 

deep, in peatlands, sedge fens, 

creeks, ditches, ponds and lakes 

No/Yes Low; habitat 

marginal 

Scouleria marginata 

(bryophyte) 

Pacific Northwest 

endemic; Oregon, 

Washington, Idaho, 

northern California, 

southwestern British 

Columbia 

Exposed or shaded rocks in 

streams; seasonally submerged or 

emergent 

No/No Low; habitat 

marginal 

Splachnum 

ampullaceum 

(moss) 

Circumboreal; from 

Alaska through 

Oregon, and Alberta

Peatlands, wetlands, on old 

ungulate dung No/No 

Low, suitable 

habitat 

unlikely 

Texosporium sanctijacobi (lichen) 

Western North 

America 

In Oregon, late seral dry 

shrub/grassland No/No 

Low, no 

habitat in 

analysis area 

Tomentypnum nitens 

(moss) 

Circumboreal, 

Alaska through 

Oregon 

Montane fens at slightly elevated 

(stumps, logs, hummocks) No/Yes 

Moderate, 

habitat 

possible 

Trematodon boasii 

(moss) 

British Columbia 

through California, 

Japan, 

Newfoundland 

Subalpine stream, trail and pond 

edges. No/No 

Low, suitable 

habitat 

unlikely 

Tritomaria 

exsectiformis 

(liverwort) 

Alaska through 

Oregon, to 

Montana, Wyoming 

and Colorado 

Open to shaded coniferous forest 

along perennial flowing water 

from springs and seeps 

No/Yes 

Moderate, 

suitable habitat 

possible 

Utricularia minor 

(vascular plant) 

Western United 

states north through 

Canada 

Aquatic plant of pools, ponds, 

bogs, marshes, wet meadows No/Yes 

Moderate, 

habitat likely 

in analysis 

area 
BLT Project Environmental Impact Statement 

Chapter 3 – Botany 

292

The following two tables reflect those species from 2003 (updated in 2004) that are called “Rare and 

Uncommon”. The last column reflects their status, whether they are outside their known range and/or 

what type of survey is required. Over the years, species categories change as more information is 

gathered. There are no known sites or potential habitat for these species within the BLT planning area 

as of September 2008. 

Table 3-87. Rare or Uncommon Fungal and Plant Species with Known Sites on the Deschutes 

National Forest as of March 21, 2004 

Species Category Group District Notes 

Albatrellus 

caeruleoporus B Fungus CRE,SIS Manage all known sites 

Alpova alexsmithii B Fungus SIS 

Alpova aurantiaca B Fungus BFR 

Arcangeliella 

lactarioides B Fungus SIS 

Chaenotheca 

subroscida E Pin lichen CRE Manage all known sites 

Chalciporus 

piperatus D Fungus CRE Manage high-priority sites 

Choiromyces 

alveolatus B Fungus SIS 

Clavariadelphus 

ligula B Fungus CRE,SIS Manage all known sites 

Collelma nigrescens F Lichen SIS 

Cortinarius wiebeae B Fungus BFR 

Cypripedium 

montanum C Vascular CRE,SIS Manage all known sites 

Dermatocarpon 

meiophyllizum E Lichen BFR 

Elaphomyces 

anthracinus B Fungus SIS 

Elaphomyces 

subviscidus B Fungus BFR 

Gastroboletus ruber B Fungus SIS 

Gastroboletus 

subalpinus B Fungus CRE,BFR Manage all known sites 

Gastroboletus 

turbinatus B Fungus SIS 

Gautieria 

magnicellaris B Fungus SIS 

Gymnomyces abietis B Fungus BFR,SIS 

Helvella 

crassitunicata B Fungus SIS 

Hydnotrya inordinata B Fungus BFR 

Hygrophorus 

caeruleus B Fungus SIS 

Leptogium 

teretiusculum E Lichen SIS 

Mycena overholtsii D Fungus CRE Manage high-priority 

sites 

Phaeocollybia 

attenuata D Fungus Willamette NF? 

Polyozellus multiplex B Fungus BFR 
Environmental Impact Statement BLT Project

 Chapter 3 – Botany 

293

Species Category Group District Notes 

Ramaria amyloidea B Fungus CRE Manage all known 

sites 

Ramaria coulterae B Fungus SIS 

Ramaria 

rubripermanens D Fungus CRE Manage high-priority sites 

Rhizomnium nudum B Moss BFR 

Strategic Surveys 

complete, equivalenteffort surveys not 

needed (Memo, 

March 2006) 

Rhizopogon 

atroviolaceus B Fungus BFR 

Rhizopogon evadens

var. subalpinus B Fungus BFR,SIS 

Rhizopogon 

flavofibrillosus B Fungus BFR 

Rhizopogon truncatus B Fungus CRE, BFR Manage all known 

sites 

Schistostega pennata A Moss CRE Manage all known 

sites 

Tritomaria 

exsectiformis B Liverwort CRE, BFR, SIS

Manage all known 

sites. Equivalent 

effort surveys 

required FY06+ 
BLT Project Environmental Impact Statement 

Chapter 3 – Botany 

294

Vascular plants, bryophytes, lichens, and fungi requiring pre-disturbance surveys and lichens and 

bryophytes requiring equivalent effort surveys are listed in Bold in the table below. 

Table 3-88. Rare or uncommon plant taxa surveyed for in 2003. 

 Species in Bold require pre-disturbance or equivalent-effort surveys. 

Taxon and Group 2001 

category 

1994 

category Comments 

Allotropa virgata

vascular plant 

OFF 1, 2 Removed from S&M list in 1999 

Botrychium 

minganense 

vascular plant 

A 1, 2 DES outside known range 

Botrychium montanum 

vascular plant 

A 1, 2 DES outside known range 

Bridgeoporus 

nobilissimus 

fungus 

A 1, 2, 3 Perennial conk; low probability of 

occurrence 

Buxbaumia viridis

bryophyte 

OFF 1, 2 Removed from S&M list 

Marsupella emarginata

var. aquatica 

bryophyte 

B 1, 3 No longer suspected on DES based on new 

information 

Polyozellus multiplex

fungus 

B 1, 3 Surveys not required – impractical 

Equivalent effort surveys by FY2011 

Pseudocyphellaria 

rainierensis 

lichen 

A 1, 2, 3 

DES outside known range 

Rhizomnium nudum

bryophyte 

B Strategic Surveys completed, equivalent 

effort surveys not required 

Schistostega pennata 

bryophyte

A 1, 2 Sites found on Crescent District, none in 

or near analysis area. 

Tetraphis geniculata 

bryophyte

A 1, 2 DES outside known range 

Tritomaria 

exsectiformis 

bryophyte

B 1, 3 Equivalent effort surveys required for 

projects analyzed in 2006 and later. 

Ulota megalospora

bryophyte 

OFF 1, 2 Removed from S&M list 

Environmental Consequences 

Sensitive Species 

All Alternatives 

There are no known sites or potential habitat within the BLT analysis area; therefore there would be no 

effects on Sensitive and rare or uncommon plant species as a result of either a passive or active 

management scenario. 
Environmental Impact Statement BLT Project

 Chapter 3 –Invasive Plants 

295

Invasive Plants ______________________________________ 

Invasive plants are undesirable in forest ecosystems because they tend to displace native plants, 

including, potentially, rare and protected species, degrade habitat for animal species, promote soil 

erosion, and lessen the value of recreational experiences. As continually disturbed, often open areas, 

roadsides are highly suitable habitats for many invasive plants. Many of the weed sites within the 

analysis area are located along roadsides. Relating to this, motorized vehicles are most likely the 

major vector for the introduction and/or spread of invasive plants within the analysis area. Vehicles 

may include those associated with public recreational use or harvesting of special forest products 

(e.g., firewood, mushrooms), or general forest management operations including commercial harvest, 

inventory, monitoring, road maintenance and fire suppression. Vehicles have the potential to 

transport weed seeds included in soil and muck stuck in tire treads or on undercarriages. Also, 

portions of whole, seed-bearing invasive plant species can become wedged in bumpers and within 

undercarriages when vehicles drive through patches of weeds. By these means, weed seeds can be 

imported or moved about within the analysis area. 

The following Figure 3-28 displays mapped invasive plant species sites within the BLT area: 
BLT Project Environmental Impact Statement 

Chapter 3 – Invasive Plants 

296

Figure 3-28. BLT Invasive Species Sites T. 24 S. T. 25 S. R. 09 E. R. 10 E. Crescent Lake Fawn Lake

Maidu Lake

Oldenberg Lake

Bingham Lakes

58

61

US 9- 7

64

62

60

62

60

60

60

2

62

0123 0.5

Miles

The USDA is an equal opportunity provider and employerjm 9/22/08T:\r06\des\cre\project\eis\eis_blt\gis\map_product

All Action AlternativeInvasive Species Sites

State-BLM-County RoadsArterial RoadsBLT Boundary
Environmental Impact Statement BLT Project

 Chapter 3 –Invasive Plants 

297

Management Direction 

The National Forest Management Act (1976) specifies that National Forest System lands “provide for a 

diversity of plant and animal communities based on the suitability and capability of the specific land 

area in order to meet overall multiple-use objectives.” The implementing regulations (36 CFR 219.26) 

for the National Forest Management Act states that “forest planning shall provide for diversity of plant 

and animal communities and tree species consistent with the overall multiple-use objectives.” In 

addition, 36 CFR 219.27 (g) states that “management prescriptions shall preserve and enhance the 

diversity of plant and animal communities, including endemic and desirable naturalized plant and 

animal species, so that it is at least as great as that which would be expected in a natural forest, ... 

reductions in diversity of plant and animal species from that which would be expected in a natural 

forest ... may be prescribed only where needed to meet multiple-use objectives. Planned type 

conversions shall be justified by an analysis showing biological, economic, social, and environmental 

design consequences, and the relation of such conversions to the process of natural change.” 

The Noxious Weed Management Act (1974) contains provisions to prevent the dissemination of 

noxious weeds. Other provisions in the act authorize the cooperation of Federal agencies with agencies 

of State, districts, farmers’ associations and similar organizations or individuals in carrying out 

operations or measures to eradicate, suppress, control or retard the spread of any noxious weed. In 

addition, 36 CFR 222.8 acknowledges the Agencies’ obligations to work cooperatively in identifying 

noxious weed problems and developing control programs in areas where National Forest System lands 

are located. 

Executive Order 13112 implemented on February 3, 1999 requires Federal agencies to use relevant 

programs and authorities to prevent the introduction of invasive species and not authorize or carry out 

actions that are likely to cause the introduction or spread of invasive species unless the agency has 

determined, and made public, documentation that shows that the benefits of such actions clearly 

outweigh the potential harm, and all feasible and prudent measures to minimize risk of harm will need 

to be taken in conjunction with the actions. The USDA Forest Service Guide to Noxious Weed 

Prevention Practices (July, 2001) supports implementation of Executive Order 13112 on Invasive 

Species. 

Region 6 of the Forest Service has prepared an Invasive Plant Environmental Impact Statement 

(hereinafter called R6 IP FEIS). The Final EIS was released in June 2005 and the Record of Decision 

(ROD) was signed in October 2005 (USDA Forest Service R6, 2005); implementation began March 1, 

2006. The R6 FEIS applies to non-native invasive plant species, but not to native competing and 

unwanted vegetation. Standards and Guidelines in the R6 FEIS are incorporated into Forest Plans in 

the region. 

Forest Direction 

The Deschutes National Forest Land and Resource Management Plan is amended to incorporate 

Standards and Guidelines from the R6 IP FEIS. 

In 1998, the Deschutes National Forest Noxious Weed Control Environmental Assessment (Weed EA) 

with its supplemental Deschutes National Forest Integrated Weed Management Plan was completed in 

accordance with the Regional Vegetation Management FEIS and Mediated Agreement (USDA Forest 

Service, Deschutes National Forest, 1998). The Decision Notice from the Weed EA selected an 

alternative that allows a variety of noxious weed treatments, including herbicides. Currently, the 

Deschutes and Ochoco National Forests and Crooked River Grassland are working on a site-specific 

project Draft Environmental Statement to control invasive plants in central Oregon. 

The 1998 Forest Weed EA and associated management plan and Draft central Oregon Invasive Plant 

EIS identify and promote actions within the noxious weed management strategies of prevention, early 
BLT Project Environmental Impact Statement 

Chapter 3 – Invasive Plants 

298

treatment, maintenance, and awareness. Implementation of management strategies include analyzing 

the risk of noxious weed invasion during the project planning process and developing tactics to avoid 

introduction or spread of noxious weeds, clean equipment provisions in contracts, actions to prevent 

weed introduction and spread, and suggestions for increasing awareness of noxious weeds and the risks 

they pose, both within the Forest Service and with the public. 

Existing Condition 

Since the early 1990s, gathering information of location and size of infestations for all known invasive 

plant sites has been underway. This information has been entered into a database and GIS and has been 

updated on an annual basis. 

Under the authority of the 1998 Weed EA, noxious weeds have been treated within BLT analysis area 

starting in 1999 using various methods, primarily manual control (hand-pulling). Invasive plants occur 

within the analysis area. Herbicide use is a foreseeable action in the Deschutes/Ochoco National 

Forests/Crooked River National Grassland Draft Invasive Plant EIS within the BLT analysis area on the 

portion of Highway 58 between Highway 97 west to Rd 60, a site on Rd 5835 west of the Little 

Deschutes River, and on Rd 5800-017 near the railroad tracks. These are mainly roadside shoulders 

where invasive plants occur. 

As of 2007, surveys and records have not indicated presence of invasive plants that overlap activity 

units within BLT. Prefield review consisted of examining GIS and recent surveys in the analysis area. 

There are 22 occurrences (records or sites) in the Invasives GIS layer documenting the presence of 13 

species of invasive plants within the analysis area. Many of these are concentrated along the Highway 

58 corridor (Draft Invasive Plant EIS Unit 12-04) where a number of BLT project units are located. 

Another concentration of weed species is in the northwest corner of the analysis area along Highway 

61, which is not scheduled for treatment in the Draft EIS, and where there are no BLT project units. 

Another weed site in the Draft EIS (12-21) is located in and adjacent to BLT project unit 875. The 

invasive plant is leafy spurge. Remaining weed sites within the analysis area boundary, whether 

addressed in the Draft EIS or not, do not overlap project activity units. 

The following brief descriptions and general locations of the invasive plants that occur or have potential 

to occur in the BLT analysis area (Figure 3-28) are listed from the R6 Invasive Plant FEIS Appendix B 

(2005): 

Spotted knapweed: Spotted knapweed (Centaurea biebersteinii, CEBI2; formerly named Centaurea 

maculosa) is a biennial or short-lived perennial composite with a stout taproot (Mauer and Russo, 

1991). This species reproduces by seeds, which are dispersed by wind, vehicles, animals, or humans. 

The competitive superiority of this species suggests pre-adaptation to disturbance (Roche et al, 1986 in 

Mauer and Russo, 1991). The initial invasion of spotted knapweed, like other noxious weeds, is 

correlated highly to disturbed areas. Once a plant or colony is established though, it may invade areas 

that are relatively undisturbed or in good condition (Tyser and Key, 1988 and Lacey et al, in Mauer and 

Russo, 1991). 

Spotted knapweed has been found and pulled along Highway 46, the Crescent Cut-off Road and 

Highway 58. 

Diffuse knapweed: Diffuse knapweed (Centaurea diffusa, CEDI3) is a highly competitive herb in the 

sunflower family (Asteraceae). The plants first form low rosettes and may remain in this form for one 

to several years. After they reach a threshold size they will bolt, flower, set seed, and then die. Thus, 

they may behave as annuals, biennials, or short-lived perennials (Carpenter and Murray, 1998a). 

Diffuse knapweed is a highly competitive and aggressive plant that forms dense colonies (Zimmerman, 

1997 in Carpenter and Murray, 1998a). It is especially adept at spreading along rights-of-way and can 
Environmental Impact Statement BLT Project

 Chapter 3 –Invasive Plants 

299

spread rapidly (Allred and Lee, 1996 in Carpenter and Murray, 1998a). Disturbed lands are prime 

candidates for colonization, but diffuse knapweed will also invade undisturbed grasslands, shrublands, 

and riparian communities (Zimmerman, 1997 in Carpenter and Murray, 1998a). 

Diffuse knapweed has been found as isolated plants and hand-pulled along major travelways in the BLT 

analysis area. 

Canada thistle: Canada thistle (Cirsium arvense, CIAR4) is an erect perennial rhizomatous thistle 

distinguished from all other thistles by: 1) creeping horizontal lateral roots; 2) dense clonal growth; and 

3) small dioecious flowerheads (male [staminate] and female [pistillate] flowers on separate plants) 

(Nuzzo, 1997). Canada thistle spreads primarily by vegetative growth of its roots, and secondarily by 

seed (Nuzzo, 1997). Despite its common name, Canada thistle is native to Europe and was apparently 

introduced to North America in the early 17th century. 

Small infestations of Canada thistle are known to occur along the Crescent Cut-Off Road and Highway 

46 in the BLT analysis area. 

Bull thistle: Bull thistle (Cirsium vulgare) is a biennial with a fleshy taproot. It reproduces solely 

from seeds that are dispersed by wind, water, animals, and human activities. Disturbed areas are prime 

habitat for bull thistle to invade (Beck, 1999). On the Deschutes National Forest, bull thistle has been 

sighted, but has not proven to be an aggressive invasive plant. When it occurs on a disturbed site, it 

seems to decrease and disappear when native vegetation regains its pre-disturbance levels (which may 

take many years). In areas that are continually disturbed, such as roadsides, bull thistle may invade and 

persist if not controlled. Due to a combination of limited funds and noxious weed species of higher 

priority, bull thistle has not been always actively pulled on the Deschutes National Forest. 

Small infestations of bull thistle (one to a few plants) are found along the major travelways in the BLT 

analysis area, with larger infestations occurring in some past harvest units, especially in landings and 

skid trails. 

Russian thistle: Russian thistle (Salsola kali) is a summer annual that reproduces by seed. When the 

plant is mature it breaks off at the ground forming “tumbleweeds” that are tossed by the wind, 

scattering seeds. A single plant can produce 100,000 to 200,000 seeds. Seeds are dormant over winter 

allowing the seed to germinate in spring over a wide range of temperatures and with very little 

moisture, generally in late March or early April. Seed viability is short and rapidly declines after two 

years in the soil. A large, spreading root system enables plenty of shoot growth with little moisture 

(Morisawa, 1999). 

Russian thistle is found occasionally when doing manual weed control along the major travelways on 

Crescent Ranger District. 

Dalmatian toadflax and Common toadflax: Dalmatian toadflax (Linaria dalmatica) and common 

toadflax (Linaria vulgaris) are perennial herbs in the figwort family (Scrophulariaceae). Both species 

are classified as weeds in Europe, Russia, Canada, and the United States, and are common throughout 

North America (Carpenter and Murray, 1998b). 

A toadflax plant has from 1-25 vertical, floral stems. These floral stems have thick-walled, woody 

xylem and supporting fibers. Flowers are bright yellow and resemble snapdragons. The taproot may 

penetrate a meter into the soil. Horizontal roots may grow to be several meters long, and can develop 

adventitious buds that may form independent plants (Carpenter and Murray, 1998b). 
BLT Project Environmental Impact Statement 

Chapter 3 – Invasive Plants 

300

Both species are persistent, aggressive invaders capable of forming colonies through adventitious buds 

from creeping root systems. These colonies can push out native grasses and other perennials, thereby 

altering the species composition of natural communities. In North America, both species of toadflax 

are considered strong competitors. They are quick to colonize open sites, and are capable of adapting to 

a wide range of environmental conditions (Carpenter and Murray, 1998b). 

In North America, Linaria dalmatica and Linaria vulgaris primarily occur on sandy or gravely soil on 

roadsides, railroads, pastures cultivated fields, range lands, and clearcuts (Saner et al., 1995 in 

Carpenter and Murray, 1998b). Both species of toadflax reproduce by seed and vegetative propagation, 

and once established, high seed production and the ability for vegetative reproduction allow for rapid 

spread and high persistence (Saner et al., 1995 in Carpenter and Murray, 1998b). Both species of 

toadflax can adapt their growth to fit a range of habitats, and have a tolerance for low temperatures and 

coarse textured soils (Carpenter and Murray, 1998b). Common toadflax and Dalmatian toadflax occur 

mainly along roadsides on Crescent Ranger District. 

Yellow star thistle: Yellow star thistle (Centaurea solstitialis) is a winter annual that depends upon 

seeds for reproduction (DiTomaso, 2001). The seeds are primarily dispersed by birds, however, 

animals, whirlwinds, humans, and vehicles also disperse seeds. It has been noted to invade sites that 

have had recent disturbance. 

In 2003, fewer than 10 yellow star thistle plants were found to occur on two sites on Highway 58 on 

Crescent Ranger District. In 2004, one new site with fewer than 5 plants was found on Highway 58 and 

no plants were seen at the sites found in 2003. In 2005, no yellow star thistle was seen during weed 

control activities on Crescent Ranger District.

St. Johnswort: St. Johnswort (Hypericum perforatum) is a perennial species with a deep penetrating 

taproot. It is commonly referred to as goatweed or Klamath weed. This species can become 

established in degraded or pristine forest or rangelands. Any soil disturbance will decrease competition 

for St. Johnswort and will cause it to increase (Piper, 1999). 

St. Johnswort is common along roadsides on all the major roads on Crescent Ranger District.

Common mullein: Common mullein (Verbascum thapsus) is a biennial, perennial or, rarely, an annual 

with a deep tap root. It grows 5-18 decimeters tall and can produce as many as 180,000 seeds per 

individual plant. Seeds may remain viable for over 100 years. Mullein depends on the presence of bare 

soil to germinate and establish. (Hoshovsky, 1986). Like bull thistle, common mullein has not proven 

to be a particularly aggressive invasive plant and it seems to decrease and disappear when native 

vegetation regains its pre-disturbance levels. 

Common mullein is common in most disturbed sites (road sides, past harvest units, campgrounds, etc.) 

on the Crescent Ranger District. 

Field Bindweed: Field bindweed (Convolulus arvensis) is a persistent, perennial vine of the morningglory family (Convolulaceae) which spreads by rhizomes and seeds. Habitats with little competition, 

repeated disturbance, and high light – such as roadsides – are ideal for growth of field bindweed 

(Lyons, 1998). 

On Crescent Ranger District, field bindweed has been found in small isolated patches on Highway 58 

and the Crescent Cut-off Road. 

Hairy-pod whitetop: Hairy-pod whitetop (Cardaria pubescens) is a hardy perennial with stout, erect 

or procumbent stems that can grow 2 to 5 decimeters tall. Hairy-pod whitetop can be distinguished 
Environmental Impact Statement BLT Project

 Chapter 3 –Invasive Plants 

301

from other weedy whitetop species by the hairy sepals and fruits, which are globose and remain inflated 

when dried. Hairy-pod whitetop can grow in a variety of non-shaded disturbed conditions, including 

roadsides, waste places, fields, gardens, feed lots, watercourses, and along irrigation ditches and is not 

particular about soil type (Hickman, 1995 in Lyons, 1998). Cardaria species are native to southwest 

Asia. 

Hairy-pod whitetop was found along Highway 58 in the vicinity of Odell Butte. 

Cheatgrass: Cheatgrass (Bromus tectorum) is an erect winter- or spring- annual grass. Cheatgrass 

reproduces only from seeds, germinates in the fall or winter, expands its roots, and rapidly exploits the 

available water and nutrients in early spring. Cheatgrass can persist in unpredictable environments 

because seed germination is staggered from August until May (Carpenter and Murray, no date). 

Small infestations of Cheatgrass occur in many places on Crescent Ranger District. Control is difficult. 

Sweetclover: Sweetclovers (Melilotus alba – white-flowered, M. officinalis – yellow-flowered) are 

annual, winter annual, or biennial legumes in the Pea Family (Fabaceae). The sweetclovers were 

introduced from Europe and Asia, becoming common along roadsides and waste areas. Sweetclover is 

often one of the first plants to appear on disturbed sites (Whitson et. al., 1992) 

Sweetclover infestations on Crescent Ranger District occur mainly along Highway 58 where it was a 

contaminant in the seed mix used by fiber optics line contractors for revegetation after installation 

(McMahan, pers. comm.). 

Leafy spurge: Leafy spurge (Euphorbia esula) is a perennial in the family Euphorbiaceae. This three 

feet tall perennial spreads by rootstalks (rhizomes), as well as by seeds. The lower leaves are narrowly 

strap-shaped and about two inches long. The upper leaves, near the flowers, are opposite and broadly 

heart shaped. The yellow floral bracts resemble a set of miniature but stout horns. A noxious weed in 

much of the northern United States and adjacent Canada, this European import invades rangelands as 

well as waste areas. Its massive numbers of seeds and very deep rhizomes make it extremely difficult 

to eradicate (Taylor, 1990). 

There is a leafy spurge site in the analysis area west of the Little Deschutes River along road 5835. This 

is site 12-21 in the 2007 Central Oregon Draft EIS. 

Risk Assessment and Environmental Consequences 

There is a high risk for spreading or introducing noxious weeds for all action alternatives in this 

project. The risk is proportional to the area of ground disturbance and miles of roads used in each 

action alternative. Highest risk is for Alternative B, followed by Alternative C, Alternative D and the 

no action Alternative A. Weeds are already present in the analysis area, particularly along Highways 

58 and 61. 

With regard to invasive plants, the possible consequences associated with any alternative considered in 

this EIS mainly arise from further disturbances within the analysis area. Factors that increase weed risk 

associated with vegetation management projects include: 

1. harvest activities, treatments to reduce fuels, and temporary road construction would increase 

the amount of disturbed, open ground available for infestation by invasive plants, and 

2. increased activity and traffic would heighten the chance for the introduction and/or spread of 

invasive plant seeds and propagules by vehicles, equipment, and personnel. 
BLT Project Environmental Impact Statement 

Chapter 3 – Invasive Plants 

302

Project Design Features (Chapter 2) are designed to reduce the risk of the introduction and/or spread of 

invasive plants. However, in projects such as this, where numerous invasive plant sites exist both 

within and adjacent to the analysis area, any action alternative will unavoidably be associated with an 

increased potential for the introduction and/or spread of invasive plants (see Figure 3-28 for locations of 

invasive species in proximity to activity units). Invasive plant risk can largely be equated with the 

number of acres of proposed harvest. For example, an alternative proposing conventional ground-based 

harvest on 1000 acres can be reasonably expected to pose a considerably greater risk than an alternative 

proposing conventional ground-based harvest on 500 acres. Specifically, acres of ground-disturbing 

activities associated with harvest and post harvest plus road management including miles of temporary 

road construction, commercial hauling, road maintenance, and reopening roads would be used to assess 

and compare invasive plant risks between alternatives. 

Prevention: All projects that propose ground-disturbing activities would have appropriate Project 

Design Features (PDFs) to lessen the risk. The PDFs are taken from the national Guide to Noxious

Weed Prevention Practices (USDA Forest Service, 2001), the Region 6 Invasive Plant EIS, and the 

Deschutes and Ochoco National Forests and Crooked River National Grassland Invasive Plant 

Prevention Guidelines. Project Design Features have been shown to be effective in reducing the risk of 

the introduction and spread of invasive plants. Prevention would be emphasized as the preferred 

strategy for invasive plant management by adhering to the Regional Standards and central Oregon 

prevention guidelines. The following Region 6 Invasive Plant Final Environmental Impact Statement 

(FEIS) Record of Decision (ROD) (USDA Forest Service, 2005) adopted Standards and Guidelines: 

Standards in the R6 Invasive Plant FEIS that apply to the BLT project are: 

1. Prevention of invasive plant introduction, establishment and spread will be addressed in ... 

vegetation management plans.... R6 Standard #1

2. Actions conducted or authorized by written permit (contracts) that operate outside the limits of 

the road prism, require cleaning of all heavy equipment (i.e., bulldozers, skidders, other 

logging equipment) prior to entering National Forest System Lands. R6 Standard #2 

3. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants 

before use and transport. (Gravel or other material used in road maintenance and 

construction/reconstruction associated with the project.) R6 Standard #7

4. Conduct road blading, brushing and ditch cleaning in areas with high concentrations of 

invasive plants in consultation with District or Forest-level invasive plant specialists, 

incorporate invasive plant prevention practices as appropriate (road maintenance and reopening roads). R6 Standard #8

The Project Design Features for the BLT Project are: 

1. Noxious weed risk assessment and management will be considered in all NEPA planning 

activities where soil disturbance or invasive plant introduction or spread could result from the 

activity. Prevention will be emphasized as the preferred strategy for invasive plant 

management. Requirement R6 Standard #1.

2. Remove mud, dirt, and plant parts from all heavy equipment that will operate outside the limits 

of the road prism prior to entering NFS lands AND before moving into a new or different 

analysis area. Cleaning must occur in areas where removed weed seeds will not create 

additional problems. Requirement R6 Standard #2.

3. Require all Forest Service employees to inspect, remove, and properly dispose of weed seed 

and plant parts found on their clothing and personal equipment prior to leaving a project site 

infested with weeds. Guideline

4. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants 

before use and transport. Treat or require treatment of infested sources before any use of pit 
Environmental Impact Statement BLT Project

 Chapter 3 –Invasive Plants 

303

material. Use only gravel, fill, sand, and rock that are judged to be weed free by District or 

Forest weed specialists. Requirement R6 Standard #7

5. Environmental analysis for any and all ground-disturbing projects will evaluate weed risk and 

consider weed prevention in the development and evaluation of alternatives and mitigating 

measures. Silvicultural prescriptions, logging plans, road management, and other activities 

will include weed prevention measures (e.g., shade retention and minimal soil disturbance). 

Prevention will be emphasized as the preferred strategy for invasive plant management. 

Guideline

RISK RANKING

Factors considered in determining the level of risk for the introduction or spread of invasive plants 

in the BLT project is high because a combination of the following three factors: 

1. Known weeds in/adjacent to analysis area; 

2. Four vectors are present including heavy equipment (implied soil disturbance); importing of 

soil, cinder or gravel for road maintenance; recreation in the area, and Forest Service project 

vehicles. 

3. Project operation in/adjacent to weed populations. 

Direct and Indirect Effects 

Risk Assessment 

The risk of the introduction and spread of invasive plants for all alternatives from highest to lowest is B, 

C, D, and A (Table 3-89). The assessment of the risk of the introduction and spread of invasive plants 

associated with activities proposed in the alternatives is based on the amount of ground disturbance that 

would occur for each alternative. Higher numbers of acres proposed in each alternative for commercial 

harvest and fuels reduction treatments would increase the risk of introducing or spreading invasive 

plants. The higher the number of miles of temporary road construction, road maintenance, and 

commercial haul routes, the higher the risk. The risk from road obliteration activities and road reopening and closing is included in this analysis. 

The total acreages of treatments are greater for Alternative B than for Alternative C. Alternative D has 

the least acreage. Total miles of road maintenance, re-opening closed roads, and commercial haul 

routes are greater for Alternative B than for Alternative C. Temporary road construction is greater for 

Alternative B than for Alternative C. Alternative D has the least miles in temporary and re-opened 

roads, road maintenance and commercial haul routes. 

Alternative B poses the highest risk for invasive plant introduction and spread based on the greater 

number of acres of ground-disturbance and the greater number of miles of road maintenance, reopening closed roads, temporary roads and commercial haul routes, which would potentially cause the 

greatest soil disturbance. 

Alternative C poses the next highest risk with a fewer number of acres of ground-disturbance from 

commercial harvest, fuels treatments, and fewer miles of road management activities. 

Alternative D poses the third highest risk with the fewest acres of ground disturbance and fewest miles 

of roads and road maintenance of the action alternatives. 

Alternative A, the No Action Alternative, poses the least risk of the introduction and spread of invasive 

plants when compared to the action alternatives. No commercial harvest, fuels reduction activities, or 

road management are proposed in this alternative, therefore there would be no additional grounddisturbance above existing levels of custodial and recreational activities. 
BLT Project Environmental Impact Statement 

Chapter 3 – Invasive Plants 

304

Table 3-89. Risk Rating for Invasive Plants by Alternative 

Action Alt. A Alt. B Alt. C Alt. D 

Commercial Harvest and 

potentially ground-disturbing 

activities (acres) 

0 7,499 5,771 2,616 

Prescribed Underburning 0 2,312 1,764 824 

Grapple Piling 0 6,666 5,027 2,227 

Handpiling and disposal in 

commercial harvest units 0 420 410 77 

Road Management 

Temp. road construction 

(miles) 

Commercial Hauling (miles) 

Road maintenance (miles) 

Re-open roads (miles) 

0 

0 

0 

0 

9.7 

160 

150 

22 

8.7 

126 

116 

17 

4.7 

76 

66 

11 

Comparative Ranking of 

Risk 

(1 = lowest) 

1 4 3 2 

Cumulative Effects 

Table 3-1 was reviewed for foreseeable actions that are ground disturbing and have potential to 

contribute to an incremental effect combined with the BLT project. None of these projects have a 

geographical zone of influence that overlaps. All past and present activities, including past timber 

sales, have been accounted for in the existing condition because that is the most informative way to 

display effects to the public and Responsible Official. The origin of most invasive plants in the analysis 

area can be found along most major highways, and the Crescent Ranger District has successfully 

managed a prevention program through monitoring and rapid response through handpulling. There is 

no indication the BLT project and additive effects from past, present and foreseeable actions would 

change this success. 

Noxious weed inventory and treatment has been occurring on the Deschutes National Forest including 

the analysis area in past years. Accurate documentation of noxious weed sites began in the early 1990s. 

Since the Deschutes National Forest Noxious Weed Control Environmental Assessment was approved 

and implemented in 1998, it has been very effective in reducing density of invasive plants on many 

sites, particularly along Highway 97. 

The Deschutes and Ochoco National Forests are in the process of finalizing a site-specific 

Environmental Impact Statement for Invasive Plants in central Oregon. This document will be tiered to 

the Region 6 Invasive Plant Final Environmental Impact Statement, and proposes to control invasive 

plants across Deschutes and Ochoco National Forests and Crooked River Grassland on approximately 

15,000 acres. Once this is implemented, it is expected to have a very positive effect by lowering the 

potential of new invasive plant populations invading the BLT area. 

Access to all forms of recreation, including Off Highway Vehicle use has potential for an additive 

effect, although there is relatively low use on the Crescent Ranger District (and the BLT analysis area) 

compared to areas closer to more populated areas. However, the implementation of the Travel 

Management Rule expected in 2009 would further reduce this risk by limiting motor vehicles to 

designated routes with no off-trail travel. 
Environmental Impact Statement BLT Project

 Chapter 3 – Special Concern Plants

305

Special Concern Plants _______________________________ 

Matsutake (Tricholoma magnivelare) mushrooms and Allotropa 

virgata (candy stick). 

Background 

The American matsutake mushroom is a valuable commercial non-timber forest product on the 

Crescent Ranger District, from both an economic and social perspective. Annual matsutake harvest 

values may exceed the value of the annual timber growth (Amaranthus et al., 1998). The large and well 

organized matsutake harvesting community comes from diverse geographic locations to the Oregon 

Cascades. The Crescent Ranger District on the Deschutes National Forest, Chemult Ranger District on 

the Winema National Forest, and the Diamond Lake Ranger District on the Umpqua National Forest, 

has some of the most productive matsutake habitat (Pilz et al., 1996a; Amaranthus et al., 1998; Pilz et 

al., 1999). Harvesters are vocal in their concerns that ground disturbance or tree thinning activities that 

open canopy could reduce either matsutake habitat or productivity. Allotropa virgata (candystick) is 

associated with matsutake mushrooms and considered an indicator of potential matsutake habitat. Both 

the mushroom and the plant are found within the BLT analysis area and within activity units. 

Matsutake mushrooms are the fruiting bodies (sporocarps) of the ectomycorrhizal fungus Tricholoma 

magnivelare. [Hereafter, mushroom, sporocarp and fruiting body will be used interchangeably.] The 

fungal mycelia are persistent below ground while the mushrooms only appear for a limited seasonal 

period, and do not necessarily reappear at all sites in all years. The fruiting bodies usually cluster in an 

arc known as a shiro that is the front of the growing mycelial mat (Hosford et al., 1997). Allotropa 

virgata is a perennial and forms mycorrhizal associations with fungi to obtain nutrients. It is considered 

to have a specific association with matsutake (Bidartondo and Bruns, 2001; LeFevre 2002). Aboveground stalks are persistent and visible when fungal mycelia and fruiting bodies are not, making it a 

suitable indicator of presence of matsutake mycelia and potential for mushrooms. 

Habitat 

Both matsutake and Allotropa grow in a variety of habitats and plant associations in the Pacific 

Northwest. In the Southern Oregon Cascades, highly productive matsutake sites occur in mixed conifer 

and pine habitat between 4430 (1350) and 6560 (2000) feet (m) elevation. Habitat types include mixed 

conifer/snowbrush-manzanita (with a component of noble fir), lodgepole pine/bitterbrush/needlegrass 

(60-120 year-old trees) and lodgepole pine/manzanita (Hosford et al., 1997). Matsutake form 

mycorrhizal connections to Douglas-fir, silver fir, Shasta red and noble firs, mountain hemlock, sugar 

pine, lodgepole pine and ponderosa pine. Shasta red and noble firs are considered a preferred host for 

matsutake (Pilz et al., 1999). Understories are generally sparse where matsutake are found, although 

there may be a good deal of buried decaying wood which serves as a moisture reservoir. Soils are 

generally well-drained sands to sandy loams with a duff layer of 2-12 centimeters. Literature suggests 

suggest that a tree canopy cover of 70 percent maintains mycorrhizal hosts for Allotropa, (Dimling, 

1997b cited in Wogen and Lippert, 1998). 

Personal communication with Luoma (2008) suggested an old growth Douglas-fir stand with 85 percent 

canopy cover contained the most robust population he has studied. While the largest populations occur 

in late- and old-structured stands, Allotropa is not restricted to these older stands. It has been observed 

in 60 year old stands of 11 centimeter-diameter trees. 

Site-specific surveys on the Crescent Ranger District suggest canopies closed more than 70 percent or 

less than 40 percent may not be optimal for matsutake production (as indicated by presence of 

Allotropa, although the literature suggests those ranges to be between 50 and 90 percent due to reduced 
BLT Project Environmental Impact Statement 

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carbon flow to the mycorrhizae and sub-optimal temperature and moisture regimes (Hosford et al., 

1997; Luoma et al., 2004; Luoma and Eberhart, 2005; Luoma et al., 2006a). Satellite data for the plots 

(points) where matsutake mushrooms were found or suspected in the BLT analysis area shows 53 

percent of the points were located in canopies of 25-40 percent; 32 percent of the points in canopies of 

40-55 percent; 13 percent of the points in canopies of 55-70 percent; and less than 1 percent in canopies 

closed more than 70 percent. It is thought matsutake may have increased sporocarp production in more 

open canopies due to increased temperature on the forest floor in some cases; reduction or thinning of 

the litter layer to warm soil may also enhance sporocarp production as shown in Japanese matsutake, 

although mulching may improve production on bare mineral soil (Hosford et al. 1997). 

Management implications 

Natural climatic and disturbance events and forest management practices can affect both matsutake 

mycelia abundance and sporocarp production. Fire and weather related soil disturbances can reduce 

both mycelial and sporocarp production (Smith et al., 2004), while timing of first frosts, autumn 

moisture and seasonal snowfall affect sporocarp production (Pilz et al., 1999). It is also thought that a 

warming climate may benefit the ectomycorrhizal fungus, as it is drought tolerant (personal 

communication, Luoma). 

Forest management practices may enhance or reduce sporocarp production, while some ground 

disturbance related to treatments affects not only sporocarp production but can also disturb mycelial 

mats and reduce mycorrhizal connectivity (Kropp and Albee, 1996; Pilz et al., 1999; Luoma et al., 

2006). Reduced mycorrhizal connectivity would have detrimental effects on the host trees as well as on 

matsutake. Management efforts may be designed to favor matsutake or conifer production 

(Amaranthus et al., 1998; Pilz et al., 1999). Improved tree growth, in turn, is hypothesized to favor 

matsutake mushroom production by supplying finer root sites for mycorrhizae-mediated carbohydrate 

supplies to matsutake mushroom mycelia (Weigand, 1998). In Japan, pine forests are managed for 

matsutake production. With 40-50 year old trees the optimal age, thinning and ground clearing to warm 

and dry the well-drained soils of the forest floor enhance the development of shiros and mycorrhizal 

connection with host trees. Other techniques lower soil temperature and increase surface humidity to 

enhance sporocarp production (Hosford et al., 1997). Much less is known about management to 

improve production of American matsutake, although some work is being done to understand how 

timber management activities affect matsutake production, and what treatments might improve that 

production. 

In the Oregon Cascades, experiments have been conducted that examine economic feasibility of 

managing for mushrooms and conifers in high altitude forests (Amaranthus et al., 1998; Weigand 1998; 

Pilz et al., 1999). Clear cutting, thinning and various dispersal patterns of understory tree retention can 

affect mycorrhizal diversity, mycorrhizal connections to host species, and below ground competition 

(Kropp and Albee, 1996; Luoma et al., 2004; Luoma and Eberhart, 2005; Durall et al., 2006). In stands 

of old noble fir with dense thickets of understory conifers (generally lodgepole pine), the noble firs can 

be “killed from below”; the entire stand may be vulnerable to stand replacing wildfire events, and 

subsequent poor matsutake sporocarp production (Amaranthus et al., 1998; Pilz et al., 1999). Thinning 

can open the canopy, reduce fuel loading and reduce competitive stress on older trees. This can result 

in new root tip growth with increased tree vigor, and increased mycelial growth. In one study removing 

trees to 15, 40 and 75 percent of the basal area, and either aggregating retained trees in blocks or 

dispersing throughout units affected sporocarp production and ectomycorrhizal fungi diversity (Luoma 

et al., 2004; Luoma and Eberhart, 2005; Luoma et al. 2006b). Live tree retention of 40 percent basal 

area or less, whether aggregated or dispersed, resulted in lower EMF diversity and sporocarp 

production. The reduced diversity and productivity may be due to decreased mycorrhizal connectivity 

with host tree species. It may take many years for sporocarp production to recover. Clearcuts may take 

as many as thirty years to resume fruiting (Ogawa, 1982, in Amaranthus et al., 2000). Even after 
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thinning to as much as 40-50 percent canopy cover, sporocarp production may take several years to 

reach pretreatment production levels (Luoma et al., 2004). 

Soil disturbances can also affect matsutake production. Matsutake harvest methods such as raking to 

uncover sporocarps disturb the mycelia in the fruiting shiro and the mycorrhizal connections with host 

roots (Luoma et al., 2006a), and result in reduced sporocarp production. This may be extrapolated to 

activity related soil disturbances such as temporary roads and skid trails, where the soil surface has been 

altered and the mycelia fragmented (Rick Abbott, Silviculturist, Umpqua National Forest, personal 

communication). Disturbance and compaction associated with road building and skid trails may disrupt 

mycorrhizal connectivity (Amaranthus et al., 2006; Colgan et al, 1999); subsequent subsoiling to break 

up the compaction may eventually enhance host plant root growth and mycorrhizal connection (Luoma, 

unpublished report, Diamond Lake Ranger District, 2007) or may initially disturb the mycorrhizal 

network (Abbott, p.c.). 

Mushrooms and Fire 

Pile burning or higher severity burning can damage the mycorrhizae and mycelia that lie near the soil 

surface (Weigand, 1998). Important information about matsutake mushroom ecology and the ability of 

matsutake mushrooms to recolonize burned sites can be found where slash residue from harvests in the 

matsutake mushroom management area has been piled and burned. Taken together, the sites furnish a 

database for analyzing and developing disturbance response to fire (Weigand, 1998). 

Prescribed fire or natural fire both influences ectomycorrhizal community dynamics and succession in 

coniferous forests to varying degrees depending on intensity and the length of time since fire (Visser 

1995; Jonsson et al. 1999; Dahlberg et al. 2001; Horton and Bruns 2001). 

Fires of low intensity that leave the organic soil horizons (functionally equivalent to duff) relatively 

undamaged do not appear to substantially alter ectomycorrhizal community composition (Jonsson et al. 

1999; Bishop 2008), whereas fires of high intensity that remove the organic layer and detrimentally 

burn the mineral soil significantly affect ectomycorrhizal community composition (Visser 1995; Baar et 

al. 1999; Grogan et al. 2000; Dahlberg et al. 2001; Bishop 2008). Aboveground ecosystem recovery 

after fire is directly linked to the survival of ectomycorrhizal fungi (Perry et al. 1989) that reside mostly 

in the surface layers of mineral soil and organic matter (Harvey et al. 1986; Swezy and Agee 1991). 

Prefield Review and Existing Condition 

Allotropa virgata was surveyed in 2003. Matsutake sites were also documented in a separate survey 

(again, by presence of A. virgata: Andy Moore, 2007, personal communication) by employing a 

regional expert in matsutake mushrooms. Both surveys include GIS coverage showing A. virgata

locations. Additional ‘sites’ (units) were identified by harvesters starting in 2004 as important picking 

areas. From surveys, best available science, and personal communication with harvesters, potential 

habitat was determined. 

Quantifying Matsutake Habitat and Production 

Habitat was quantified based on the best available science and site-specific conditions where suspected 

or actual matsutake presence is within the analysis area. It is assumed that ground disturbance and 

opening the canopy below 25 percent in some Plant Association Groups would reduce quality habitat 

and mushroom production, at least in the short-term. Habitat and mushroom production would be 

reduced approximately proportionate to the area of proposed activity relative to the entire analysis area. 

In some cases, active management might actually enhance mushroom production, if not immediately, 

then in the near future. Conservatively, there might be a reduction in mushroom production for 2 to 6 

years, or up to 10 years in severely disturbed drier sites. Based on silvicultural projections, there would 

be little or no loss of habitat from implementation of the action alternatives by 10 years post-treatment. 
BLT Project Environmental Impact Statement 

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In addition to knowing what habitat matsutake thrives in and how different disturbances and 

silvicultural practices affect matsutake production, it is desirable to be able to quantify appropriate 

habitat for matsutake. It is important to understand the distinction between matsutake mushroom and 

the growth and persistence of the fungus in the soil. Because of the wide habitat range of matsutake, 

and the various conditions that optimal fruiting are found in, it seems likely that there is more matsutake 

habitat than is evident by harvester’s comments or presence of Allotropa or matsutake mushrooms. As 

forest structure changes through time, evident production of matsutake mushrooms should vary in 

density and location over the landscape. Information on specific requirements and ranges of optimum 

environmental conditions for matsutake is limited and varies with geographic location. In addition to 

literature cited in this document, there is a great deal of anecdotal information from harvesters that 

helps to characterize matsutake habitat, although their information usually refers to sporocarp 

production, and not strictly organism habitat. 

Defining matsutake habitat in the BLT analysis area uses information on mushroom production 

provided by harvesters as well as surveys by agency personnel and contractors to locate Allotropa 

virgata indicating the presence of matsutake. The harvesters rated the quality of the habitat by amount 

of sporocarp production, and identified those units on a map. The surveyors noted the presence of 

Allotropa (or matsutake if present), indicating presence of mycelia, but not necessarily indicating 

fruiting bodies, or any sense of quantity of potential mushroom production. Presence was recorded as 

points on a map. These unit polygons and points can be analyzed in GIS using existing datasets that 

contain attributes such as canopy closure class, plant association (and plant association group), stand 

size structure, and dominant species. Applying this habitat information, the points and polygons can be 

used to verify the range of conditions considered appropriate matsutake habitat. 

Analysis can then be applied to other map units (project boundaries, treatment units, other ownerships) 

to identify them as habitat if they contain the suite of attributes in suitable range of values. Canopy 

cover classes were equated to basal area. The GIS datasets used for canopy closure class, stand 

structure class, plant association (group) and species are raster datasets with 25x25 meter pixel size, 

generated from LANDSAT TM satellite images provided under contract to the Forest Service by 

Spatial Solutions in 2004 (Mike Simpson, Deschutes and Ochoco National Forests Ecologist, personal 

communication). All timber sales, fuel reduction activities, natural disturbance events such as wildfire, 

and vegetation activities on private lands within the BLT analysis area were included in this 

information. All activities that occurred after 2004 and their potential incremental effects within the 

BLT area are discussed further in the cumulative section. 

Assessing the effects of any of the treatment alternatives on matsutake fungus abundance and 

mushroom production is difficult and speculative because of the lack of direct evidence of current 

fungal abundance and mushroom production potential. Estimates of potential habitat for the matsutake 

mushroom used Viable Ecosystem (Forested Vegetation, Chapter 3). The categories used in the Viable 

analysis differ somewhat from those used in the matsutake habitat analysis, however, alternative 

differences across the analysis area should adequately reflect effects to matsutake habitat. This is not 

meant to be a discussion of all forested land changes through seral stages, but a comparison of 

matsutake habitat for the different alternatives in the analysis area. 

Ideal matsutake and Allotropa habitat might be characterized as between 50 to 85 percent crown closure 

(Hosford et al., 1997; Luoma et al., 2004; Luoma and Eberhart, 2005, Luoma et al. 2006a), and 

mushroom harvesters prefer that units not be thinned too extensively. The satellite data for the points in 

the surveys show 53 percent of the points located in canopy cover class of 25-40 percent, 32 percent of 

the points in canopy cover class of 40-55 percent, 13 percent of the points in canopy cover class of 55-

70 percent, and less than 1 percent in canopy cover class more than 70 percent. A caveat of using these 

crown cover classes is that it is unclear what the actual percent cover class of the 53 percent of points 

within the 25-40 percent range. The ecological difference between 25 and 40 percent cover class may 
Environmental Impact Statement BLT Project

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309

be considerable for matsutake (Luoma et al., 2004). Forty-nine percent of the points were in the dry 

lodgepole pine habitat types (plant association groups or PAGs), 14 and 17 percent in the dry and moist 

mixed conifer habitat types (respectively) and 14 and 3 percent (respectively) in the dry and moist 

ponderosa pine habitat types. Most of the points were located in pole (48 percent) small (22 percent) 

and medium (17 percent) sized timber classes. 

Using this data and cited soil characteristic of sandy to sandy loam well drained soils, current and 

potential habitat in the alternatives and the general analysis area was quantified using the following 

parameters and values. 

Three categories of potential matsutake habitat were developed and analyzed using plant association 

group (PAG) combinations, crown closure class and structure/size classes. Potential habitat is assumed 

to be capable of supporting current matsutake populations, or potentially within 5-10 years. The three 

categories are “Thin to Quality Habitat” (Thin), “Good Quality Habitat” (Good), and “Grow to Quality 

Habitat” (Grow), based on aggregated attributes of crown cover class and size/structure class. PAGs 

included lodgepole pine moist and dry, ponderosa pine moist and dry, mixed conifer moist and dry. 

Wet conifer types, were excluded presuming the soil is not well enough drained to provide optimum 

habitat, regardless of structure or canopy closure. Seedling-sapling and sapling-pole size/structure 

classes were excluded from potential habitat in the short term. Optimal canopy cover classes for 

“Good” habitat ranged from 25-70 percent across the small (10-15 inches), medium (15-20 inches) and 

larger size/structure classes. In the pole size class (5-10 inches), 25-40 percent canopy cover was 

placed in the “Grow” category, 40-55 percent canopy cover in the “Good” category, and 55-70 percent 

canopy cover in the “Thin” category. Canopy cover in the 10-25 percent was placed in the “Grow” to 

quality category across all pole and larger size classes, while canopy cover greater than 70 percent was 

placed in the “Thin” category for all pole and larger size classes. Analysis was then applied using total 

acres in Alternatives B, C and D, as well as for the entire BLT analysis area. 

A note of caution must be inserted for interpreting this analysis. This is a model based on assumptions 

derived from a synthesis of the literature and anecdotal evidence from harvesters, and applied to 

modeled and reclassified raster data. It does not take into account below ground interspecific 

competition, actual tree species composition in the stands, or distribution of soil and hydrologic 

characteristics. It also does not imply that matsutake necessarily would occur in areas that are modeled 

as potential habitat, or does not occur in areas not considered habitat. Additionally, estimates of 

potential habitat cannot be extrapolated to estimates of potential matsutake production. Results would 

be discussed in terms of approximate acreages. Reported percentages are percentage of acres analyzed 

for the entire BLT analysis area and individually for each alternative. 

Based on this interpretation of the raster data, the BLT planning area currently contains approximately 

54,122 acres (71 percent) of potential matsutake habitat. As a subset of potential habitat, 39,325 acres 

(51 percent) is currently “Good” habitat, 12,837 acres (17 percent) can “Grow” to good habitat, and 

1960 acres (3 percent) can be “Thinned” to good habitat. Most of the current potential is in the dry 

lodgepole pine, ponderosa pine and mixed conifer habitat types (22, 9 and 11 percent respectively, of 

acreage in analysis). Ten percent of the analysis area is in dry lodgepole pine that can “Grow” to good 

habitat, 3.4 percent is in dry ponderosa pine and 1.6 percent is in dry mixed conifer. Most of the 

acreage that can be “Thinned” to good habitat is in the dry (1.7 percent) and moist (0.4 percent) mixed 

conifer and dry (0.4 percent) lodgepole pine habitat type. 
BLT Project Environmental Impact Statement 

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Table 3-90. BLT Analysis Area Matsutake Potential Habitat by Plant Association Group 

Plant Association 

Group (Habitat Type) Grow Good Thin 

Acres Percent Acres Percent Acres Percent 

Lodgepole pine dry 7530 9.8% 16,745 21.9% 216 0.3% 

Lodgepole pine moist 78 0.1% 186 0.2% 2 0.0% 

Ponderosa pine dry 2614 3.4% 7,075 9.3% 83 0.1% 

Ponderosa pine moist 452 0.6% 1,903 2.5% 10 0.1% 

Mixed conifer dry 1210 1.6% 8,755 11.4% 1319 1.7% 

Mixed conifer moist 953 1.4% 4,662 6.1% 329 0.4% 

Direct and Indirect Effects 

Alternative A 

In this alternative, no active management would occur except for custodial activities such as fire 

suppression and ongoing prescribed burning in stands classified as Fire Regime 1 (frequent fire 

interval) on 800 acres within the analysis area. The 10-year effects of a passive management scenario 

treatment may increase or enhance potential matsutake habitat in terms of desired canopy closure and 

size classes among PAGS. However, that may be offset by increased litter depth and woody debris on 

the ground which may reduce matsutake mushroom production, as well as increase the potential for 

wildfire which could reduce both matsutake habitat and mushroom production. Also, in terms of a 

sustainable harvest, this alternative would have the greatest risk for a disturbance event that could 

potentially remove large blocks of habitat. 

Viable Ecosystems modeling over 10 years shows dry lodgepole pine increases in all seral/size/canopy 

(lodgepole only has late seral state in this analysis) classes except late open pole, which is marginal 

habitat. This may enhance or increase potential matsutake habitat. 

In dry ponderosa pine, acreage increases in the closed canopy larger size classes, and is reduced in the 

smaller (pole) size classes. Moist ponderosa pine acreage generally increases in the larger closed 

canopy classes, while acres in early- and mid-seral pole size are reduced. Both of these conditions have 

the potential to enhance or increase potential matsutake habitat. 

In dry mixed conifer, this PAG presents a more complex representation. There are fewer acres of midand late-seral in pole and larger size classes except for the largest closed canopy category which 

increased as did most of the early seral larger size classes. Early seral stages may indicate pine 

dominance and all stages may have some presence of red fir, but the data does not break this out by 

individual species. Some indications are that presence of red fir might indicate a more likely presence 

of matsutake. This may enhance or increase potential matsutake habitat unless the shift is to early-seral 

condition consisting of shrub land or seedling-sapling. Either of those would trend away from 

matsutake mushroom production, or matsutake habitat in the case of shrubs, regardless of host tree 

species dominance. 

Effects Common to All Action Alternatives 

Opening the overstory, by stand thinning and by selecting species with naturally more open canopies, 

permits stronger pulses of solar energy and water to reach upper soil layers at the time of matsutake 

mushroom fruiting. Thinning trees and pruning branches both reduce leaf area index, although the 

intensity of control differs with each practice. Thinning reduces drought stress and concentrates 

biomass on trees having the best prospects for financial returns or on trees promoting the best 

environment for matsutake mushrooms (Weigand, 1998). Post-treatment effects on matsutake habitat 

and mushroom production would likely reduce mushroom production immediately following treatment 

proportionately to the acres of active management in Alternatives B, C, and D. Matsutake production 

recovery might occur as soon as 2 years or as many as 6 years or more following treatment depending 
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311

on PAG and original quality of habitat. Ten years following activity, there is little difference between 

any of the alternatives and modeled results for Alternative A across all PAGs, seral stages, canopy, or 

size classes. This indicates a high degree of similarity between all alternatives for potential matsutake 

habitat and mushroom production. 

Specific modeling results show a shift from closed to open canopy in dry lodgepole pine in all size 

classes pole and larger (approx. 670 acres for Alt. B, 461 acres for Alt. C., and 209 acres for Alt. D). 

The most dramatic shift was in the pole size class (473, 322 and 144 acres for alternatives B, C, and D, 

respectively). Immediately following activity, this may reduce matsutake habitat and mushroom 

production due to the reduction in host trees, as well as the potential disruption of the mycorrhizal 

network by soil disturbance and compaction. In the longer term (2-6 yrs), this may enhance habitat 

through new mycorrhizal root tip growth and increased tree vigor. Modeling 10-years post activity 

shows a slight shift in acres of closed to open canopy in pole and larger size classes only for 

Alternatives B and C. Alternative D shows no difference from modeled results of Alternative A. Ten 

years after treatment there is virtually no difference between alternatives in potential matsutake habitat 

in this type. 

Little change is detected in early or late seral dry ponderosa pine. For Alternatives B, C, and D, 

opening of the canopy in mid-seral larger size classes (M4a and M5a), reduces potential matsutake 

habitat by 290, 244, and 66 acres (respectively). That potential habitat may have been marginal 

anyway, as canopy is considered closed in this type at 25 percent. Opening the canopy could possibly 

reduce active mycorrhizal connections, as might soil disturbance and compaction as a result of active 

management. Recovery to pre-treatment levels could take as long as 6-10 years or more. Modeling 10-

years post activity shows a small change from closed to open canopies in the mid-seral larger size 

classes for dry ponderosa pine for all alternatives compared to modeled results for Alternative A (261, 

120 and 60 acres for alts B, C, and D, respectively). This may indicate some loss of potential matsutake 

habitat or mushroom production, although the lost acreage may be marginal habitat. 

In moist ponderosa pine type, a slight shift from closed to open canopy occurs across all seral and size 

classes. Even that shift may not indicate a reduction in matsutake habitat as the threshold from open to 

closed canopy is 40 percent. There is little difference between alternatives B, C or D. Matsutake 

habitat and mushroom production may be reduced in the very short term due to reduced mycorrhizal 

connectivity and soil disturbance. Recovery and enhancement may occur in 2-6 years with expansion 

of mycorrhizal root tips and increased host tree vigor. In 10-years post- activity, there is virtually no 

difference between alternatives. 

In dry mixed conifer as in ponderosa pine, slight shifts from closed to open canopy occur. The 

noticeable changes are in the larger (greater than 10 inch in diameter) mid and late seral categories, 

where alternatives B and C have an equal departure from Alternative A. Alternative D shows no 

departure. In the dry and moist mixed conifer the threshold from open to closed canopy is 55 percent. 

Depending on how much the canopy is actually reduced, much of the open canopy may remain good 

potential matsutake habitat. Immediate short term reduction in matsutake production may occur with 

disruption to the mycorrhizal network due to activity related soil disturbance and reduction in 

mycorrhizal root tips with loss of host trees. Matsutake production could improve within 2-6 years as 

mycorrhizal root tips expand and with increased host tree vigor. 

In moist mixed conifer, also very slight shifts away from closed canopy occurred across seral and size 

classes (about 52 acres for alternatives B and C, and 17 acres for alternative D). As the threshold 

between open and closed canopy is also 55 percent, similar immediate and short term effects are 

probable for this type as for the dry mixed conifer. Both dry and moist mixed conifer types showed 

little difference between alternatives at 10 years post-activity. Slightly more open canopy for mid and 

late seral larger size classes for alternatives B, C and D than for Alternative A do not necessarily 
BLT Project Environmental Impact Statement 

Chapter 3 – Special Concern Plants 

312

indicate a reduction in potential matsutake habitat or mushroom production. The threshold between 

open and closed canopy is 55 percent, and the shift may actually be beneficial to mushroom production. 

Measures have been incorporated into the design of all action alternatives (Chapter 2) to limit soil 

disturbance. Where matsutake are present or suspected tractor skidding and mechanized felling on 

frozen ground or sufficient snow depth as determined by the Forest Service except for units 770 and 

785 which overlap the Beales Butte groomed snowmobile trail. In addition, all post sale fuels reduction 

and related activities post-harvest cannot add to detrimental soil conditions, limiting mechanical 

equipment to existing skid trails. 

Prescribed fire may be used, although care must be exercised that the organic layer where the mycelium 

and mycorrhizal roots reside not be consumed or the fungus heat-killed. Another Project Design 

Feature specifies slash disposal using prescribed fire to be accomplished during the cool and moist 

seasons of spring and fall. Pile burning in bare areas such as skid trails and low intensity broadcast 

burns would probably not harm habitat. Although one study (Smith et al., 2004) found spring burns less 

damaging to ectomycorrhizal fungi, local botanists express concern that spring burns move less rapidly 

through a treatment area, allowing the ground to heat up and kill below ground plant parts. Fall burns 

that move rapidly through a treatment area may burn less intensely. To address this, prescribed burning 

would be accomplished in a mosaic pattern with unburned areas within the burn, in addition to 

unburned designated leave areas. No underburning or broadcast burning would take place in early-seral 

or mid-seral mixed conifer stands, and lodgepole pine habitat types other than minor creeping from 

burning piles. 

Measures designed to protect soil quality and limiting detrimental disturbance have demonstrated 

success on numerous projects, including Tums Timber Sale. Also, prescribed burning in the past has 

been accomplished during cool and moist periods with low-intensity fire, where mushroom harvest has 

been maintained or enhanced mushroom production (TMP, Railroad/Rimrose). 

Alternative B 

Using the ranges for canopy cover class by plant association group where potential matsutake 

production occurs, Alternative B would have an approximate 1,120 acre net shift toward less productive 

habitat. Fuels reduction/maintenance activities (prescriptive fire) on additional 2,312 acres can reduce 

the organic layer and potentially enhance mushroom productivity depending on the method and timing 

of the treatment. Anecdotal evidence for dry ponderosa pine units (TMP, Railroad/Rimrose) supports 

this assumption (Jeff Bishop, former mushroom harvester, personal communication). Conversely, 

intense fire, either natural or prescribed, can reduce matsutake habitat and mushroom production. 

Alternative B could be considered the most active alternative focused on the long-term as it relates to 

reducing risk of a wide-scale disturbance event that could remove large blocks of habitat. It consists of 

approximately 7,499 acres of which 7,323 acres (98 percent) are in potential matsutake habitat. 

Approximately 4,465 acres (60 percent) is in currently “Good” habitat, 2,082 acres (28 percent) is in the 

“Grow” category and 776 acres (10 percent) in the “Thin” category. The dry lodgepole pine habitat 

type predominates with 4,486 acres (60 percent) in potential matsutake habitat, with roughly half of that 

(2,310 acres) considered currently “Good” habitat. There are 1,304 acres (17 percent) of “Good” 

habitat in the dry ponderosa pine habitat type, 471 acres (6 percent) in the “Grow” category and 49 

acres (less than 1 percent) in the “Thin” category. There are 417 acres of dry mixed conifer, 325 acres 

of moist mixed conifer and 92 acres (1.2 percent) of moist ponderosa pine in “Good” matsutake habitat. 
Environmental Impact Statement BLT Project

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Table 3-91. Alternative B Potential Matsutake Habitat by Plant Association Group 

Plant Association 

Group (Habitat Type) Grow Good Thin 

Acres Percent Acres Percent Acres Percent 

Lodgepole pine dry 1472 19.7% 2310 30.9% 704 9.4% 

Lodgepole pine moist 12 0.2% 16 0.2% <1 <.1% 

Ponderosa pine dry 471 6.3% 1304 17.4% 49 0.7% 

Ponderosa pine moist 19 0.3% 92 1.2% 3 <.1% 

Mixed conifer dry 71 1.0% 417 5.6% 9 0.1% 

Mixed conifer moist 37 0.5% 326 4.4% 10 0.1% 

 

Alternative C 

Alternative C is very similar to Alternative B in terms of potential affect to matsutake production and 

long-term goals for sustaining vegetation over time. Using the ranges for canopy cover class by plant 

association group where potential matsutake production occurs, Alternative C would have an 

approximate 859 acre net shift toward less productive habitat. Prescribed fire on additional 1,764 acres 

in dry ponderosa pine has the potential to enhance mushroom productivity. Alternative C consists of 

5,771 acres of which approximately 5,092 (89 percent) acres are categorized as potential matsutake 

habitat. There are 3,457 acres (60 percent) in the “Good” habitat category, 1,560 acres (27 percent) in 

the “Grow” category and 75 acres (1.3 percent) in the “Thin” category. Dry lodgepole pine contains 

about half (48 percent) the area across categories, followed by dry ponderosa pine (25 percent). 

Table 3-92. Alternative C Potential Matsutake Habitat by Plant Association Group 

Plant Association 

Group (Habitat Type) Grow Good Thin 

Acres Percent Acres Percent Acres Percent 

Lodgepole pine dry 1062 18.5% 1667 29.1% 21 0.4% 

Lodgepole pine moist 10 0.2% 14 0.2% <1 <.1% 

Ponderosa pine dry 376 6.6% 1012 17.7% 33 0.6% 

Ponderosa pine moist 16 0.3% 86 1.5% 3 0.1% 

Mixed conifer dry 60 1.0% 359 6.3% 8 0.1% 

Mixed conifer moist 36 0.6% 318 5.6% 10 0.2% 

Alternative D 

Alternative D would be considered to have the most emphasis on potential short-term matsutake 

production of the action alternatives. Using the ranges for canopy cover class by plant association 

group where potential matsutake production occurs, Alternative D would have an approximate 352 acre 

net shift toward less productive habitat. Prescribed fire in dry ponderosa pine would occur on an 

additional 824 acres, potentially improving matsutake production. Alternative D consists of 2,616 acres 

of which 2,274 acres (89 percent) are potential matsutake habitat. There are 1,526 acres (59 percent) in 

“Good” category habitat, 714 acres (28 percent) in the “Grow” category and 34 acres (1.3 percent) in 

the “Thin” category. Dry lodgepole pine contains a little more than half the area across categories (55 

percent) with dry ponderosa pine containing 22 percent. 
BLT Project Environmental Impact Statement 

Chapter 3 – Special Concern Plants 

314

Table 3-93. Alternative D Potential Matsutake Habitat by Plant Association Group 

Plant Association 

Group (Habitat Type) Grow Good Thin 

Acres Percent Acres Percent Acres Percent 

Lodgepole pine dry 529 20.6% 874 34.0% 10 0.4% 

Lodgepole pine moist 7 0.3% 7 0.3% 0 0.0% 

Ponderosa pine dry 145 5.7% 396 15.4% 17 0.7% 

Ponderosa pine moist 11 0.5% 79 3.1% 2 0.1% 

Mixed conifer dry 2 <.1% 32 1.2% 2 0.1% 

Mixed conifer moist 19 0.8% 139 5.4% 3 0.1% 

Summary for All Action Alternatives 

While all action alternatives reduce risk of a stand replacement event to some magnitude across the 

landscape, they potentially reduce matsutake habitat and mushroom production in the short-term. It is 

useful to consider not only how this relates to individual units, but to the entire 80,000-acre watershed 

(BLT analysis area). Estimating change does not assume that all described potential habitat is occupied 

by the organism, or that the habitat is producing mushrooms. Seventy one (71) percent of 54,100 acres 

of the analysis area are considered potential matsutake habitat. For Alternative B, 7,300 acres (98 

percent) is considered potential habitat. If active management associated with Alternative B totally

removed its acres from matsutake production, it would approximate 14 percent of the potential habitat 

in the entire analysis area. Likewise, Alternative C would remove 9 percent and Alternative D would 

remove 4 percent of potential habitat from the analysis area. However, at least 10 percent of 

Alternative B where the canopy cover is greater than 70 percent has potential to be improved by 

thinning. It is highly unlikely that the entire acreage of potential habitat in the analysis area, or for any 

of the alternatives, actually produces mushrooms, but there are no data to support or refute that claim. 

Also, it is not possible to predict accurately to what extent active management would affect mushroom 

production, even where it is known to occur. “The interval of time and correlation between stand 

treatment and matsutake fruiting are still unknown, but it will be critical to planning future management 

action. Matsutake may occur several years or several decades after stand treatment or perhaps not at all 

(Amaranthus et al., 1998).” Production can vary a great deal from year to year for many reasons, even 

in areas untouched by human activity. It is assumed for this analysis, that any ground disturbing 

activity or removal of a host species would have some effect, even if small, on mushroom production 

(Amaranthus et al., 1996; Amaranthus et al., 1998; Durall et al., 2006; Kranabetter and Kroeger, 2001; 

Kropp and Albee, 1996; Luoma et al., 2004; Luoma et al., 2006). There is little data regarding 

silvicultural effects on ectomycorrhizal organisms in general, and matsutake mushroom production in 

particular (Amaranthus et al., 1998; Kropp and Albee, 1996; Luoma et al., 2004; Weigand, 1998), or 

how much time is needed to return to pre-treatment production. There is information that clearcutting 

can reduce mushroom production for more than 5 years (Durall et al., 2006, Kranabetter and Kroeger, 

2001); thinning could buffer that effect (Durall et al., 2006) and new root growth after 5 years would 

offset the reduced production. Soil compaction and disturbance reduce ectomycorrhiza production. In 

an Idaho study root tip quantity was reduced after compaction and seedling height remained diminished 

5 years later, a result of decreased mycorrhizal connection (Amaranthus et al., 1996). Reduced 

matsutake production after removal of the litter layer persisted 9 years in a study at Diamond Lake, 

Oregon. Where litter was removed then replaced, production seemed to rebound after 4-6 years 

(Luoma et al., 2006). With this information, it is considered reasonable to expect that some reduction 

in mushroom production might occur after silvicultural and fuel reduction activities; and that recovery 

to pre-treatment conditions, mushroom production might occur in a time period of 2-6 years. Areas of 

marginal, but still potential habitat, may take 10 years or more to recover. Monitoring would be 

necessary to validate the recovery time estimate. 
Environmental Impact Statement BLT Project

 Chapter 3 – Special Concern Plants

315

Monitoring 

Much of the analysis area has been described as potential matsutake habitat. It is not known how much 

of the analysis area or any of the alternatives actually has matsutake mycelia in it or how much actually 

produces matsutake mushrooms. Additionally, for areas that are known to have matsutake mycorrhiza, 

it is unknown if or where matsutake mushrooms will appear from year to year, or how it would respond 

to silvicultural or fuels activities. This project offers an opportunity to document occurrences of 

matsutake or its indicator, Allotropa virgata, in and out of treatment units, develop baseline data for 

production and environment, and subsequently monitor the effects of the silvicultural and fuels 

prescriptions (Weigand, 1998). Attributes for consideration would be canopy closure, size class, plant 

association, species composition, litter/duff depth and soil drainage class. These attributes have been 

cited as contributing to habitat and mushroom production but quantification has been unclear. Repeat 

visits may be necessary as formerly productive areas may take several years to recover, and year to year 

production is extremely variable. This type of monitoring may not have the rigorous design needed in a 

peer-reviewed scientific study, but can function as a way to test and refine the identification and 

quantification of matsutake habitat and mushroom production. 

Within the BLT analysis area, effectiveness monitoring was set up in the in the fall of 2003, prior to 

implementation of the Critter Timber Sale (2000 Baja EA) to determine what potential effect forest 

management has on matsutake production. The vegetative prescription for the two units can be 

characterized as understory thinning in mixed conifer similar to actions proposed in BLT. Plots were 

placed in a unit that was harvested with a helicopter (#15), and a tractor (#90). Although this 

monitoring lacked the scientific rigor and timeframe to provide sufficient answers, there is evidence to 

determine forest management does not eliminate matsutake production. Matsutake mushrooms were 

found within units that have experienced timber harvesting. 

Pre-harvest monitoring included controlled intuitive pedestrian transects between plots to note presence 

and abundance of American matsutake and Allotropa virgata, as well as evidence of picking. Presence 

of mushroom harvesters was noted as well. The plots would then be visited for five consecutive years 

post-harvest to assess the same information. In 2004, the first post-harvest monitoring was completed. 

The frequency of collection of information occurs every two weeks within the harvest season, usually 

from mid September until November 1. The following is a summary of findings up to 2007: 

Critter 15 Logged May thru June 2004 

Plots 1, 4, & 6 have never shown any fruiting matsutake including prior to timber harvest. 

Plots 2, 3, 7 did not show any fruiting matsutake prior to harvest, but have shown occasional/sporadic 

fruiting since. 

Plot 5 showed no pre timber harvest fruiting, but has fruited very consistently post harvest. 

Critter 90 Logged April thru August 2005

Plots 1, 4, 7, 8, 10, 11, 12, & 13 have never shown any fruiting matsutake including prior to timber 

harvest. 

Plots 5 & 9 did not show any fruiting matsutake prior to harvest, but have shown occasional/sporadic 

fruiting since. 

Plots 2, 6, & 14 have been shown to fruit only occasionally both pre and post harvest 

Plots 3 &15 showed no pre timber harvest fruiting, but has fruited fairly consistently post harvest. 

There was evidence of mushroom harvest collection for each year. 

Proposed Monitoring for all Action Alternatives 

Goal: In collaboration with the scientific community and interested matsutake harvesters, determine the 

effect of active management on matsutake production. The goal is for forests in a sustainable condition 

also produce collectible mushrooms. 
BLT Project Environmental Impact Statement 

Chapter 3 – Special Concern Plants 

316

Objective: To gather information on the effects of silvicultural treatments on matsutake habitat and 

mushroom production. 

Monitoring Elements: Presence of matsutake, identification of soil biota, Plant Association Group, 

condition class, structural stage, canopy cover, environmental factors such as weather and topography, 

fuels hazard, soil condition, basal area 

Area of Consideration: It is expected a study plan with appropriate monitoring criteria would be 

developed with the Pacific Northwest Research Station prior to implementation. Establish a number 

study plots consistent with scientific protocol two years prior to implementation of BLT 

Cumulative Effects 

The selected zone of influence was the 80,000-acre 5th field Upper Little Deschutes Watershed plus the 

Crescent Lake area since these have been identified by the harvesters as the most important for 

matsutake production. Viable Ecosystems modeling has accounted for all active management that has 

occurred in the BLT area (Upper Little Deschutes Watershed) up to September 2004. Since that time 

Baja West, Critter, and the Lower timber sales from Baja 58 Environmental Assessment and Finding of 

No Significant Impact have been completed (1,310 acres). These sales are characterized as understory 

thinning in mixed conifer, retaining the largest trees. This would affect matsutake production on 2 

percent (1,310/54,122) of potential habitat within the BLT area. For Alternative B, 7,300 acres (98 

percent) is considered potential habitat. If active management associated with Alternative B totally

removed its acres from matsutake production plus timber sales since 2004, it would approximate 16 

percent of the potential habitat in the entire analysis area. With this information, it is considered 

reasonable to expect that some reduction in mushroom production might occur after silvicultural and 

fuel reduction activities, and that recovery to pre-treatment conditions, mushroom production might 

occur in a time period of 2-6 years. For these reasons, the analysis of past actions other than those 

listed in this section is based on current environmental conditions. Areas of marginal but still potential 

habitat may take 10 years or more to recover. 

Fuels reduction activities that have occurred in the BLT area since September 2004 include small 

diameter thinning in lodgepole pine plantations and brush mastication (771 acres). It is assumed these 

activities did not reduce matsutake production because they occurred in areas that likely were not 

producing mushrooms, and were accounted for in the 2004 Viable modeling. In addition, 180 acres of 

prescribed burning in ponderosa pine along road 5825 may have actually enhanced matsutake 

production. 

A petition brought to the Forest Service in October 15, 2002, by mushroom harvesters regarding 

concern for the Baja timber sales and future vegetation management projects resulted in withdrawal of 

the Woody Fiber timber sales and Critter #20 in the Windigo Pass area. Windigo Pass is nearby 

Crescent Lake and is characterized as one of the more valuable areas for picking matsutake. In addition 

to withdrawal of the timber sales, 610 acres of prescribed burning in fire intolerant stands for blackbacked woodpecker habitat was also removed from implementation. Also, as part of agreements with 

the Pacific West Community Forestry Center who represented mushroom harvesters at the time, the 

Crescent Ranger District implemented additional measures to collaborate on future projects and agreed 

to use a helicopter for removing timber in Critter unit #15. 

Since the petition and collaboration that has occurred from 2002 on, no other timber sales have 

occurred in the Windigo Pass Area. The Crescent Lake Wildland Urban Interface Fuels Reduction 

Project signed in 2004 has begun thinning and fuels reduction within the Walker Range Community 

Wildland Protection Plan area on 3,700 acres. An effort to outreach the mushroom harvesters occurred. 

Timber sales from this decision include the Trig Stewardship, Indy Firewood, Camp Fiber Timber sale, 

UP Timber Sale, Tums Timber Sale, and BSA Timber Sale. These activities are characterized as small 

diameter thinning to relieve competition to the larger trees and hazardous fuels reduction, mostly where 

lodgepole is the more dominate species. 
Environmental Impact Statement BLT Project

 Chapter 3 – Special Concern Plants

317

It is also reasonable to expect that some reduction in mushroom production might occur after 

implementation of these activities, and that recovery to pre-treatment conditions, mushroom production 

might occur in a time period of 2-6 years. Areas of marginal but still potential habitat may take 10 

years or more to recover. 

 
BLT Project Environmental Impact Statement 

Chapter 3 - Cultural Resources 

318

Cultural Resources ___________________________________ 

Management Direction 

Management direction for cultural resources is found in the Deschutes National Forest Resource 

Management Plan, in the Forest Service Manual section 2360, in Federal Regulations 36CR64 and 

36CFR800 (amended December 2000), and in various Federal laws including the National Historic 

Preservation Act (NHPA) of 1966 (as amended), the National Environmental Policy Act, and the 

National Forest Management Act. 

In general, the existing management direction is to determine the effects on cultural resources when 

considering projects that fall within the Forest’s jurisdiction. Further direction indicates that the Forest 

will determine what cultural resources are present on the forest, evaluate each resource for eligibility to 

the National Register of Historic Places (National Register), and protect or mitigate effects to resources 

that are eligible. 

Relevant Forest Plan Standards and Guides include: 

• CR-2, which states that cultural resource properties located during inventory will be evaluated 

for eligibility to the National Register. 

• CR-3, which states that in concert with inventories and evaluations, the Forest will develop 

thematic National Register nominations and management plans for various classes of cultural 

resources. 

• CR-4 indicates that project level inventories or the intent to conduct such shall be documented 

through environmental analysis for the project. 

Desired Condition 

The desired condition is not clearly stated in the Forest Plan but can be derived from the implied goals 

of the Standards and Guides and the Monitoring Plan. It would be desired to know the location and 

extent of all cultural resources, to have evaluated each one for eligibility to the National Register, and to 

have developed management plans for all eligible properties that would provide protection or mitigate 

effects that will occur to the resources. 

Existing condition 

The Upper Deschutes 5th field watershed is not within ceded lands for any tribes. However, a treaty 

with the Klamath Tribe in 1864 identified the area as usual and accustomed grounds. The treaty’s 

northern boundary at the 44th parallel divides the interest for the Confederated Tribes of Warm Springs 

and Burns-Paiute, although their interests may overlap. 

There are no known ethnobotanical plants of economic significance, or native foods within the analysis 

area. Native plants found today in the analysis area are representative of current environmental 

conditions. Since these conditions have been subject to change over time, so too, have the native plants 

changed. Trees, shrubs, forbs, roots, sedges, and grasses supplied such needs as food, tobacco, chewing 

gum, seed sources, teas, medicine, insect repellants, dyes, and materials for basketry and other building 

needs. Limited information is available about native plant use in the past in the analysis area. It may be 

inferred from evidence at archaeological sites in the area. Tools that fall into a category called “ground 

stone” are documented, including mortars, hopper mortars, manos, and metates. Grinding, mixing, 

pounding, and cooking activities are all indicated by these clues from the past. 

Due to the sensitive nature of cultural resource sites, documentation can be found on file at the Crescent 

Ranger District. 
Environmental Impact Statement BLT Project

 Chapter 3 – Cultural Resources 

319

Previously reported cultural resource inventory survey has covered 25,207 acres (approximately 32 

percent of the 80,000 acre analysis) of the proposed project units. A new inventory survey of 5,783 

acres (or approximately 7 percent of the project) was completed in 1988, 2003, and 2005. Previous and 

new surveys combine to reach a sample of 30,990 acres (or 39 percent) of the analysis area receiving 

cultural resource inventory survey. This includes all of the projected high probability areas. 

Seventy-three cultural resource sites (previously known and newly reported) were identified within or 

adjacent to the various areas of activity within the analysis area. Of these, 52 sites have been evaluated 

for eligibility to the NRHP; 16 of them are eligible and 36 are not eligible. The remaining 21 sites have 

not been evaluated for eligibility; this therefore requires that they be protected. Site types represented 

include lithic scatters, lithic scatters with flake tools, historic structure remains (singly or in a complex 

of related structures), refuse dumps, refuse scatters, a corral, a fence, a wagon road, and remains of 

historic era railroad logging. 

Consultation 

Tribal consultation for the BLT project was initiated in 2003 under the 1995 Programmatic Agreement. 

During the early stages of this project, contacts were made with affected tribes (Klamath, Confederated 

Tribes of Warm Springs, and Burns-Paiute). Government-to-government consultation has been 

informal through meetings between the Deschutes National Forest supervisor and their representatives, 

scoping letters, and personal contact with natural resource members representing all three tribes. In 

addition, Paul Claeyssens, the Central Oregon Tribal Liaison acting on behalf of the Forest Supervisor, 

met with the Klamath tribal leaders in January and then again in March 2008 at their annual quarterly 

meetings to discuss Forest programs and potential projects of interest. No special concerns about Tribal 

resources were identified. 

Environmental Consequences 

Alternative A 

Alternative A would continue the status quo for vegetation. Custodial activities such as fire suppression 

would continue. There would be no effects to eligible or potentially eligible cultural resource sites. 

Effects Common to all Action Alternatives 

Following guidelines in a 2003 Regional Programmatic Agreement among USDA-Forest Service, the 

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

finding of “Historic Properties Avoided” was determined. This finding is based on the practice of 

avoiding all eligible and unevaluated sites. Under proposed Alternative B activities, 12 eligible or 

potentially eligible sites are found within 17 units. Twelve Alternative C areas of activities overlap part 

or all of seven sites. In Alternative D 10 units are in conflict with 10 sites. Given the potential ground 

disturbing activities to perturb sites, all would be protected by avoidance. There are no direct, indirect, 

or cumulative effects anticipated for cultural resources under either action alternative. There are no 

anticipated effects on cultural resources that would be an irreversible or irretrievable commitment of 

cultural resources. 

If a new cultural resource site is discovered all applicable standards and guidelines would be met 

through contract provisions and notification of the appropriate personnel. 

It is acknowledged that the Tribes may have lost the verbal history and they may not know where 

desired plant species and resources may be found. This affects their ability to tell Federal agencies 

where Tribal trust resources can be located on Federal lands. Restorative activities planned for the BLT 

project, such as prescribed burning in appropriate places would promote the types and amounts of 

plants that evolved in a frequent fire regime and were likely utilized by native peoples, so they would 

likely remain or increase in the project area. 
BLT Project Environmental Impact Statement 

Chapter 3 - Cultural Resources 

320

Based on the current knowledge about cultural use of native plants by American Indian tribes and the 

nature of the proposed action, there would be no effect. Access to potential culturally important areas 

in the project area, would not change as a result of proposed actions. 

Given this finding of Historic Properties Avoided, there would be no direct effects from the proposed 

alternatives on any eligible or potentially eligible cultural resource sites. Monitoring by appropriate 

personnel occurs during activity layout, during harvest operations by Sale Administrators, and post 

harvest. This has shown to be effective during several recent projects including the Davis Fire 

Recovery Project. The combination of protection through avoidance and monitoring is an effective way 

to manage known cultural resources for long-term preservation. 

The BLT project maintains consistency with Deschutes Forest Plan standards and guidelines by 

inventorying sites, evaluating their potential, and providing documentation. 
Environmental Impact Statement BLT Project

 Chapter 3 - Recreation 

321

Recreation __________________________________________ 

Existing Condition/Facilities 

Relative to other areas on the Crescent Ranger District, the BLT planning area offers a limited range of 

recreational experiences. The majority of uses are associated the Little Deschutes Wild and Scenic 

River, dispersed camping primarily associated with hunting season, mushroom picking, motorized 

recreation, and activities such as hiking associated with the nearby Oregon Cascades Recreational 

Area.. Although there are only established trail systems for over-the-snow vehicles, roads and various 

user-created trails provide access for Off-Highway Vehicles during the summer and shoulder seasons. 

The BLT project would not change access for motor vehicles. However, in November 2005, the Final 

Rule for Travel Management was released and published in the Federal Register. The Deschutes and 

Ochoco National Forests is currently implementing a public process to identify opportunities to 

designate motorized use and prohibit use outside of those areas. The final map is expected to be 

published in 2009. There are no developed recreation sites in the BLT analysis area, and a few known 

and traditional dispersed sites. 

The level of unregulated camping with no-fee (dispersed) recreation throughout the remaining analysis 

area is considered low compared to other more popular areas on the District with access to water 

bodies. These sites are mainly visited late in the fall hunting season, and have a typical recreational 

experience of semi-primitive with motorized access. The majority of known sites are located along the 

Little Deschutes River off Highway 58 on 5835, in the “Cow Camp” area, near Odell butte and 

Highway 58, and at the end of road 6100-100 near a local landmark called “Bridge Out”. In recent 

years, road 6100-100 has deteriorated to a point safe access to the campsite has been reduced, causing 

determined campers to breach the road prism. 

The BLT area also has approximately 15.3 miles of designated snowmobile trails (Beal’s Butte 

Connector, Chemult Run, and Beal’s Loop). The Chemult Run is probably the most popular and all are 

groomed on an occasional basis by volunteers. The entire trail system is located on maintenance level 

II roads (roads maintained for high clearance vehicles), or better. 

There is also a cross country ski trail that on Little Odell Butte that has no evidence of use and is no 

longer identifiable on the ground. Due to the situation and a limited budget for maintenance, it will be 

taken off the forest inventory of cross country ski trails. 

Environmental Consequences 

Alternative A 

Alternative A would continue the status quo for vegetation within the analysis area. Custodial activities 

such as suppression of wildfires and maintenance of roads would continue. This alternative has the 

greatest risk from large-scale disturbance process, potentially which would have the greatest effect on 

visitor experiences. 

Those who use dispersed camping and snowmobile trails in the area areas would not be affected by 

vegetation management activities. 

Action Alternatives 

In Alternatives B, C, and D prescriptions for management of trees are designed to lessen the risk of a 

large-scale disturbance process. They would maintain the largest trees on site and there would be no 

loss of Late and Old Structure (LOS). However, evidence of active management would be noticeable to 

people who use the dispersed camping sites, particularly off the 6100-100 spur near the Little Deschutes 

River (unit 65) and the Odell Butte/Highway 58 site off of roads 5800-895, 925 and 927. Mitigation 

measures have been designed to retain the recreational experience by limiting skid trails and landings to 
BLT Project Environmental Impact Statement 

Chapter 3 - Recreation 

322

outside the camping area and all slash from harvest operations within the camping area would be 

handpiled. Also, both potentially affected sites would be posted to inform users. Access to the “Bridge 

Out” site would be improved to facilitate harvest operations, fixing drainage structures and road surface 

to a maintenance Level II road. 

Winter harvest operations to limit soil disturbance in areas where matsutake is present or suspected 

have the potential to affect trail grooming operations on the Chemult Run and Beal’s Loop Trail 

systems. Therefore, units where harvest operations have potential to conflict with trail grooming are 

restricted to April 15 through November 15 affecting five units in Alternative B (410, 460, 525, 770, 

785) and two in Alternatives C and D (525 and 785). With this mitigation in place, trail grooming 

operations would be unaffected except for approximately 1,000 linear feet between the junction of the 

5825/5830 and 5825/5825-055 roads. In collaboration with the affected local snowmobile trail 

groomer, it was agreed that the trail could be maintained by grooming adjacent to the plowed road 

because of the wide and flat terrain available adjacent to a young tree plantation. Incidental removal of 

young trees may be necessary, but this would be similar to regular maintenance activities to retain 

public safety and site distance on open roads. 

Recreational picking of matsutake (as opposed to commercial) would not change beyond those effects 

expressed under the heading “Special Concern Plants”. The management emphasis for the balance of 

recreational matsutake picking versus commercial opportunities would not change as a result of BLT 

activities. 

Cumulative Effects 

There are no additive effects identified in addition to an active management scenario. Access for 

recreation to the National Forest as a result of this project would not change except for routine road 

maintenance activities on roads that have been identified as “open” for motor vehicle access. 
Environmental Impact Statement BLT Project

 Chapter 3 - Transportation System 

323

Transportation System_______________________________ 

Management Direction 

Desired Transportation System Conditions 

The desired condition is to provide a road system that is safe, affordable, has minimal ecological 

impacts, and meets immediate and projected long-term public and resource management needs. 

The current direction for management of the road system is found in the 1990 Deschutes National 

Forest Land and Resource Management Plan (LRMP). According to the LRMP, the goal of the 

Forest’s transportation system is “to plan, design, operate, and maintain a safe and economical 

transportation system providing efficient access for the movement of people and materials involved in 

the use and protection of National Forest Lands.” (LRMP pg. 4-71) 

Existing Condition 

Location and Distribution 

Within the BLT analysis area there are approximately 545 miles of roads under various private and 

public jurisdictions. The existing road system is unevenly distributed throughout the analysis area and 

is mostly outside of the Oregon Cascades Recreation Area (OCRA) and Mt. Thielsen Wilderness. West 

of the Little Deschutes River, roads are generally widely distributed, while a greater abundance of roads 

can be found south of Two Rivers subdivision and on private land in the northern portion of the analysis 

area. Within the OCRA, there are approximately 2 1⁄2 miles of road 5830300. It runs up the Little 

Deschutes River canyon in the OCRA while approximately 1 1⁄2 mile of abandoned decommissioned 

roadbed can be found at the southern end of the analysis area in the Mt. Thielsen Wilderness. 

The majority of roads within the analysis area are located on relatively gentle terrain, with ground 

slopes rarely exceeding 15 percent. Scattered roads can be found in midslope positions on grades at or 

beyond 30 percent. Most such roads are in the lower Little Deschutes River canyon south of the Two 

Rivers subdivision, along the southwest side of the analysis area adjacent to the Oregon Cascades 

Recreation Area boundary, and within the watershed boundary on Odell Butte. 

Age and Development History of the Transportation System 

The majority of roads within the analysis area have been in existence for more than 40 years, with few 

additions having been constructed in the recent past. Some portions of the system date back to early 

railroad logging days in the early 20th Century centered around the sawmill facility at Mowich; in fact, 

some of the current roads in earlier days served as locations for railroad grades. With few exceptions, 

the roads in this analysis area have been constructed for access to timber harvest areas; a small number 

of roads on private land have been developed as infrastructure in support of developing subdivisions 

(Two Rivers, Schoonover Estates). 

The relatively gentle topography within the analysis area has led to a tradition of employing groundbase yarding systems to remove logs to landings. Temporary roads have customarily been constructed 

to provide access to those landings that were within the interior of units or otherwise not immediately 

adjacent to existing portions of the transportation system. Older temporary roads that had not 

revegetated were added to the transportation system in the late 1970s in response to a directive that all 

existing wheel tracks be inventoried. With the advent of the requirement in 1976s National Forest 

Management Act that temporary roads be revegetated within 10 years, more attention has been paid to 

improving circumstances for revegetation on compacted temporary road surfaces, and within the last 

decade they have been aggressively treated by decompaction with tractor-mounted winged subsoiling 

tools. 
BLT Project Environmental Impact Statement 

Chapter 3 - Transportation System 

324

Road Use Patterns over Time, Now, And In The Future 

The roads within the analysis area generally have a pattern of use common to low-standard forest roads 

in the absence of residential enclaves or developed recreation. With the exception of roads immediately 

adjacent to subdivisions such as Two Rivers - where all-terrain vehicle (ATV) use outside of riparian 

areas can be extensive – or of the arterial roads and major through-routes such as 5825, 5830, 5835, and 

6125, most roads see little use other than administrative traffic through the course of the spring and 

summer. Timber sale activity can contribute substantially to daily traffic values, but the pattern of such 

activity is usually isolated to one particular area at any given time. 

In past years when active grazing allotments were located within the analysis area, there was a small 

usage component provided by permittee vehicles, but that has ended with the abandonment of the 

allotments. The bulk of use, especially southwest of State Highway 58, comes in the late summer and 

fall with the commencement of deer and elk hunting season and the matsutake mushroom picking 

season. 

 

The existing road system is employed by two specific users in support of their commercial endeavors. 

Union Pacific Railroad holds road use permits to maintain access to their main rail line running through 

the analysis area, and Mid-State Electric Cooperative uses parts of the existing system to service their 

electrical lines that pass through the analysis area. These uses, although not a significant component of 

the total usage, have occurred for many years (especially in the case of the railroad access for the 

former Southern Pacific Railroad) and will continue into the foreseeable future. 

 

The anticipated future use patterns will most likely reflect current trends, with the majority of summer 

usage being comprised of administrative traffic with occasional isolated increases resulting from timber 

sale activity, followed by increased late summer/fall traffic due to hunting and mushroom picking 

activity. 

Primary Destinations of Road System Users 

The bulk of the roads within the analysis area do not generally serve any particular destinations. 

Rather, they provide access to areas of interest for various users. For land managers, these roads serve 

as access to areas where reforestation or vegetative management activities are ongoing or planned. For 

hunters, they provide access to popular hunting areas like Beales Butte or the boundary of the Oregon 

Cascades Recreation Area. For matsutake mushroom pickers, these roads provide entry into a number 

of picking areas in the southwest portion of Crescent Ranger District. 

Road Surface Types and Existing Maintenance Levels 

By far the majority of roads within the analysis area, almost 91 percent, are native surface roads. Those 

under Forest Service jurisdiction are variously managed as either being open for high clearance vehicle 

traffic (Maintenance Level 2) or as being physically closed so that traffic is eliminated and the roads are 

in a basic custodial status (Maintenance Level 1) but not prohibited (by Order). The native surface 

roads in Maintenance Level 2 status are not maintained on a recurring basis but are instead periodically 

reviewed to determine whether maintenance needs to protect adjacent resource values are present. 

Many of the native surface roads in the analysis area are on private land and are variably open to public 

access depending on the wishes of individual landowners or existence of public rights of way (as in the 

case of subdivisions within the analysis area.) 

An additional 3 percent of the roads are either categorized as improved native or aggregate-surfaced. 

One of these roads, Rd. 5830 through the Two Rivers subdivision, is maintained to allow passenger car 

use (Maintenance Level 3), while others, such as Rd.’s 5825 or 5835, are not specifically maintained for 

passenger car use. 
Environmental Impact Statement BLT Project

 Chapter 3 - Transportation System 

325

The remaining 6 percent of roads are asphalt or bituminous-surfaced facilities which includes Hwy. 58, 

the southern leg of Road 5825, and County Road 61 (Crescent Cutoff). Held mostly in jurisdiction by 

entities other that USDA Forest Service, these roads are classified as Maintenance Levels 4 and 5, 

which includes roads where passenger car use is encouraged and the primary emphasis is on traveler 

comfort and safety. 

Table 3-94. Miles of Road by Maintenance Level 

Existing Road Management Objectives 

The existing management objectives for roads within the analysis area is for roads to be managed 

primarily for administrative and land management purposes, with public access being a primary 

consideration only in areas where access to subdivisions is provided. 

With the exception of those roads providing access to dispersed campsites or recreational/permanent 

residences, the seven-digit roads are generally managed, when open, to be primarily used by high 

clearance vehicles. While passenger car operation is possible on these routes, no special consideration 

or effort is devoted to allowing their use. During periods of log haul, these seven-digit roads are 

intended to be single-user facilities, given that their narrow travel ways and lack of frequent, 

intervisible turnouts preclude opportunities to safely provide for mixed commercial/private traffic. 

Road Densities 

Open road densities within the analysis area can be expressed as either “objective” or “operational”. 

For example, the Seven Buttes Environmental Assessment Decision Notice and Finding of No 

Significant Impact overlaps the BLT analysis area and closed almost 100 miles of roads as part of the 

decision. Many of the roads have been closed, but not all due to budget and opportunity. That number 

is reflected in the “Operational Open Road Density”. A plan has been put in place on the District to 

alleviate this situation and physically close roads by priority. In addition, roads listed in this category 

do not receive maintenance and become effectively closed over time as vegetation returns. 

The objective open road density is the desired density that would be achieved if all roads were in their 

desired opened or closed status; the operational road density is a reflection of the current opened or 

closed status of roads within a given sixth field subwatershed. 

Total road density is expressed as all roads which are open or closed for each category. 

The analysis area lies within six separate sixth field subwatersheds. The following table displays the 

overall road densities within those seven subwatersheds, including both roads inside and outside the 

analysis area and private roads as well as roads under Forest Service jurisdiction. 

Operational Maintenance Level Miles 

Unclassified Other Jurisdiction 266 

M/L 1 (Closed) 35 

M/L 2 (High Clearance Vehicles 

Allowed) 231 

M/L 3 (Passenger Car Allowed; 

Low Speed) 6 

M/L 4 (Passenger Car Accepted; 

Moderate Speed) 2 

M/L 5 (Passenger Car 

Encouraged; High Speed) 22 
BLT Project Environmental Impact Statement 

Chapter 3 - Transportation System 

326

Table 3-95. Road Density on a Subwatershed Basis (Mile/Square Mile) 

Subwatershed 

Name

Operational Open 

Road Density

Objective Open 

Road Density

Total 

Road Density

Bunny Butte 

(All Roads) 3.99 2.86 4.15 

Bunny Butte 

(FS Roads Only) 2.14 1.02 2.31 

Clover Butte 

(All Roads) 1.82 1.29 1.84 

Clover Butte 

(FS Roads Only) 1.17 0.64 1.19 

Gilchrist 

(All Roads) 5.66 5.63 5.89 

Gilchrist 

(FS Roads Only) 1.30 1.31 1.57 

Gilchrist Junction 

(All Roads) 5.90 5.09 6.03 

Gilchrist Junction 

(FS Roads Only) 2.85 2.05 2.90 

Hemlock Creek 

(All Roads) 2.73 1.81 3.18 

Hemlock Creek 

(FS Roads Only) 2.09 1.16 2.53 

Little Odell Cr.

(All Roads) 4.95 3.24 5.64 

Little Odell Cr. 

(FS Roads Only) 3.72 2.03 4.43 

Table 3-96. Road Density on a Key Elk Area Basis 

Key Elk Area 

Name

Operational Open 

Road Density

Objective Open 

Road Density

Total 

Road Density

Hemlock 5.24 2.35 5.90 

 

The small portion of Fly Key Elk Area also overlaps the BLT analysis area on 26 acres, however, there 

is no active management planned and therefore road densities were not calculated. 

Alternative A 

Direct and Indirect Effects 

Under Alternative A, the existing road system would experience no changes in its current status and 

condition. Roads that are currently in custodial status (Maintenance Level 1) would remain closed and 

open roads would continue to provide access for recreational, commercial, and administrative functions 

in the same manner that they currently do. Open roads would receive no maintenance beyond that 

which is normally scheduled, which is generally devoted to the higher standard roads within the 

Analysis Area. Roads that have been scheduled to be closed under previous decisions would continue 

to be decommissioned according to the District-wide road closure plan. 

Common to Action Alternatives

Direct and Indirect Effects 

As a function of use during harvest activities, road maintenance activities would be conducted on roads 

designated for use. As a direct effect, some roads that do not receive recurring maintenance, primarily 

low standard roads in the Maintenance Level (M/L) 2 category, would see some improvements in both 
Environmental Impact Statement BLT Project

 Chapter 3 - Transportation System 

327

safe drivability and in their ability to handle surface runoff and the resultant sediment. Native surface 

M/L 2 roads, as a result of use and infrequent blade maintenance, tend to develop shallow ruts in their 

wheel tracks, which can concentrate shallow flow and lead to increased sediment rates (Foltz, 1991). 

Post-haul maintenance that would occur on these roads would restore flat road surfaces (without ruts) 

that would be capable of producing less sediment than their rutted counterparts; post-haul water bars 

would also remove surface runoff from the erosive road surfaces. 

The type of work that would be expected to be performed as maintenance in timber sale contracts 

includes: brushing for improved sight distances, removal of hazard trees, blading and shaping of 

traveled way, restoring existing surface drainage features (such as drain dips or outlet ditches), cleaning 

culverts and ditches, and installing water bars after periods of haul. 

Dust abatement, primarily using water, would be performed as necessary to maintain safe driving 

conditions. This would have a secondary effect of maintaining a relatively well-bonded road surface 

free of the highly erosive pulverized ash “flour” that can occur on native surface roads under heavy use 

conditions. Implementation of action alternatives would increase the potential for encounters on 

roadways between forest visitors and equipment associated with harvest. This elevated level of risk 

would be present for the short-term (approximately 5 years). Safety measures such as informational 

signing, flaggers, and road maintenance activities, such as brushing roads for increased visibility, would 

be enforced in the timber sale contract. 

Haul would be occurring through the Two Rivers subdivision on road 5830, which is under Forest 

Service jurisdiction. Road maintenance and dust abatement would occur commensurate with operations 

and a 25 mile posted speed limit would be enforced through contract provisions. 

Alternative B 

Direct and Indirect Effects 

It is assumed the activities associated with all the action alternatives would begin at the earliest in 

summer 2009. Commercial haul activities and other vegetative treatments proposed in this Alternative 

would result in the use of approximately 160 miles of system roads under U.S.D.A.-Forest Service 

jurisdiction. During the course of treatment activities, 22 miles of roads currently closed and in 

custodial status as Maintenance Level 1 roads would be opened. This would result in some short-term 

increase in open-road densities in staged implementation (e.g. not all timber sales would operate at the 

same time) for duration of 5 years. The majority of maintenance work would be performed on the 150 

miles of Maintenance Level 1 and 2 roads used for commercial activities, in particular blading and 

brushing. 

 

Table 3-97. Alternative B Road Miles (Forest Service Jurisdiction) by Maintenance Level 

Operational Maintenance Level Length 

1 – Basic Custodial Care (Closed) 21.6 

2 – High Clearance Vehicles 128.4 

3 – Suitable For Passenger Cars 8.1 

4 – Moderate Degree of User Comfort 1.5 

Alternative C 

Direct and Indirect Effects 

Under this alternative, 126 miles of system roads would be used for commercial haul activities and 

other vegetative treatment proposals. Treatment activities would result in the opening of 17 miles of 

Maintenance Level 1 roads, resulting in a short-term increase in open road density, but – as with 

Alternative B – not all roads would be opened at the same time and all would be closed at the end of 

treatment activities. Under this alternative, approximately 116 miles of Maintenance Level 1 and 
BLT Project Environmental Impact Statement 

Chapter 3 - Transportation System 

328

Maintenance Level 2 roads would receive the majority of attention, particularly the native surface 

roads. 

Table 3-98. Alternative C Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level 

Operational Maintenance Level Length

1 – Basic Custodial Care (Closed) 16.7 

2 – High Clearance Vehicles 99.4 

3 – Suitable For Passenger Cars 8.1 

4 – Moderate Degree of User Comfort 1.5 

Alternative D

Direct and indirect Effects 

The least number of roads would be employed under this alternative, with 76 miles of system roads 

being used for commercial haul activities and other vegetative treatment proposals. Treatment activities 

would result in the opening of 11 miles of Maintenance Level 1 roads, resulting in a short-term increase 

in open road density, but, as with the two previous alternatives, not all roads would be opened at the 

same time and all would be closed at the end of treatment activities. Under this Alternative, 

approximately 66 miles of Maintenance Level 1 and 2 roads would receive the majority of attention, 

particularly the native surface roads. 

Table 3-99. Alternative D Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level 

Operational Maintenance Level Length

1 – Basic Custodial Care (Closed) 11.4 

2 – High Clearance Vehicles 55.1 

3 – Suitable For Passenger Cars 8.1 

4 – Moderate Degree of User Comfort 1.5 

Temporary Roads 

Temporary road construction is sometimes required to facilitate the economical harvest of trees from a 

particular harvest unit. Within the BLT analysis area, all action alternatives would result in the 

temporary commitment of acreage to use as road beds. Mileage and acres per alternative are shown in 

Table 3-100. 

 Table 3-100. Temporary Road Estimate, By Alternative 

Alternative Estimated Mileage Estimated Acres 

Alternative B 9.7 20.2 

Alternative C 8.7 16.8 

Alternative D 4.7 9.2 
Environmental Impact Statement BLT Project

 Chapter 3 - Transportation System 

329

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The USDA is an equal opportunity 

provider and employer

Action Alternative Temporary Road

Action Alternative Haul Road

Action Alternative

Road Operational Maintenance Level

1 - BASIC CUSTODIAL CARE (CLOSED)

2 - HIGH CLEARANCE VEHICLES

3 - SUITABLE FOR PASSENGER CARS

4 - MODERATE DEGREE OF USER COMFORT

5 - HIGH DEGREE OF USER COMFORT

Figure 3-29. Action Alternative Temporary Road Construction West of Highway 58 
BLT Project Environmental Impact Statement 

Chapter 3 - Transportation System 

330

Figure 3-30. Action Alternative Temporary Road Construction East of Highway 58 

58

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Action Alternative Temporary RoadAction Alternative Haul RoadAction Alternative

Road Operational Maintenance Level

1 - BASIC CUSTODIAL CARE (CLOSED)2 - HIGH CLEARANCE VEHICLES3 - SUITABLE FOR PASSENGER CARS4 - MODERATE DEGREE OF USER COMFORT5 - HIGH DEGREE OF USER COMFORT
Environmental Impact Statement BLT Project

 Chapter 3 - Transportation System 

331

Temporary roads would be constructed primarily on flat ground (slopes less than 10 percent) and 

excavation and construction of embankments would be negligible. These temporary roads would be 

built to low construction standards, with constraints of grade, curve radius, compaction, surfacing, and 

width being tailored to the minimum capabilities of the intended user vehicles. By doing so, they 

would be constructed in a manner that would minimize disturbance and impacts to adjacent resources. 

Temporary roads, by their nature, are not intended for mixed vehicle use, nor are they intended to 

remain as identifiable facilities after the administrative need for their use has ended. At the completion 

of harvest and post-harvest activities (treatment of residual slash), all temporary roads would be 

barricaded to eliminate motor vehicle access and would be subsoiled as part of post-harvest soil 

remediation activities to facilitate their return to proper hydrologic function and vegetative productivity. 

Effects of temporary roads stem directly from compaction and include loss of infiltrative capacity, 

increased erosion potential, and dramatically reduced vegetative productivity. Compaction results in 

increased bulk density and reduced porosity, primarily through the loss of macropores, leading to 

reduced aeration and drainage, as well as disruption to microbial populations that causes that reduced 

productivity and increased erosion potential (Elliot et al., 1999). Bulk density has been show in several 

studies to reduce tree growth not only within the compacted area itself, but also for trees adjacent to the 

compacted area because of root zone compaction (Froehlich, 1979; Heilman, 1981; Helms and Hipkin, 

1986; Conlin and van den Driessche, 1996) as a result of increased root impedance and disrupted 

microbial processes. Natural recovery from compaction can be variable, with the more dramatic 

reduction in bulk density coming near the surface of the soil profile, but in general the rate of natural, 

unassisted recovery is slow (Froehlich et al., 1985). These effects would be reduced by soil restoration 

such as subsoiling so that they generally apply only over the short term – five years or less. Because of 

the moderate ground slopes and high to excessive infiltration rates of the soils adjacent to these 

temporary road beds, sedimentation effects would be localized to upland areas immediately adjacent to 

the roads. 

Cumulative Effects 

There are no incremental or additive effects that that overlap the analysis area except for 

implementation of the Travel Management Rule expected in 2009. When central Oregon forests and 

grasslands finalize this process, travel on Maintenance Level 1 roads would be prohibited and the 

operational road objectives densities displayed in Table 3-95 would move toward those in the objective 

road column. Also, off road travel would be prohibited except in designated areas. This would 

effectively reduce the number of roads the public has now available for motorized travel. Additional 

effects are not known at this time until the final transportation map is published which would begin the 

process of analyzing for designated trails. 
BLT Project Environmental Impact Statement 

Chapter 3 – Roadless / Unroaded 

332

Inventoried Roadless Areas____________________________ 

Within the area planned for activities, there are no unroaded, Inventoried Roadless Areas, or wilderness 

areas as defined by Forest Service Manual 7712.16a “Contiguous Unroaded Areas.” The nearest 

Inventoried Roadless Area or Wilderness designation is at least 4 miles away. 

Unroaded Characteristics/Oregon Cascades Recreation 

Area _______________________________________________ 

The entire western boundary of the BLT analysis area abuts the Oregon Cascade Recreation Area 

(OCRA). The goal of this section of OCRA is to “conserve, protect, and manage in a substantially 

undeveloped condition.” The emphasis is to provide opportunity to enjoy scenic, wildlife, and 

recreational settings that is not dominated by human activities but where some motorized use could be 

permitted along with some recreation-related facilities. There would be no activities associated with 

BLT planned in this area. 

OCRA is mostly unroaded, except for motorized access provided by the Windigo Pass road from 

Crescent to Diamond Lake and a portion of a high clearance road that follows the Little Deschutes 

River through Cow Camp (5830-300). Roaded access terminating at the OCRA boundary surrounds 

the unroaded area throughout the BLT analysis area. There are no identified trails that originate from 

the boundary of the analysis area and OCRA. From a visitation standpoint, the area is likely considered 

secondary or incidental to other recreation locations and activities in the area. 

Alternative B and C (units 1085, 1135, 1175, 1180, 1181, 1260, and 1310) are on the boundary of 

OCRA. A total 218 acres would be harvested by tractor and with a prescription for lodgepole 

improvement (HIM) and 184 acres by advanced systems such as skyline or helicopter with a 

prescription for understory thinning (HTH). Approximately one-half mile of temporary would be 

needed in units 1085 and 1135. Both these units would be accessed 5825-835 and 5825-800, 

respectively. Temporary road construction would be used to facilitate economic timber harvest removal 

within the units themselves, as external access is already in place. 

Since there are no nearby trails or trailheads into the OCRA, it is unlikely adjacent harvest operations 

would affect OCRA visitors’ feelings of seclusion, remoteness, and solitude. In addition, unit 1135 

would be harvested during the winter when presence of visitors would likely be less than in the 

summertime. There would be some localized noise and dust associated with the harvest operation and 

log haul and the duration would be approximately one season. Risk of invasive plants would be limited 

to the area of disturbance; a discussion of risks associated with invasive plants species can be found in 

the section titled “Invasive Plants” in Chapter 3 of this EIS. 

The BLT project would not likely forego future designation as Wilderness as the analysis area is well 

roaded up to the boundary, and it does not create any permanent roads. Therefore, access to OCRA 

would not change. After the completion of all sale work, temporary roads would be rehabilitated by 

decompaction and those roads opened for harvest operations would be closed once again to vehicular 

traffic. For effects to wildlife, reference that section in this chapter for dependent species on habitat 

provided in OCRA. 

Oregon Wild provided a map of unroaded areas and Figure 3-31 displays proximity to BLT Activity 

units. Units 1200 and 1240 overlap Oregon Wild’s identified portion of an unroaded area that lays 

between two roads the parallel the Deschutes River and is attached to OCRA. Both units have 

experienced active management following the beetle infestation in the 1980s. The following Particular 
Environmental Impact Statement BLT Project

 Chapter 3 –Roadless / Unroaded 

333

values that may be provided by undeveloped or unroaded areas identified in the Roadless Conservation 

Rule as follows (Federal Register, Vol. 66, No. 9) were applied to these two units: 

• High quality Soil, water, and air: These would continue to be provided. Impacts to the soil 

resource are limited to the area of activity and are described in the soils section in Chapter 3. Soil 

productivity is maintained through project design features and post-activity subsoiling. No activity 

would occur within riparian reserves; therefore water quality would not be adversely affected. Air 

is protected by adhering to smoke management rules as described in Project Design Features listed 

in Chapter 2 and Air Quality in Chapter 3. 

• Sources of public drinking water: These areas are not sources of public drinking water. 

• Diversity of plant and animal communities: The diversity of plant and animal communities are not 

unique for the area. Diversity of vegetation is at risk of loss due to a wide-scale disturbance 

process. There is no Sensitive plant species within activity units. Effects to wildlife and botany are 

disclosed in Chapter 3. 

• Habitat for threatened, endangered, proposed, candidate, and sensitive species, and for those species 

dependent on large, undisturbed areas of land: these areas are not habitat for threatened, 

endangered, proposed, candidate and sensitive species. Effects to the Pacific fisher and other 

species dependent upon large, undisturbed areas of land are disclosed in the Threatened, 

Endangered, and Sensitive wildlife section in Chapter 3. Overall, the BLT project would improve 

future habitat conditions for the Pacific fisher. Viable Ecosystem outyear modeling was conducted 

to determine changes in suitable denning habitat acreage at 10 years, 20 years and 50 years for all 

alternatives. All alternatives showed an increase in suitable denning habitat acreage over each 

decade. 

• Primitive, semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of recreation 

opportunities: The recreation opportunities would remain the same. The area supports dispersed 

recreation that would not be changed by the project activities. 

• Reference landscapes: These two activity areas are located in a large landscape of similar 

characteristics of lodgepole flats, plant associates, and soils. 

• Landscape character and scenic integrity: The landscape character would be similar following 

treatments. Landscape level disturbance has already occurred and is still occurring with the 

mountain pine beetle outbreak. Tree mortality is evident from the high points and open canopies 

though snag fall down is apparent. Activities will create more ground disturbance, however. For 

more detail on vegetative prescriptions for these two units, and how the scenic integrity is affected, 

reference the Wild and Scenic section in Chapter 3. 

• Traditional cultural properties and sacred sites: There are no known cultural properties or sacred 

sites within the Oregon Wild-identified unroaded areas. If found during operations, they would be 

avoided (Cultural Resources, Chapter 3). 

• Other locally identified unique characteristics: The Landscape Analysis Process did not identify 

any locally unique characteristics to the adjacent unroaded areas in the BLT planning area. 
BLT Project Environmental Impact Statement 

Chapter 3 – Roadless / Unroaded 

334

R. 7 E. R. 8 E.

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Oregon Wild Unroaded AreaBLT Alternative-B_2_28_08RailroadBLT Project BoundaryState-BLM-County RoadsArterial RoadsCollector Roads

Figure 3-31. Oregon Wild Roadless Data and BLT Activity Units 
Environmental Impact Statement BLT Project

 Chapter 3 -Scenery 

335

Scenery Resources___________________________________ 

Existing Condition 

For the purposes of this analysis, the existing Forest Plan direction on scenic quality will be used. 

However, whenever possible, Scenic Integrity Objectives will also be displayed and discussed. Further 

direction regarding scenery management is found in Forest Service Manual 2380 (Landscape 

Management). 

The major scenic corridor in the BLT analysis area is along Highway 58 in close proximity to Odell 

Butte. This area is classified in the Deschutes Forest Plan as “Partial Retention Foreground” or a 

Scenic Integrity level “Slightly altered landscape with medium scenic integrity level.” The scenery in 

the BLT analysis area is undergoing a gradual but noticeable change. Previous regeneration harvest, 

fire exclusion, and mortality from insect and disease have caused the scenery to develop characteristics 

that do not represent the historic or expected appearance of central Oregon’s high desert forests. Since 

around the late 1990s and 2000, understory thinning projects are beginning to appear along the scenic 

views and change this trend. However, remaining in the foreground are landscapes where encroaching 

lodgepole into ponderosa pine stands around Odell Butte as seen from Highway 58, blocking views and 

preventing the development of large diameter trees which historically dominated these forests. Large 

trees make up a desired component of scenic quality and they likely represented a greater portion of the 

landscape in the past. Along the remaining portions of Highway 58 understory thinning of trees has 

opened the stands to allow filtered views of the larger trees and middle ground landscape. 

In stands of lodgepole pine, there are generally two types of forests as viewed from Highway 58. Both 

can be classified as mature and some forest visitors may perceive the landscape as unhealthy. One type 

has experienced bark beetle infestations in the 1990s and trees have died and fallen over with signs of 

wood cutting or salvage activity. The other could be characterized as dense, with sparse crowns and 

pockets of insect and disease, appearing near the end of a normal approximately 100-year cycle. 

On a larger landscape, large wildfires and other forest disturbance processes are especially visible and 

accessible to the forest visitor along major travel corridors. These include the Davis Fire (Highway 46), 

Road 18 and Bessie Butte Fires (Highway 97), Awbrey Hall Fire (Highway 46 near Bend), and the 

Skeleton Fire, B&B, Cache Mountain and Link Fires (Highway 20). These events tend to change the 

landscape character to “distinctive,” altering scenery to a degree that is perceived by many to have 

deviated from the landscape constituents valued for their aesthetic quality (that is, it no longer appears 

as natural, or whole). Landscapes are primarily viewed by two types of public: casual forest visitors 

who mainly are from outside the Central Oregon area, and local residents who tend to be more familiar 

with forest succession and processes. 

Table 3-101 displays the Scenic Views categories (by Visual Quality Objective or VQO) within the 

BLT analysis area. 

Table 3-101. Acres of Scenic Views Management Area by Visual Quality Objective in the BLT 

Analysis Area 

Visual Quality Objective Acres 

Partial Retention Foreground 2441 

Partial Retention Middle ground 994 

Total 3,435 
BLT Project Environmental Impact Statement 

Chapter 3 – Scenery 

336

Environmental Consequences 

Direct and Indirect Effects 

Alternative A 

The main potential for effects to the scenery resource is within the foreground area. The No Action 

alternative, or passive management scenario, would allow the current trend to continue. Along 

Highway 58 and Odell Butte, dense stands with large trees would continue to be at risk to a large-scale 

disturbance, blocking views into the stands as the understory develops. The current shift in stand 

composition from encroaching lodgepole into the ponderosa pine stands mask the appearance of large 

trees and delay fire tolerant cohorts by many decades. 

In lodgepole pine, although this relatively short-lived species evolves with disturbance process that 

reinitiate stand renewal approximately every century, the stands along Highway 58 in the visual 

corridor would continue to appear unhealthy to many visitors. 

This alternative has the greatest potential to alter scenery from what most visitors expect to see in 

central Oregon. 

Alternatives B, C, and D 

Prescriptions for the action alternatives are designed to thin the understory and retain the largest trees 

and healthiest-appearing crowns (Table 3-102 displays total treatment acres proposed by Visual Quality 

Objective). Table 3-103 displays the treatments proposed in more detail, showing the type of treatment 

in each VQO category. 

For understory thinning (HTH) within the immediate foreground in ponderosa pine, large yellowbarked overstory trees would dominate the views and compliment adjacent areas that have implemented 

similar vegetative treatments. Fifteen percent retention areas with younger trees would provide visual 

diversity. . 

Within the lodgepole pine stands and improvement harvest (HIM), stands that lack visual diversity 

would improve over time as younger trees regenerate from tree removal. Stands would appear healthier 

with fuller crowns (M-51), as most of the dominate trees most likely would remain. 

Activities would be noticeable along the foreground areas; however they have been designed to be 

subordinate to the larger landscape to be consistent with the standards and guidelines for scenery within 

the Deschutes Forest LRMP. Machinery has the potential to alter the texture of soils and make them 

more visible. Therefore, skid trails and landings would be designed to minimize visibility. Landings 

closer than 200 feet as viewed from the roadway would be approved on a case by case basis. Also, 

areas designed within units (15%) to retain a passive management scenario would allow for screening 

from the roadway. Slash would be handpiled within 150 feet of Highway 58 and disposed within two 

years. No marking paint, tags, ribbons, and boundary signs would be visible following project 

completion. Large diameter trees (24 inches and greater) would not be harvested unless they meet 

specific criteria related to forest health and public safety, as described in the Forest Plan. These 

measures have been used on the nearby Davis Fire Recovery Project as well as numerous other sales on 

the forest. They have proven to be highly effective and practical to implement. 

Table 3-102. Active management in Scenic Views by Acres 

Visual Quality Objective Alt. B Alt. C Alt. D 

Partial Retention Foreground 762 598 399 

Alternative B units: 200, 210, 260, 270, 285, 335, 350, 435, 455, 465, 516, 751 and 800. 

Alternative C: 200, 210, 260, 270, 285, 335, 350, 465, 751 and 800. 

Alternative D: 200, 260, 270, 335, 455, 751 and 800. 
Environmental Impact Statement BLT Project

 Chapter 3 -Scenery 

337

Table 3-103. Prescriptions in Foreground Retention by Acres 

Treatment Alt. B Alt. C Acres Alt. D 

Lodgepole Improvement (HIM) 477 391 253 

Understory Thinning (HTH) 285 207 146 

Fuels Treatments only 0 0 0 

Total 762 598 399 

Cumulative Effects 

The projects identified in Table 3-1 were reviewed for potential overlap in space and time within the 

BLT project. The zone of influence is the major travel corridors connected to the analysis area at key 

locations. All other relevant activities past and present with potential for additive effects have been 

incorporated into the existing condition and this section. 

The Air Timber Sale from the Seven Buttes Return was recently completed. Approximately 415 acres 

were implemented within the foreground. Along county Road 61, understory thinning highlighted the 

large ponderosa pines in the stand, opening up views of lava flows in the background. This sale is 

directly across the road from the Demo Butte project, which also highlighted the large trees, mainly 

consisting of ponderosa pine. Prescribed fire was returned into the stand along the roadway. For 

almost six miles west from the edge of Demo Butte until Highway 58, a roadside understory thinning 

project removed trees up to 6 inches in diameter within 300 feet of the roadway. 

North from the Road 61 and Highway 46 junction, the Air timber sale thinned dense areas of lodgepole 

pine and removed down material, also highlighting the largest trees that were on site. In addition, small 

diameter trees were thinned along the road side on 100 acres, nearly up to the boundary of the Davis 

Fire. For approximately five miles, the Davis Fire and salvage operations are evident. Across from 

Lava Flow campground is the Goose Timber Sale (Seven Buttes Return EA) which had an understory 

prescription very similar to those proposed in ponderosa pine along Odell Butte in the BLT project. 

BLT project actions would appear in-between existing thinning projects, complementing the work that 

has been accomplished. The result would be that large trees would be more visible and the landscape 

would appear more similar to the historic landscape than it did in the 1990s, except within the Davis 

Fire perimeter. In the Davis Fire, much of the remaining trees that appeared live a few years ago after 

the fire are now dead. As shrubs, grasses, and tree seedlings return to the wildfire area, and dead trees 

fall, the stark contrast between live and dead stands would soften. 

Consistency with the Forest Plan 

All activities planned in Alternatives B, C, and D are consistent with Goals, Objectives, and Standards 

and Guidelines in the Deschutes National Forest Plan because: 

In Foreground areas, visible results of active management would not be noticeable to the casual forest 

visitor within two years in Partial Retention (Medium Scenic Integrity). The greatest potential for 

change would be on Highway 58 near Odell Butte in the ponderosa pine where vegetative prescriptions 

would be characterized as understory thinning, favoring the largest diameter trees and the healthiest 

crowns and forms (M9-6). Mitigation measures to comply with M9-12 and M9-58 (for Partial 

Retention) include handpiling and disposal of tops and limbs within two years, and measures to 

minimize evidence of management activities such as marking guidelines that are discreet from viewer 

locations. Measures such as these have been successfully implemented for activities along sensitive 

viewer locations such as the Charlie Brown project and the Davis Fire Recovery EIS and have proven 

to be successful. 
BLT Project Environmental Impact Statement 

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338

Consistency with the Forest Plan 

All activities planned in Alternatives B, C, and D are consistent with Goals, Objectives, and Standards 

and Guidelines in the Deschutes National Forest Plan because in Retention areas, visible results of 

active management would not be noticeable to the casual forest visitor within one year in Retention 

Foreground (High Scenic Integrity) and two years in Partial Retention (Medium Scenic Integrity). The 

greatest potential for change would be on Highway 58, the National Scenic Byway, in units 250, and 

265. The vegetative prescription for these units would be characterized as understory thinning, favoring 

the largest diameter trees and the healthiest crowns and forms (M9-6). Mixed conifer stands would be 

managed to perpetuate and enhance the characteristic landscape (M9-20). Mitigation measures to 

comply with M9-8 and M9-9 (for Partial Retention) include handpiling and disposal of tops and limbs 

within one year, and measures to minimize evidence of management activities such as marking 

guidelines that are discreet from viewer locations. Measures such as these have been successfully 

implemented for activities along sensitive viewer locations such as the Charlie Brown project and the 

Davis Fire Recovery EIS and have proven to be successful. These actions have been reviewed by a 

landscape architect. 
Environmental Impact Statement BLT Project

 Chapter 3 – Public Health andSafety 

339

Public Health and Safety _______________________________ 

Public and Worker Safety 

Under each action alternative, danger trees would be removed from along all haul routes. The signing of 

project activity areas in addition to notification of additional project-related traffic would promote a safe 

environment for forest visitors during project implementation. 

Implementation of action alternatives would increase the potential for encounters on roadways between 

forest visitors and equipment associated with harvest. This elevated level of risk would be present for the 

short-term (approximately 5 years). Safety measures such as informational signing, flaggers, and road 

maintenance activities, such as brushing roads for increased visibility, would be enforced in the timber 

sale contract. 

The work environment during all phases of logging operations would be physically demanding and 

hazardous; effects to worker health and safety would be possible. Activities with the highest potential for 

serious injury would include tree felling and helicopter operations. All project activities carried out by 

Forest Service and Forest Service contract employees would comply with State and Federal Occupational 

Safety and Health Administration (OSHA) standards. All Forest Service project operations would be 

consistent with Forest Service Handbook 6709.11 (Health and Safety Code) 

The Clean Air Act lists 189 hazardous air pollutants to be regulated. Some components of smoke, such as 

polycyclic aromic hydrocarbons (PAH) are known to be carcinogenic. Probably the most carcinogenic 

component is benzo-a-pyrene (BaP). Other components, such as aldehydes, are acute irritants. In 1994 

and 1997,34 air toxins were assessed relative to the exposure of humans to smoke from prescribed and 

wildfires. The five toxins most commonly found in prescribed fire smoke were: 

Particulate matter - Particulates are the most prevalent air pollutant from fires, and are of the most 

concern to regulators. Research indicates a correlation between hospitalizations for respiratory problems 

and high concentrations of fine particulates (PM2.5, fine particles that are 2.5 microns in diameter or 

less). Particulates can carry carcinogens and other toxic compounds. Overexposure to particulates can 

cause irritation of mucous membranes, decreased lung capacity, and impaired lung function. 

Acrolein - An aldehyde with a piercing, choking odor. Exposure severely irritates the eyes and upper 

respiratory tract. 

Formaldehyde - Low-level exposure can cause irritation of the eyes, nose and throat. Long-term 

exposure is associated with nasal cancer. 

Carbon Monoxide - CO reduces the oxygen carrying capacity of the blood, a reversible effect. Low 

exposures can cause loss of time awareness, motor skills, and mental acuity. Also, exposure can lead to 

heart attack, especially for persons with heart disease. High exposures can lead to death due to lack of 

oxygen. 

Benzene - Benzene causes headache, dizziness, nausea and breathing difficulties, as well as being a 

potent carcinogen. Long-term exposure can cause anemia, liver and kidney damage, and cancer. 

The closest Designated Area to the analysis area is the city of Bend, Oregon; the communities of 

Crescent, Chemult, Sunriver, and La Pine are closer to the analysis area but are not as highly populated. 

 

34 Results of an April 1997 conference to review the results of health studies and develop a risk management plan 

for the protection of fire crews were published by Missoula Technology Development Center in Health Hazards of 

Smoke, Technical Report 9751-2836-MTDC. 
BLT Project Environmental Impact Statement 

Chapter 3 - Public Health and Safety 

340

The greatest risk of exposure to airborne toxins from prescribed fires or wildfires would be to firefighters 

and forest workers implementing the prescribed burning. It is unlikely the general public would be 

exposed to toxin levels adverse to human health during implementation of prescribed burning operations 

in the BLT analysis area because of the distance from populated areas and the application of prescriptions 

designed to lessen the release of particulate matter. People who suffer from breathing ailments may 

experience some difficulty during periods of prescribed burning, especially during atmospheric conditions 

that do not favor dispersion of smoke. The Forest Service voluntarily follows the guidelines assigned by 

Oregon Smoke Management to limit state-wide exposure on a cumulative basis, in compliance with the 

Clean Air Act. 

Forest workers and firefighters can face unhealthy levels of smoke when patrolling or holding fire lines 

on the downward edge of a wildfire or prescribed fire, or while mopping intense hot spots. In most cases, 

measures such as education on the effects of short and long term exposure, rotation out of the smoke, and 

the use of respirators can reduce exposure levels. OSHA regulates exposure to hazardous materials in the 

workplace. All project activities carried out by Forest Service and Forest Service contract employees 

would comply with State and Federal OSHA standards. 
Environmental Impact Statement BLT Project

 Chapter 3 – Economic and Social Analysis 

341

Economic and Social Analysis _________________________ 

Social and economic elements, which are interrelated and interdependent with ecological elements, 

comprise the human dimension of component of the ecosystem. 

The implications of resource management decisions for the BLT Project to the social and economic 

uses and values are of interest to residents of the area and users of the area. These people have made 

their interests known through organized groups and personal efforts. It is these interests, issues and 

concerns that have helped formulate the purpose and need for action and identify the issues connected 

with achieving the purpose and need elements discussed in Chapter 1. 

This section will focus on: 

1. A review of the social and economic conditions of Klamath County Oregon, using census and 

other sources of data. 

2. A review of the key social and economic relations between the communities and the uses and 

services provided by the Federal lands in the BLT analysis area. 

3. A discussion about how the alternatives affect conditions, relationships and values of 

community members. 

General Social and Economic Features 

The primary area of consideration is Klamath County, Oregon. A small part of the Crescent Ranger 

District is located in Deschutes County. The Klamath or “Clamitte” tribe of Indians, for which Klamath 

County was named, has had a presence in the area for 10,000 years. White settlement began in 1846 

along the Applegate Trail, which precipitated clashes between the Klamath Indians and the White 

settlers and culminated in the Modoc War of 1872. The Legislative Assembly created Klamath County 

on October 17, 1882. Linkville, later known as Klamath Falls, was named the county seat. 

More white settlers were drawn to the area in the early 1900s with the coming of the railroad and the 

heavily taxpayer-subsidized creation of the Klamath Irrigation Project, a Federal reclamation project. It 

drained much of the Lower Klamath Lake and Tule Lake to convert 188,000 acres of lakebed and 

wetland to irrigated farmland. 

Population 

According to the US Census 2006 estimate, the population of Klamath County is 66,438. The county 

covers an area of 6,136 square miles; the population density is currently 11 persons per square mile. 

The population growth of the county compared to the state, according the Bureau of Economic Analysis 

Regional Economic Information System (BEA REIS 2005) Table CA30, was 31 percent from 1970 to 

2005. County population growth did not keep pace with state and national growth. 

Age distribution for Klamath County, was in the 40 to 54 age bracket (Baby Boom in 2000) and it grew 

the most from 1990 to 2000. The percentage of young people under 20 declined slightly, while the 

percentage of people 65 years and older increased slightly. 

By far, whites are the most numerous ethnic group. Next are Hispanic at 7.8 percent of the population 

followed by a little over 4 percent American Indian and Alaska Native. 

Economic Conditions 

Historically, Klamath County has devoted its economic base to farming, timber, and wood products 

manufacturing. Although these industries currently provide a smaller contribution to the county’s 
BLT Project Environmental Impact Statement 

Chapter 3 Economic and Social Analysis 

342

current economic activity than they once did; they are still important in community identity and local 

politics. 

The largest employer in the area is Sky Lakes Medical Center; however, few or no residents of Crescent 

or Gilchrest are employed there. In Klamath County, the Medical Center is followed by Klamath 

County School District and Jeld-Wen, a company that manufactures windows and doors. During the 

past few years, the county has experienced a housing construction boom. The area is attractive to 

retirees from more densely populated areas of California. Recreation – including fishing, hunting, and 

hiking – contribute to the appeal of the area and its economy. Crater Lake National Park, which attracts 

approximately half a million visitors a year, also contributes to the local economy. The area is also 

famous for bird watching. 

Employment 

From 2001 to 2006, total employment in Klamath County increased from 32,576 jobs to 35,441 jobs. 

The principal industrial sectors in Klamath County remain the same. They are government and 

government enterprises. The second largest is retail trade. This is followed by health care and social 

assistance. Between 2001 and 2006, government and government enterprises lost a few jobs, while 

retail trade gained more than 200 jobs. The health care and social assistance sector gained more than 

700 jobs. Other important employment sectors in Klamath County are the manufacturing, 

accommodation, and food services sector, farm employment, and construction. A major change over 

the five years from 2001 to 2006 was the decline in jobs in the forestry, fishing, and related activities 

sector. This sector declined by 17 percent to 628 jobs. 

Table 3-104. Klamath County Employment 

Full and Part-time 

Employment by Year 

2001 2004 2006 

Total employment 32,576 33,219 35,441 

 Farm employment 2,038 2,078 2,065 

 Nonfarm employment 30,538 31,141 33,376 

 Forestry, fishing, related activities, other 1/ 755 741 628 

 Mining 1/ 14 30 78 

 Utilities 92 121 122 

 Construction 1,933 1,706 2,213 

 Manufacturing 2,740 2,754 2,872 

 Wholesale trade 769 788 919 

 Retail trade 3,983 3,974 4,198 

 Transportation and warehousing 1,015 972 1,060 

 Finance and insurance 919 1,256 869 

 Real estate and rental and leasing 1,151 1,182 1,435 

 Professional and technical services 1/ 1,036 1,036 1,073 

 Management of companies and enterprises 1/ 1,213 722 1,121 

 Administrative and waste services 1/ 284 1,047 1,700 

 Health care and social assistance 3,216 3,777 3,998 

 Accommodation and food services 2,508 2,448 2,744 

 Other services, except public administration 1,812 1,917 2,072 

 Government and government enterprises 5,547 5,561 5,451 

1/ Some undisclosed REIS data are estimated using IMPLAN data. These data are indicated by bold italics. 

Source: Regional Economic Information System, Bureau of Economic Analysis (BEA REIS), U.S. Department of 

Commerce (Table CA25 NAICS). 
Environmental Impact Statement BLT Project

 Chapter 3 – Economic and Social Analysis 

343

The poverty rate for Klamath County is higher than that of the state. Approximately 17 percent of 

individuals had income that was below the poverty line in 1999. The percentage in Oregon as a whole 

was 12 percent. 

From 1970 to 2005, average earnings per job, adjusted for inflation, have fallen from $35,154 in 1970 

to $32,816 in 2005. In 2005, average earnings per job in Klamath County, Oregon ($32,816) were 

lower than the state ($41,152) and the nation ($45,817). 

Per capita income, adjusted for inflation, has risen from $19,193 in 1970 to $25,997 in 2005. Average 

per capita income in the county was $25,997. That is lower than the state average of $32,289 and the 

national average of $34,471 in 2005. 

In the last 35 years, non-labor sources of income grew at an annual rate of 3.6 percent, outpacing labor 

sources which grew at a 0.8 percent rate. In 2005, 42.6 percent of total personal income was from nonlabor sources. These sources include dividends, interest, and rent as well as transfer payments from 

governments to individuals, such as Medicare, Social Security, unemployment, and disability insurance. 

From 1970 to 2005, 69.1 percent of new income was from non-labor sources. 

The largest components of non-labor income are from dividends, interest, and rent. In 2005, welfare 

represented 8.8 percent of transfer payments and 2.1 percent of total personal income. 

In 2006, the unemployment rate was 6.8 percent compared to 5.4 percent in the state and 4.6 percent in 

the nation. Since 1990, the unemployment rate varied from a low of 6.8 percent in 2006 to a high of 

10.4 percent in 1993. Monthly unemployment rates are higher in the winter compared to the summer. 

Unemployment Rate

6.8

5.4

4.6

0

2

4

6

8

10

12

1988

1990

1992

1994

1996

1998

2000

2002

2004

2006

Percent

Klamath County, OR Oregon United States

Figure 3-32. Annual Average Unemployment Rate Compared to the State and the Nation 
BLT Project Environmental Impact Statement 

Chapter 3 Economic and Social Analysis 

344

Primary Uses of Forest Lands 

Timber Harvest 

Timber harvesting has been a key use of forests in Klamath County. Production in the 1980s was 

nearly half a billion board feet per year. For example, in 1986, a total of 462 million board feet were 

harvested. Of that, 281 million board feet, about 61 percent, was harvested from Forest Service land. 

During the 1990s harvest levels declined sharply. In 2006, approximately 152 million board feet were 

harvested in Klamath County. Of that total, 29 million board feet, or 19 percent, was harvested from 

Forest Service land. 

Table 3-105. Volume Removed in 1,000s of Board Feed (Scribner Log Scale) 

Year 

Forest 

Industry 

Other 

Private 

Native 

American State BLM USFS Other Public TOTALS 

2001 185,329 3,173 0 9,344 619 13,665 0 212,130 

2002 168,420 1,528 0 12,594 4,390 20,761 0 207,693 

2003 144,443 2,447 0 82 7,303 44,394 0 198,669 

2004 109,437 5,147 0 13,256 6,229 37,126 20 171,215 

2005 107,375 15,668 0 17,115 7,632 42,483 0 190,273 

2006 98,648 5,913 0 5,939 12,384 29,673 0 152,557 

Source: Oregon Department of Forestry http://www.oregon.gov/ODF/index.shtml

Klamath Falls has two mills that process logs. One is Thomas Lumber, which produces lumber for 

Jeld-Wen, the manufacturer of windows and doors; the other produces dimensional lumber. Timber cut 

from the Crescent and Chemult Ranger Districts is rarely or never sent to the dimensional lumber mill 

in Klamath Falls. The closest mill to Crescent and Chemult is Interfor Pacific in Gilchrist. That mill is 

temporarily running on limited operation, in large part, to market conditions. Wood from the Crescent 

and Chemult Ranger Districts is also sent to two mills in John Day, a dimensional mill for pine in 

Warm Springs, and two mills in White City/Medford and Roseburg. There are some small 

manufacturing mills that produce windows and doors in Prineville and Redmond. There is also a small 

molding mill in the town of Crescent that employs about 10 people. It is dependent on byproduct from 

the local mill. 

Non-timber Forest Products 

Grier and others (1989) point out those investments in forest stands should not be based solely on net 

primary aboveground productivity. Sites yielding products with disproportionately high economic value 

per unit of biomass may in the long run be advantageous to manage, and may garner broad public 

support for intensified management as well. Both forest incomes and forest structure can be maintained. 

Mixing crops with different harvest intervals also helps to even out flows of income at the stand scale. 

Stand-level even flow of resource benefits is a fundamentally different notion from even flow of timber 

income from annual harvesting of a fixed percentage of a forest landscape. Nearly annual crops of wild 

mushrooms, of triennial boughs crops, decadal crops of Christmas trees, and partial timber cuts every 

25 to 50 years may extract commercial biomass at a higher average annual rate than intensive 

management of a single timber crop. Investing in an array of valuable crops, such as high-quality 

western white pine timber and matsutake mushrooms, with long histories of consumer demand globally, 

cushions uncertainty about future markets and management costs (Weigand, 1998). 

The American matsutake mushroom is a valuable commercial non-timber forest product that grows on 

the Crescent and Chemult Ranger Districts. The districts have some of the best matsutake habitat in the 

United States. Experts estimate that as much as 60 percent and as little as 20 percent of the most 

productive matsutake habitat in the United States is on Forest Service land in the southern Cascades. 

(Personal communication, Andy Moore 2008). 
Environmental Impact Statement BLT Project

 Chapter 3 – Economic and Social Analysis 

345

The matsutake harvest community is large and well-organized. Most of the matsutake harvesters were 

born in Southeast Asia. They come from different ethnic and linguistic backgrounds, including, 

Laotian, Hmong, Mian, and Cambodian. Most were born in Cambodia, Laos, Thailand and Burma. 

They now spend most of the year living in various towns in the western United States. A large group of 

the harvesters live in Olympia, Richmond, and Tacoma, Washington. Others live in Stockton, 

California. Some come from as far away as Lynn and Woster, Massachusetts, and Richmond Virginia. 

A few of the harvesters are Caucasian and a few are Mexican. 

About 1,000 harvesters come to the southern Cascades annually to pick mushroom during the season, 

which runs from September to November. Some of the Asians have experience picking mushrooms in 

their birth countries, others do not. The harvesters camp on the Chemult and Crescent Ranger Districts. 

Some camp in their recreational vehicles, others set up tents in the camp sites for $100 per season. On 

the Crescent Ranger District, the camp is divided into two “towns”. One is made up of Hmong and 

Mian people and the other is Laotian and Thai. 

Despite the language barrier, the harvesting community has been vocal in their concerns that 

disturbance to the soil or activities that open the tree canopy could reduce either matsutake habitat or 

productivity. Project Design Features for all action alternatives and Alternative D (specifically) was 

designed to address these concerns. Chapter 1 displays stakeholder collaboration. 

While most of the harvesters have other jobs during the months that they are not harvesting mushrooms, 

the cash that they earn during the mushroom harvest is an important component to their household 

economies. Anecdotal evidence suggests that matsutake harvesters earn about $200 on an average day. 

On a good day, a harvester may earn as much as $400; on a bad day, they earn as little as $60. For 

example, one harvester earned between $7,500 and $8,000 on an average season. 

Recreation 

Recreation – including fishing, hunting, and hiking – adds to the appeal of the area and its economy. 

Crater Lake National Park, which has approximately half a million visitors a year, contributes to the 

local economy. The area is also famous for bird watching. 

Effects of the Alternatives 

Proposed management scenarios assume that society’s interests in public forests are best served by 

maintaining stand structure and biological diversity as well as by even flows of forest products through 

time. This analysis deals with many variables in the economy, in project design and implementation, 

and in the social responses of diverse publics. The analysis strives to estimate the effects as accurately 

as possible using the best available data, making reasoned assumptions and focusing the analysis on key 

components. The issue of absolute accuracy does not affect the utility of this analysis since the 

alternatives are all developed, analyzed, and compared in the same manner. 

The following section includes discussions of both social and economic impacts as well as economic 

efficiency. Both impact analysis and efficiency analysis are important to trade-off assessment. Impact 

analysis addresses the distribution of costs and benefits. It identifies who gets how much of what and 

who pays the cost. This includes the distribution of jobs and income resulting from goods and services 

produced by each alternative, impacts to businesses, and changes to social variables. These 

distributional costs and benefits can be described in monetary, or other quantitative and qualitative 

measures. 

Efficiency is about the cost of producing or doing something and comparing that cost to the resulting 

change in values. Typical measures include benefit cost rations, present net value, and cost per unit 

output. Such measures are useful to determine if timber sale projects are below or above cost or if 

annual road maintenance expenditures are generating an equal value in use benefits. Not all efficiency 
BLT Project Environmental Impact Statement 

Chapter 3 Economic and Social Analysis 

346

measures can or need to be expressed monetarily. Other quantitative and qualitative measures are also 

useful. 

Social and Economic Effects 

The social and economic effects are evaluated using several indicators, including harvest volume, jobs, 

income, and potential for reduced matsutake harvest, and physical and social environmental health (e.g. 

environmental justice). 

The effects of each alternative on social values associated with different lifestyles are estimated from 

the standpoint of how different components of the local population may perceive the goals, objectives 

and management activities associate with each alternative. 

The purpose and need for this project includes contributions to local and regional economies by 

providing timber and other wood fiber products. Alternative B produces the most timber volume, 

approximately 12 million board feet. Alternative C produces nearly 10 million board feet; and, 

Alternative D produces about 5 million board feet. Timber industry response coefficients and timber 

related job estimates were produced using state-wide estimates based on log consumption by industry, 

employment and labor income for 1998 (Gebert, Krista M et al., Utilization of Oregon’s Timber 

Harvest and Associated Direct Economic Effects, 1998, PNW-GTR-532). According to the 

calculations using a sawmill job’s response of 4 jobs per million board feet, Alternative B would 

produce 91 jobs, that is more than the other alternatives. Alternative C would produce 74 jobs; and 

Alternative D would produce 39 jobs. Alternative A would not produce any jobs related to the timber 

industry. 

Table 3-106. Potential Jobs in the Timber Industry Created by the BLT 

Timber Industry 

Response 

Coefficients ** 

Alt B Alt C Alt D 

Jobs/MMBF Volume Jobs Volume Jobs Volume Jobs 

Logging (749 MMCF) 3.5 12,099 43 9,800 35 5200 18 

Sawmills 4.0 8,471 34 6,861 28 3,639 15 

Reconstituted 4.0 3,628 15 2,939 12 1561 6 

Total 91 74 39 

Table 3-107. Klamath County Employment in the Timber industry 

Klamath 

Employment 

2006 

Alt B Alt C Alt D 

Logging 281 15% 12% 7% 

Sawmills 191 18% 14% 8% 

Reconstituted 479 3% 2% 1% 
Environmental Impact Statement BLT Project

 Chapter 3 – Economic and Social Analysis 

347

Table 3-108. Cash Flow Analysis by Alternative 

Alt A Alt B Alt C Alt D 

Volume (MBF) 0 12,099 9,800 5,200 

Purchaser Predicted High Bid $53.99 $52.01 $57.07 

 Total Receipts to the FS $653,218 $509,746 $296,781 

FS Timber Harvest Activity Costs 

 Sale Preparation 19 19 19 

 Sale Administration 10.01 10.01 10.01 

Total FS Timber Harvest Activity Costs $350,992 $284,298 $150,852 

Net Value of Timber Harvest Activity $302,226 $225,448 $145,929 

Non-essential KV 

 Subsoiling $62,422 $47,318 $14,042 

 Prescribed Burning $346,800 $264,600 $123,600 

 Small Tree Thinning $442,441 $268,352 $121,644 

Total Non-essential KV $851,663 $580,270 $259,286 

Net Value of Total Project -$549,437 

-

$354,822 -$113,357 

Planning Costs 

NEPA per MBF $21.00 $21.00 $21.00 $21.00 

Transportation per MBF $19.85 $19.85 $19.85 $19.85 

Total Planning Costs $494,244 $494,244 $494,244 $494,244 

Table 3-109. Volume of Wood in Thousand Board Feet 

Total Fiber Saw 

Alt B 12,099 3,628 8,471 

Alt C 9,800 2,939 6,861 

Alt D 5,200 1,561 3,639 

Related to effects associated with matsutake harvest, little is known of the effects of silvicultural 

treatments on matsutake habitat and mushroom production. Lack of good baseline data, i.e. historical 

and current abundance of the fungal mycelium as well as sporocarps (mushrooms) and its potential 

habitat make it difficult to assess the precise effects of actions on habitat, fungal populations, or 

mushroom production. The fungal mycelia are persistent below ground, while the mushrooms only 

appear for a limited seasonal period, and do not necessarily reappear at all sites in all years. 

Assessing the effects of any of the treatment alternatives on matsutake fungus abundance and 

mushroom production is difficult and speculative because of the lack of direct evidence of current 

fungal abundance and mushroom production potential. 

Using the ranges for canopy cover class by plant association group where potential matsutake 

production occurs, Alternative B would have an approximate 1,120 acre net shift toward less productive 

habitat, followed by Alternatives C and D (859 and 352 acres) respectively. Alternative C would have 

an approximate 859 acre net shift toward less productive habitat (Chapter 3, Special Concern Plants). 

While this may directly overlap an area harvesters may traditionally pick, the Deciding Official made 

several efforts to remove those areas identified as the most productive (Chapter 2, Public Participation). 

Based on site-specific and modeled data, the BLT planning area currently contains approximately 

54,122 acres (71 percent) of potential matsutake habitat. As a subset of potential habitat, 39,325 acres 
BLT Project Environmental Impact Statement 

Chapter 3 Economic and Social Analysis 

348

(51 percent) is currently “Good” habitat, 12,837 acres (17 percent) can “Grow” to good habitat, and 

1960 acres (3 percent) can be “Thinned” to good habitat. If there is a net shift of less production 

compared to acres considered “good habitat”, Alternative B would potentially affect 8.7 percent (or 2.0 

percent of the total habitat), followed by 6.7 percent in Alternative C (or 1.5 percent of total habitat), 

and 2.7 in Alternative C (or 0.7 percent of total habitat). 

Although matsutake production recovery might occur as soon as 2 years or as many as 6 years or more 

following treatment depending on Plant Association Group and original quality of habitat, worst case 

scenario in Alternative B would retain over 91 percent of picking areas categorized considered as “good 

habitat” in the Upper Little Deschutes Watershed/BLT analysis area. This does not include the picking 

area surrounding Crescent Lake/Windigo Pass area, which is outside the analysis area. 
Environmental Impact Statement BLT Project

 Chapter 3 – Environmetal Justice 

349

Environmental Justice and Civil Rights Impact Analysis ____ 

Executive Order 12898 of February 11, 1994 requires that each Federal agency “shall make achieving 

environmental justice part of its mission by identifying and addressing... disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on minority and 

low-income populations.” 

In order to identify and address environmental justice concerns, the EO states that each agency shall 

analyze the environmental effects, including human health, economic, and social effects of Federal 

actions, including effects on minority populations, low-income populations, and native Americans as 

part of the NEPA process. 

Two distinct populations fall into the categories identified by EO 12898. One population is the 

harvesters, most of whom are members of the Asian minority. In Environmental Justice analyses, 

Census data is often used to illustrate the percentage of the population that belongs to an ethnic 

minority in the study area. Data usually comes from sources similar to those presented in the Social 

and Economic section. 

Although most of the matsutake harvesters are members of the Southeast Asia minority, they are not 

counted in Census data for the study area, because they spend much of the year in places such as 

Olympia, Richmond, and Tacoma, Washington. Others spend their time in Stockton, California. Some 

come from as far away as Lynn and Woster, Massachusetts, and Richmond Virginia. Therefore, 

quantitative data on the ethnic composition of the harvester community is not available. However, 

there is strong anecdotal, qualitative data showing that a majority of the harvesters are Southeast Asian. 

The other population in the study area that falls into the category identified by EO 12898 is the group of 

low-income, permanent residents of Klamath County who are mostly White and considered a lowincome population. The poverty rate for Klamath County is 5 percent higher than that of the state. 

Approximately 17 percent of individuals had income that was below the poverty line in 1999. The 

percentage in Oregon as a whole was 12 percent. 

The EO requires that each Federal agency must also provide for effective participation of the minority 

groups in the NEPA process. Providing for effective participation requires innovative approaches. 

Because mushroom harvesters are of several different Asian ethnic and linguistic backgrounds, signs 

informing harvesters of meetings were posted in several different languages. Field rangers also 

informed harvesters of meetings. Translators also assisted with communication at most of the dozen 

public scoping meetings that were held prior to the release of the BLT proposed action and more than 

three dozen scoping meetings after site specific actions were presented to the public (Table 2-1, Public 

Involvement). These translators helped overcome not only the linguistic, but also the cultural and 

institutional barriers that otherwise may have interfered with their participation in the NEPA process. 

In addition, public meeting were often held late in the evenings after the harvesters had finished their 

long days of work. In addition, the members of the BLT ID Team also traveled to Stockton, California, 

to visit the harvesters in one of home communities to better understand their culture and their input for 

the BLT Project. 

 

Development of the BLT Project has been conducted under Departmental Regulation 5600-2, 

December 15, 1997, and the Council on Environmental Quality’s Environmental Justice – Guidance 

Under the National Environmental Policy Act. The proposed action, its purpose and need and potential 

effects have been clearly described, and as mentioned above, scoping under the National Environmental 

Policy Act employed a variety of approaches to involve citizens, including those identified by the 
BLT Project Environmental Impact Statement 

Chapter 3 Environmental Justice 

350

Executive Order, in the planning process. This included on-going consultation with members of the 

Asian harvester community. 

 

Environmental Consequences 

Alternative A – No Action 

This alternative would continue the local economic situation as described in the section titled 

“Economic and Social Analysis” in Chapter 3 of this EIS. Opportunities for employment of minority 

and low-income workers may arise through contract activities for various forest work, such as annual 

thinning, conifer planting, and various small business contracts related to work outside the BLT area, 

but there are no known disproportionately high effects to any ethnic minorities, people with disabilities, 

and low-income groups. 

Effects Common to all Action Alternatives 

Alternatives B, C, and D may have some adverse impacts on both the Asian matsutake harvester 

community and the White low-income populations of Klamath County. Research shows that vegetation 

management and fuels treatments have the potential to affect matsutake growing condition in the shortterm by changing micro-climates as tree canopies are reduced. Also, as mentioned in the issues 

statements, soil biota important for mushroom production uses a complex symbiotic relationship in an 

environment that does not tolerate soil disturbance well. In sum, timber harvesting practices may have 

a negative impact on the production of matsutake mushrooms. Botanists predict that recovery of the 

matsutake production to pre-treatment conditions will take between 2 and 6 years in most of the area, 

and up to 10 years dependent upon the Plant Association Group and site-specific conditions. 

Based on site-specific and modeled data, the BLT planning area currently contains approximately 

54,122 acres (71 percent) of potential matsutake habitat. As a subset of potential habitat, 39,325 acres 

(51 percent) is currently “Good” habitat, 12,837 acres (17 percent) can “Grow” to good habitat, and 

1960 acres (3 percent) can be “Thinned” to good habitat. If there is a net shift of less production 

compared to acres considered “good habitat”, Alternative B would potentially affect 8.7 percent (or 2.0 

percent of the total habitat), followed by 6.7 percent in Alternative C (or 1.5 percent of total habitat), 

and 2.7 in Alternative C (or 0.7 percent of total habitat). 

Mitigation Measures were incorporated into all action alternatives to address concerns for affect to 

matsutake production. These are: 

 In units where matsutake mushrooms have been determined, or are suspected to be present, 

tractor skidding and mechanized felling shall be on frozen ground or with sufficient snow depth 

as determined by the Forest Service except for units 770 and 785 which overlap the Beals Butte 

groomed snowmobile trail. This applies to tractor units and advanced systems, if mechanized 

felling is used. This mitigation shall be incorporated in the following units: 

a. Alternative B: 125, 195, 200, 210, 245, 265, 270, 285, 300, 310, 311, 312, 315, 

316, 320, 335, 340, 410, 460, 525, 820, 835, 845, 915, 1035, 1100 and 1135. 

b. Alternative C: 125, 195, 200, 210, 245, 265, 270, 300, 315, 316, 320, 335, 340, 

525, 835, 845, 915, 1035, 1100, and 1135. 

c. Alternative D: 125, 195, 200, 265, 270, 300, 315, 316, 335, 340, 410, 525, 820, 

and 845. 

 In all other units, when possible, operate equipment over frozen ground or a sufficient amount 

of compacted snow to protect mineral soil. Equipment operations should be discontinued when 

frozen ground begins to thaw or when there is too little compacted snow and equipment begins 

to cause soil-puddling damage (rutting). 
Environmental Impact Statement BLT Project

 Chapter 3 – Environmetal Justice 

351

• Prevent additional soil impacts in random locations of activity areas, between skid trails and 

away from landings, by machine piling and burning logging slash on existing log landings and 

skid trails that already have detrimental soil conditions. Machine piling equipment must stay 

on existing skid trails and landings. 

• Restrict grapple skidders to designated areas (i.e., roads, landings, designated skid trails) at all 

times, and limit the amount of traffic from other specialized equipment off designated areas. 

The use of harvester machines will be authorized to make no more than two equipment passes 

on any site-specific area to accumulate materials. 

• In "fuels only units", restrict mechanical equipment to existing areas considered in a 

detrimental condition such as skid trails and landings. 

a. Alternative B: 45, 80, 115, 620, and 940 

b. Alternative C: 45, 80, 115, 620, and 940 

c. Alternative D: 45, 80, and 115 

Civil Rights Impact Analysis 

The project alternatives, given the size of potential social and economic effects, are not likely to result 

in civil rights impacts to Forest Service employees or customers of its programs. 
BLT Project Environmental Impact Statement 

Chapter 3 - Air Quality 

352

Air Quality and the Clean Air Act_________________________ 

Smoke produced from wildland or prescribed fires can have significant effects on a large urban landscape. 

Approximately 75,000 people live in the surrounding communities. Many of the residents in the area live 

in the large city of Bend, or small towns such as Sunriver, La Pine, Crescent, Gilchrist, and Crescent Lake 

Junction; however, a significant percentage of the populations live in the wildland/urban interface 

surrounding these cities and towns. 

The Clean Air Act prescribes air quality to be regulated by each individual state. Areas affected are 

called “attainment areas”. The BLT analysis area is considered to be in attainment of the National 

Ambient Air Quality Standards (NAAQS) for Class II airsheds. 

Class 1 

The Oregon Smoke Management Plan (OAR 629-043-0043) considers Diamond Peak wilderness as a 

Class 1 airshed. Class 1 areas are protected by the PSD (Prevention of Significant Deterioration) 

program and include national parks, national wilderness areas, national monuments, national seashores, 

and other areas of special national or regional natural, recreational, scenic, or historic values. These are 

considered “smoke sensitive” and require restrictions on prescribed burning accordingly during the 

Visibility Protection Period July 1 to September 15. 

Class II Airshed 

Class 2 areas are attainment areas that are neither industrialized nor meet the specific requirements for 

classification as Class I areas. They are protected by the PSD program. The BLT analysis area is a Class 

2 area. 

Designated Areas 

Designated areas are those areas identified as principal population centers or other areas of requiring 

protection under state or Federal air quality laws or regulations. The BLT analysis area is located 

approximately 35 miles southwest of Bend, Oregon. Bend is classified as a “Designated Area” by the 

Oregon Smoke Management Report. The analysis area is considered to be in attainment of the National 

Ambient Air Quality Standards (NAAQS) for Class II airsheds. 

Direct and Indirect Effects 

Alternative A 

Although this alternative would not have any activity-generated smoke emission, it carries the highest 

likelihood for a wildfire with a “Problem Fire” scenario. Table 3-110 illustrates that emissions and 

subsequent effect to air quality from a wildfire such as the recent Davis Fire are far greater than through 

management actions prescribed in Alternatives B through D. 

Alternatives B, C, D and Wildfire

Prescribed burning operations associated with all action alternatives would incorporate the Project Design 

Features (Chapter 2) intended to minimize effects to air quality. Potential effects to human health are 

displayed in the section titled “Public Health and Safety” in Chapter 3. 

The First Order Fire Effects Model (FOFEM) is a computer program developed to predict and plan for 

fire effects. Development of FOFEM involved a search of the fire effects literature for predictive 

algorithms. These algorithms were screened to evaluate their predictions over a range of conditions. 

Thus, a major internal component of FOFEM is a decision key that selects the best available algorithm for 

the conditions specified by a user. 
Environmental Impact Statement BLT Project

 Chapter 3 - Air Quality 

353

Analysis of the BLT alternatives used FOFEM to generate Tables 3-110 through 3-113 to summarize fuel 

consumption and smoke emission information. Alternative A was modeled under a problem fire scenario. 

Alternatives B, C, and D include emissions from planned pile disposal and prescribed underburning. 

These estimates are conservative for the action alternatives because the market demand for biomass could 

utilize piles instead of burning for disposal. This would lower the emissions and carbon output. 

Table 3-110. Potential Emission from a “Problem Fire” Scenario 

Emissions Pounds per Acre 

PM10 384 

PM25 326 

CH4 192 

CO 4,155 

CO2 28,519 

NOX 21 

SO2 21 

Total Tons Emission 705,978,000 

Table 3-111. Alternative B Prescribed Fire Emissions (7,499 acres)35

Emissions Pounds per Acre Total /Tons 

PM10 235 875 

PM 2.5 199 741 

CH4 119 443 

CO 2,558 9,527 

CO2 16,749 62,382 

NOX 12 45 

SO2 12 45 

Total Tons Emission 74,958 

Table 3-112. Alternative C Prescribed Fire Emissions (5,771 acres) 

Emissions Pounds per Acre Total /Tons 

PM10 235 678 

PM 2.5 199 574 

CH4 119 343 

CO 2,558 7,381 

CO2 16,749 48,239 

NOX 12 35 

SO2 12 35 

Total Tons Emission 57,285 

Table 3-113. Alternative D Prescribed Fire Emissions (2,616 acres) 

Emissions Pounds per Acre Total /Tons 

PM10 235 307 

PM 2.5 199 260 

CH4 119 156 

CO 2,558 3,346 

CO2 16,749 21,908 

NOX 12 16 

SO2 12 16 

Total Tons Emission 26,009 

 

35 PM10: Particulate Matter that is 10 micrometers or smaller in size; PM2.5: Particulate Matter that is 2.5 

micrometers or smaller in size; CH4: Methane; CO: Carbon Monoxide; CO2: Carbon Dioxide; NOX: Nitrogen 

Oxide; SO2: Sulphur Dioxide. 
BLT Project Environmental Impact Statement 

Chapter 3 - Other Disclosures 

354

Other Disclosures _____________________________________ 

Short-term Uses and Long-term Productivity 

NEPA requires consideration of the relationship between short-term uses of man’s environment and the 

maintenance and enhancement of long-term productivity (40 CFR 1502.16). As declared by Congress, 

this includes using all practicable means and measures to foster and promote the general welfare, to create 

and maintain conditions under which man and nature can exist in productive harmony, and fulfill the 

social, economic, and other requirements of present and future generations of Americans (NEPA Section 

101). 

The Multiple Use – Sustained Yield Act of 1960 requires the Forest Service to manage National Forest 

System lands for multiple uses (including timber, recreation, fish and wildlife, range, and watershed). All 

renewable resources are to be managed in such a way that they are available for future generations. 

Salvage and thinning activities that provide a commercial product, or use of standing timber, can be 

considered a short term use of a renewable resource. As a renewable resource, trees can be re-established 

and grown in again if the productivity of the land is not impaired. 

Maintaining the productivity of the land is a complex, long-term objective. All alternatives protect the 

long-term objective of the analysis area through the use of specific Forest plan Standards and Guidelines, 

mitigation measures, and BMPs. Long-term productivity could change as a result of the various 

management activities proposed in the alternatives. Timber management activities would have a direct, 

indirect, and cumulative effect on the economic, social, and biological environment. Those effects are 

disclosed in Chapter 3 of this analysis. 

Soil and water are two key factors in ecosystem productivity, and these resources would be protected in 

all alternatives to avoid damage that could take many decades to rectify. Sustained yield of timber, 

wildlife habitat, and other renewable resources all rely on maintaining long-term soil productivity. 

Quality and quantity of water from the analysis area may fluctuate as a result of short-term uses, but no 

long-term effects to water resources are expected to occur as a result of timber management activities. 

All alternatives would provide the fish and wildlife habitat necessary to contribute to the maintenance of 

viable, well distributed populations of existing native and non-native vertebrate species. The abundance 

and diversity of wildlife species depends on the quality, quantity, and distribution of habitat, whether for 

breeding, feeding, or resting. Management Indicator Species are used to represent the habitat 

requirements of all fish and wildlife species found within the analysis area. By managing habitat of 

indicator species, the other species associated with the same habitat would also benefit. The alternatives 

vary in risk presented in both fish and wildlife habitat capability. 

None of the alternatives would have an effect on the long-term productivity of timber resources. 

 

Unavoidable Adverse Effects 

Several unavoidable adverse effects, including some that are minimal and/or short term, were identified 

during the analysis. Adverse effects are associated with all alternatives, including the No Action and the 

Action alternatives. Resource protection measures or mitigations were identified for each adverse effect 

associated with an Action alternative as a means to lessen or eliminate such effects on specific resources. 

See the section titled “Resource Protection Measures” in Chapter 2 of this EIS. Resource areas 

determined to have potential adverse effects (resulting from any of the alternatives – including No Action 

and the Action Alternatives) are documented within the appropriate Environmental Consequences 

sections of each resource in Chapter 3. 
Environmental Impact Statement BLT Project

 Chapter 3 - Other Disclosures 

355

Soils 

Reference the section titled “Soils” in Chapter 3 of this EIS. Productivity of soils in proposed activity 

units would be 

• Alternative B would increase the amount of detrimental soil condition in the project area 

following restoration 1,524 acres. 

• Alternative C would increase the amount of detrimental soil condition in the project area 

following restoration activities 1,166 acres. 

• Alternative D would increase the amount of detrimental soil condition in the project area 468 

acres. 

Wildlife

Reference discussions in Chapter 3 under “Wildlife” for disclosure of effects for dead wood, Management 

Indicator Species, Regional Forester sensitive species, Birds of Conservation Concern, Big Game, and 

Old Growth Management. Specifically, the northern goshawk and 2 woodpeckers (black-backed and 

three-toed) were analyzed as Key Issues with management actions. The disclosure of effects for those 

three species are summarized in Chapter 2 under Comparison of Alternatives. 

Special Concern Plants 

For matsutake production, opening the canopy could possibly reduce active mycorrhizal connections, as 

might soil disturbance and compaction as a result of active management. Recovery to pre-treatment 

levels could take as long as 6-10 years or more. Modeling 10-years post activity shows a small change 

from closed to open canopies in the mid-seral larger size classes for dry ponderosa pine for all alternatives 

compared to modeled results for Alternative A (261, 120 and 60 acres for alts B, C, and D, respectively). 

This may indicate some loss of potential matsutake habitat or mushroom production, although the lost 

acreage may be marginal habitat. 

This was considered as a Key Issue and the tradeoffs are expressed in Chapter 2, comparison of the 

alternatives. 

Wild and Scenic Rivers 

Analysis has determined that scenic values may temporarily change from active management and may be 

visible. However, all activities have been found to be consistent with the Little Deschutes Wild and 

Scenic Management Plan by maintaining activities subordinate to the landscape, maintaining an existing 

level of scenic integrity (short- term), improving the scenic integrity level in the long-term, and reducing 

risk of a wide-scale disturbance event. 

Irreversible and Irretrievable Commitments of Resources 

Irreversible commitments of resources are those that cannot be regained, such as the extinction of a 

species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of time 

such as the temporary loss of timber productivity in forested areas that are kept clear for use as a power 

line rights-of-way or road. 

The action alternatives are expected to create effects that could cause irreversible damage to soil 

productivity. There is low risk for mechanical disturbances to cause soil mass failures (landslides) due to 

the inherent stability of dominant land types and the lack of seasonally wet soils on steep slopes. Careful 

planning and the application of Best Management Practices and project design elements would be used to 

prevent irreversible losses of the soil resource. 

The development and use of temporary roads and logging facilities is considered an irretrievable loss of 

soil productivity until their functions have been served and disturbed sites are returned back to a 

productive capacity. The action alternatives include soil restoration activities (subsoiling) on portions of 

activity areas estimated to exceed the 20 percent standard following implementation of the fuels and 
BLT Project Environmental Impact Statement 

Chapter 3 - Other Disclosures 

356

commercial harvest activities, including subsoiling temporary roads and logging facilities. Subsoiling 

would improve the hydrologic function and productivity on detrimentally disturbed soils. 

Incomplete and Unavailable Information 

Predictions of effects were made with the most current information available. The BLT Project ID Team 

identified the following based upon criteria described in the CEQ Guidelines (Sec. 1502.22 Incomplete or 

unavailable information). 

Little is known of the effects of silvicultural treatments on matsutake habitat and mushroom production. 

Lack of good baseline data, i.e. historical and current abundance of the fungal mycelium as well as 

sporocarps (mushrooms) and its potential habitat make it difficult to assess the precise effects of actions 

on habitat, fungal populations, or mushroom production. It is unknown at present how much of the 

modeled habitat actually contains matsutake mycelia or produces mushrooms. Environmental conditions 

for the matsutake vary spatially and temporally even in the absence of active forest management. The 

most recent abundant crop of mushrooms was harvested in 1993 and 1997 when environmental 

conditions were the most favorable for production. Whether it is possible to predict when these 

conditions may recur and if other factors, such as opening up of the tree canopy, may have an effect on 

future crops is still unknown. 

While limited evidence suggests that a tree canopy cover of approximately 70 percent maintains habitat 

for Allotropa (Dimling, 1997b cited in Wogen and Lippert, 1998), it is thought matsutake may increase 

sporocarp production in more open canopies with increased temperature on the forest floor; reduction or 

thinning of the litter layer to warm soil may also enhance production for Japanese matsutake (Hosford et 

al. 1997). Even thinning to as much as 40-50 percent canopy cover may take sporocarp production 

several years to reach pre-treatment production levels (Luoma et al., 2004). 

Forest management practices may enhance or reduce sporocarp production, while some ground 

disturbance related to treatments affects not only sporocarp production but can also disturb mycelial mats 

and reduce mycorrhiza connectivity (Kropp and Albee, 1996; Pilz et al., 1999; Luoma et al., 2006a). 

Reduced mycorrhizal connectivity would have detrimental effects on the host trees as well as on 

matsutake. Clear cutting, thinning and various dispersal patterns of understory tree retention can affect 

mycorrhizal diversity, mycorrhizal connections to host species, and below ground competition (Kropp 

and Albee, 1996; Luoma et al., 2004; Luoma and Eberhart, 2005; Durall et al., 2006). “The interval of 

time and correlation between stand treatment and matsutake fruiting are still unknown, but it will be 

critical to planning future management action. Matsutake may occur several years or several decades 

after stand treatment or perhaps not at all (Amaranthus et al., 1998).” There is little data regarding 

silvicultural effects on ectomycorrhizal organisms in general, and matsutake mushroom production in 

particular (Amaranthus et al., 1998; Kropp and Albee, 1996; Luoma et al., 2004; Weigand, 1998), or how 

much time is needed to return to pre-treatment production. 

Effects on Wetlands and Floodplains 

Executive Orders 11988 and 11990 direct Federal agencies to avoid, to the extent possible, both shortterm and long-term adverse impacts associated with the modifications of floodplains and wetlands. All 

alternatives have no specific actions that adversely affect wetlands and floodplains. Proposed activities 

are compliant with the orders and USDA Departmental Regulation 9500-3. See discussions related to this 

topic in the hydrology, fishery and soils resource sections in Chapter 3 for more information. 

Effects on Prime Farmland, Rangeland and Forest Land 

All Alternatives were consistent with the Secretary of Agriculture memorandum 1827 for the 

management of prime farmland. The BLT analysis area does not contain any prime farm land or 
Environmental Impact Statement BLT Project

 Chapter 3 - Other Disclosures 

357

rangelands. Prime Forest Land, as defined in the memorandum, is not applicable to lands within the 

National Forest System. 

Energy Requirements of Alternatives 

Under the action Alternatives, additional consumption of fossil fuels and human labor would be expended 

for the use of vehicles transporting Forest workers, chainsaws, heavy equipment and trucks. Fossil fuel 

would not be a retrievable resource. There are no irregular energy requirements involved in 

implementing any of the action alternatives. 
BLT Project Environmental Impact Statement 

Chapter 4 –Consultation / Coordination 

358

CHAPTER 4. CONSULTATION AND COORDINATION 

Preparers and Contributors ___________________________ 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and 

non-Forest Service persons during the development of this environmental assessment: 

Preparers 

Chris Mickle, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Environmental Coordinator 

Contribution: NEPA review and oversight 

Experience: Forest Service 29 years including positions in Fire/Fuels and Planning 

David Baker, USDA Forest Service, Deschutes National Forest, Supervisors Office, Ecologist / 

Botanist 

Contribution: Botany, Invasive Plant Strategy 

Education: MSC Forest Products/Forest Science, Oregon State University 

Experience: 

Marcy Boehme, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Environmental Specialist

Contribution: Writer-Editor 

Education: Candidate for MAS Environmental Policy and Management, University of Denver; BS 

Wildlife, Humboldt State University 1993. 

Experience: Forest Service - 13 years; positions include Biological Technician, Wildlife Biologist, 

Writer-Editor, and Environmental Specialist 

Joe Bowles, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Silviculturist / Data Analyst 

Contribution: Silvicultural analysis 

Education: BS Forest Resources, Minor in fire ecology and management, University of Idaho, 

2005 

Experience: Since 2000, USFS work in fire, timber, and silviculture 

Ken Kittrell, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Transportation Planner / Road Manager 

Contribution: Transportation planning 

Education: BS Fisheries Biology, University of Idaho, 1978 

Experience: Forest Service since 1978; positions include Road Survey Technician, Project 

Engineer, Soil/Watershed Specialist, Transportation Planner and Road Manager 

Leslie Hickerson, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Archaeologist 

Contribution: Heritage Program Input 

Education: MA Anthropology, University of Arizona 1989; BS Anthropology with “High 

Scholarship”, Oregon State University 1976 

Experience: Forest Service since 1976; District Archaeologist since 1988 
Environmental Impact Statement BLT Project

 Chapter 4 –Consultation / Coordination 

359

Joan Kittrell, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Wildlife 

Biologist 

Contribution: Wildlife Viable Modeling, Snag and Down Wood HRV Analysis 

Education: BS Wildlife, Washington State University 1981 

Experience: Forest Service 26 years; biologist with Forest Service 18 years 

Paul Miller, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Wildlife 

Biologist 

Contribution: Wildlife analysis 

Education: BS Wildlife Biology, Washington State University 

Experience: Forest Service 25 years including positions in fire, recreation, and 19 years as a 

biologist 

Paul Powers, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Fisheries 

Biologist 

Contribution: Fisheries analysis, water quality 

Education: BS, Oregon State University 1996 

Experience: Fisheries work with Forest Service and USGS Biological Research Lab since 1995 

Dorothy Thomas, USDA Forest Service, Region 6, Data Resources Management, GIS Specialist 

Contribution: GIS Analysis and Support 

Education: BS Environmental Sciences, Oregon State University 2000; ASS Geographic 

Information Systems, Central Oregon Community College 1995 

Experience: Forest Service GIS 13 years 

Janet Hollister, USDA Forest Service, Deschutes National Forest, Supervisor’s Office, Planner 

Contribution: Comment analysis, document review; writer/editor 

Education: BS Biological Sciences, University of Alaska; University of Oregon 

Experience: Forest Service – 15 years 

Christine Frisbee, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

District Ranger

Contribution: Line officer providing management guidance and oversight 

Education: BS Horticulture, Texas A&M University; BS Secondary Science Education, Montana 

State University 

Experience: Forest Service - 17 years 

Joe Monroe, USDA Forest Service 

Contribution: GIS/Data Services 

Education: BS Forest Management, Oregon State University 1985 

Experience: Forest Service 22 years; GIS Specialist with Forest Service 8 years 

Ken Boucher, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

AFMO/Fuels Specialist 

Contribution: Fire and Fuels analysis; modeling 

Education: University of Las Vegas, Biological Sciences Certificate 2007 

Experience: Fire and Fuels, 15 years 

Rick Cope, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Hydrologist

Contribution: Soils, Hydrology, Water Quality 

Education: BS Geology, Oregon State University 

Experience: Forest Service hydrologist for 19 years; 22 years with the Federal government 
BLT Project Environmental Impact Statement 

Chapter 4 –Consultation / Coordination 

360

Mose Harris, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Planner 

Contribution: Document review; planning assistance 

Education: Tuskegee University, Alabama 

Experience: Forest Service - 2 years 

Kristen McBride, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Natural Resources Team Leader

Contribution: Oversight 

Education: BS Environmental Science, Northern Arizona University 1994; MS Range Science and 

Management, University of Arizona 2001 

Experience: Forest Service since 1997; positions include Biological Science Technician, 

Monitoring Team Coordinator, Ecologist (Forest Plan Revision Team) and Natural 

Resources Team Leader 

Elisabeth Grinspoon Spiro, USDA Forest Service, Regional Office, Portland, Oregon, Social 

Scientist 

Contribution: Social and Economic Conditions 

Education: BA Middlebury College 1990, MF Yale University 1996, PhD University of 

California at Berkeley 2002. 

Experience: Forest Service 6 years 
Environmental Impact Statement BLT Project

 Chapter 4 – EIS Distribution 

361

Distribution of the Environmental Impact Statement _______ 

Draft Environmental Impact Statement 

The Forest Service consulted with or received project comments from the following individuals, 

agencies, tribes, and non-Forest Service persons during the development of the draft environmental 

impact statement. 

Federal Agencies

US Environmental Protection Agency 

US Fish and Wildlife Service 

State Government

Oregon Department of Fish and Wildlife 

Tribes

Confederated Tribes of the Warm Springs 

Burns Paiute Tribe 

The Klamath Tribes 

Organizations

American Forest Resources Council 

Associated Oregon Loggers, Inc. 

Blue Mountains Biodiversity Project 

Cascadia Wildlands Project 

Cascade Timberlands, LLC 

Central Oregon Flyfishers 

Forestry Action Committee 

Friends of Living Oregon Waters 

Klamath Forest Alliance 

Native Plant Society 

Northwest Environmental Defense Council 

Northwest Special Forest Products Association 

Oregon Chapter Sierra Club 

Oregon Eagle Foundation 

Oregon Equestrian Trails 

Oregon State Snowmobile Association 

Oregon Water Resources 

Oregon Wild 

Pacific Northwest 4-Wheel Drive Association 

Quincy Library Group 

Sierra Club, Juniper Group 

The Nature Conservancy 

The Wilderness Society 

Trout Unlimited 

Upper Deschutes Watershed Council 

Walker Rim Riders 

Businesses

Boise Cascade Corporation 

C & B Construction 

Central Point Lumber 

Crescent Creek Cottages 

DR Johnson Lumber Company 

Frontier Advertiser 

Herald & News – Klamath Falls 

Katie Sharkey 

KLE Enterprises 

KTVZ - Bend 

Ochoco Lumber Company 

Odell Sportsman 

Pacific Legal Foundation 

Shelter Cove Resort 

The Bulletin - Bend 

The Nugget Newspaper – Sisters 

Union Pacific Railroad 

US Timberlands Services 

Individuals

Greg Aitken 

Jim Anderson 

Shawn Carroll 

Bob Davis 

Dick & Joani Dufourd 

Harry Farley 

Forrest Fleischman 

Brian Fuller 

Robert Irwin 

Gene Keane 

Rebecca McLain 

Richard Meadows 

Joni Mogstad 

Bob Mullong 

Vern Oden 

Kao Saechao 

Deng Sandara 

Kristen Stankiewitz 

Ben Sunderland 

Sothon S. Suy 

Fred Tanis 

Anna Tsing 

Roy Vermillion 

Garrett Waltosz
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Visser, S. 1995. Ectomycorrhizal fungal succession in jack pine following wildfire. New Phytol. 129: 

389–401. 
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assessment). 
Environmental Impact Statement BLT Project

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385

Glossary____________________________________________ 

A 

Advanced Regeneration - Small trees, usually 

less than 1 inch in diameter, which are growing 

under mature trees prior to planned harvest 

activities. 

B 

Bald Eagle Management Areas (BEMAs) - 

Areas managed under the Deschutes National 

Forest Land and Resource Management Plan 

for the protection of the threatened northern 

bald eagle. BEMAs provide nesting and 

roosting habitat for the species. 

C 

Canopy - The uppermost spreading branchy 

layer of a forest. 

Canopy Base Height – The height above the 

ground of the first canopy layer where the 

density of the crown mass within the layer is 

high enough to support vertical movement of a 

fire. Low canopy base heights have been shown 

to initiate crown fire behavior. 

Canopy Bulk Density - Canopy bulk density 

(CBD) describes the density of available 

canopy fuel in a stand. It is defined as the mass 

of available canopy fuel per canopy volume 

unit. 

Chain – A standard measurement for the rate 

of spread of fire. 

Condition Classes - A function of the degree of 

departure from historical fire regimes. 

Condition class 1 is within or near historical 

conditions; class 3 is significantly altered from 

historical regimes. 

Crop Trees -Trees which are considered 

suitable to meet long term management 

objectives for an analysis area. These may also 

be referred to as healthy or manageable trees. 

This may include both the physical make-up of 

the tree as well as the species. 

Cryic - Soils in this temperature regime have a 

mean annual temperature higher than 0°C but 

lower than 8°C. 

Cycle - As applied to uneven-aged 

management, it is the time interval between 

harvest entries. It should be noted that harvest 

entries in uneven-aged management are to 

leave residual levels of growing stock which 

should not need treatment for at least one cycle 

length. 

D 

Desirable Species - Any species of plant or 

animal which is considered to be compatible 

with meeting management goals and 

objectives. 

Disturbance - Events that disrupt the stand 

structure and/or change resource availability or 

the physical environment (Oliver, 1996). 

Diurnal - Active during the daytime, resting 

during the night. 

E 

Early Seral - Plants which inhabit a disturbed 

site within the first few years subsequent to the 

disturbance. 

Excess Trees - Trees which are considered not 

needed in the stand in order to meet 

management objectives. 

Extended Attack - When a fire has not been 

contained by the initial attack resources 

dispatched to the fire, will not have been 

contained within the management objectives 

that are established for that zone or area, and 

has not been contained within the first 

operational period. 

Extirpated - Local extinction. 

F 

Fire Regime - A function of the historical 

frequency of fire and the degree of severity of 

those fires. 
BLT Project Environmental Impact Statement 

Chapter 4 – Glossary 

386

 

Fuels - Vegetative matter, dead or alive, that 

burns in a fire. It is broadly characterized by 

the following categories: 

• Surface or ground fuels are within a 

foot or so of the ground surface. 

• Ladder fuels exist when you have a 

continuous vertical arrangement of fuel 

that allows fire to easily go from 

ground level into the tree canopy. 

• Crown fuels are the tree limbs and 

leave that can burn with enough heat 

and/or wind. 

• Live fuels are the green (live) herbs 

and shrubs. 

Fuel Models - Fuel models are a tool used to 

standardize discussion of fuel conditions on a 

landscape. 

G 

Group Selection - A stand management 

method in which silviculturists identify groups 

of trees which need to be removed from a stand 

of trees in order to meet management 

objectives. 

I 

Individual Tree Selection - A stand 

management method in which silviculturists 

identify individual trees that need to be 

removed from a stand of trees. In these method 

specific types, sizes, or qualities of trees are 

identified for either removing from the stand or 

remaining in the stand. 

Initial Attack – The fire suppression effort that 

takes place as soon as possible following a 

wildland fire report. 

L 

Ladder Fuels – Fuels that provide vertical 

continuity between the ground and tree crowns, 

thus creating a pathway for a surface fire to 

move into the overstory tree crowns. 

M 

Mechanical Thinning - Reducing the number 

of trees in a stand using a factor which is 

independent of tree quality. The use of spacing 

for thinning is one type of mechanical 

treatment. For example, the closest tree to the 

points of a 15' by 15' grid would be left, 

regardless of tree quality. 

N 

Noxious Weeds (Invasive species) - Non-native 

plants listed by the State that generally have 

either economic or ecosystem impacts, or are 

poisonous to wildlife and/or livestock. They 

aggressively invade disturbed areas such as 

fires, road sides, and construction areas. 

P 

Prescribed Fire - Fire which is planned and 

used as a tool to meet specific management 

objectives. 

Percentile Weather - The weather conditions 

that can be expected of X% of the days during 

a fire season. The standard percents are Low 

(0%-15%), Moderate (16%-89%), High (90%-

96%) and Extreme (97%+). So low percentile 

weather is the average suite of weather 

conditions that would occur less than 15% of 

the time.

Problem Fire - Problem fires are wildfires that, 

because of extreme fire behavior, present a 

high risk to human safety and loss of forest 

resources. 

R 

Rotation - A pre-determined time frame in 

which an even-aged forest stand will reach 

maturity and be harvested. 

S 

Salvage - Activity, usually removal or 

chipping, of material killed by a disturbance 

event such as insects, fire, wind, etc. Where 

possible, this material is used as some form of 

forest product of commercial value, such as 

firewood, pulp, and/or chips. 

Seral Stages - Seral stage describes the phase 

of development of a plant community. Early 

seral species are those species you would 

expect to find on a site soon after a major 

disturbance, like fire. These are species such as 

pines, Douglas-fir, snowbrush, fireweed, etc. 

They are generally shade intolerant species. 

Late seral are the species that can come in 
Environmental Impact Statement BLT Project

 Chapter 4 - Glossary 

387

under a fully developed vegetative canopy, 

such as true firs, prince's pine, lichens, etc. 

Silviculture -The theory and practice of 

directing forest establishment, composition, 

and growth for the production of forest 

resources to meet specific management 

objectives. The word is derived from the 

Latin word sylva, which means "forest" and 

from cultura, which means "to develop and 

care for." So, it is the development and caring 

for the forest. 

Silviculturist - One who plans, assists in and 

supervises the implementation of silviculture 

projects. The silviculturist determines 

(prescribes) the vegetative treatments necessary 

to meet the objectives for vegetation on a given 

site. 

Site - A specific location where management 

activity is considered, planned, or operating. 

Site Potential - The specific ability of a site to 

grow vegetation. It includes the soil, 

topographic, and climatic conditions that 

determine the resources available for growing 

vegetation. 

Site Preparation - The removing or rearranging 

of vegetation or woody debris to meet specific 

management objectives. Most often it is used 

to describe the process(es) used to expose 

mineral soil areas suitable for planting or 

seeding desirable species of plants. 

Stand - A group of trees of similar canopy 

structure, species composition, and/or size 

growing on a continuous area . A stand is 

distinct from neighboring stands in either 

structure, growing conditions, or management 

objectives. 

Stand Dynamics - The changes in forest stand 

structure with time, including stand behavior 

during and after disturbances (Oliver, 1996). 

Stand Structure - The physical and temporal 

distribution of trees and other plants in a stand 

(Oliver, 1996). 

Subnivean - Living underneath snow. 

T 

Trees per Acre - The amount of trees of a 

specific diameter on an acre of land. 

Thinning - Any cutting or removal of 

vegetation (trees, brush, etc.) resulting in a 

reduction of competition for water, light, and/or 

nutrients between individual plants. Thinning 

is commonly referred to as commercial 

thinning and small tree thinning. 

• Commercial thinning refers to removing 

material that has an established dollar value 

on the open market and can be sold with at 

least a minimal net value sufficient to pay 

for the thinning activity. 

• Small tree thinning/Ladder fuel 

reduction may or may not have a dollar 

value and usually includes the need to pay 

someone to accomplish the work. This is 

sometimes called small-tree thinning 

because the trees are smaller than the sizes 

that have a commercial value. 

Thrifty trees - Trees which have at least a 40% 

live crown ratio and with little or no evidence 

of disease or insects are called thrifty. They 

should also show evidence of good growth with 

long leaders and a good color, usually dark 

green. 

Treatment - A term used to broadly refer to the 

vegetative changes made to meet management 

objectives. It may include thinning, cutting of 

undesirable trees, prescribed fire, salvage, or 

any manipulation of the vegetative conditions. 

Trees per Acre – The number of trees of a 

specific diameter on an acre of land. 

U 

Underburn - Using prescribed fire under the 

canopy of an existing stand of trees. 

Undesirable Species - Any species of plant or 

animal which is NOT considered to be 

compatible with meeting management goals 

and objectives. 
BLT Project Environmental Impact Statement 

Chapter 4 – Glossary 

388

Ustic - A soil moisture regime in which 

moisture is limited but is present at a time when 

conditions are suitable for plant growth. 

W 

Woody Debris - Dead pieces of woody 

vegetation such as stems, limbs, or leaves 

which are on a site. 

X 

Xeric - A soil moisture regime in which soil is 

dry for 45 or more consecutive days in the 4 

months following the summer solstice, and 

moist for 45 or more consecutive days in the 4 

months following the winter solstice. 
Environmental Impact Statement BLT Project 

 Index 

389

Index_______________________________________________ 

B

Bull Trout, vi, 257 

C

Clean Water Act, 383 

Cultural Resources, 15 

Cumulative effects, 46 

Cumulative Effects, 51 

D

Douglas-fir, 29, 378 

E

Economics, vii, 8, 15, 46, 293, 337, 346, 350, 378, 382, 

385, 393 

Economic efficiency, vii, 385 

erosion, 51, 393 

Erosion, 55 

F

Fire, iii, vi, 2, 30, 35, 48, 102, 113, 115, 271, 291, 308, 

331, 332, 333, 334, 335, 336, 348, 349, 355, 377, 378, 

379, 383, 386, 390, 393, 395 

Problem Fire, 102, 349 

Wildfire, i, iv, 2, 44, 92, 114, 115, 333, 336 

I

Issue, 13 

Analysis, 13, 15 

Key, 13 

Key, 13 

Issues, iv, vii, 1, 4, 13, 15, 45 

Analysis, 15 

Key, 13, 45 

L

Lodgepole Pine, i, 29, 333 

M

Management Indicator Species, 15, 350 

mitigation, 46 

N

Northwest Forest Plan, 383 

Noxious Weeds, 328 

P

Ponderosa Pine, 29, 31, 333, 388, 391 

R

Recreation, 15 

redband trout, vi, 257 

restoration, 51, 346, 384 

S

Scenery, 15 

sediment, 51, 393 

Soils 

Detrimental, 31, 347, 351, 393 

subsoiling, 351 

Survey and Manage Species, 15 

T

Threatened, Endangered and Sensitive Species, 15, 127, 

176, 257, 258 

W

Water Quality, 15, 51, 383, 393 

Wildlife, 15 
BLT Project Environmental Impact Statement 

Appendix A 

390

APPENDIX A – CONSISTENCY WITH CURRENT 

LAWS AND MANAGEMENT DIRECTION 

Current Laws and Management Direction ________________ 

Development of this Environmental Impact Statement follows implementing regulations of the National 

Forest Management Act (NFMA); Title 36 , Code of Federal Regulations, Part 219 (36 CFR 219); 

Council of Environmental Quality, Title 40; CFR, Parts 1500-1508, and the National Environmental 

Policy Act (NEPA). 

The American Antiquities Act of 1906 

This Act makes it illegal to appropriate, excavate, injure or destroy any historic or prehistoric ruin or 

monument or any object of antiquity, situated on lands owned by the Government of the United States, 

without permission of the Secretary of the Department of the Government having jurisdiction over the 

lands on which said antiquities are situated. 

The National Historic Preservation Act of 1966, as amended

This Act requires Federal agencies to consult with American Indian Tribes, State and local groups 

before nonrenewable cultural resources, such as archaeological and historic structures, are damaged ore 

destroyed. Section 106 of this Act requires Federal agencies to review the effects proposed projects 

may have on the cultural resources of the analysis area. 

Following guidelines in a 2003 Regional Programmatic Agreement among USDA-Forest Service, the 

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

of “Historic Properties Avoided” was determined. This finding is based on the practice of avoiding all 

eligible and unevaluated sites (Chapter 3, Cultural Resources). 

The Endangered Species Act of 1973, as amended

The purposes of this Act are to “provide a means whereby the ecosystems upon which endangered 

species and threatened species depend may be conserved, to provide a program for the conservation of 

such endangered and threatened species, and to take such steps as may be appropriate to achieve the 

purpose of the treaties and conventions set forth in subsection (a) of this section.” The Act also states 

“It is further declared to be the policy of Congress that all Federal departments and agencies shall seek 

to conserve endangered species and threatened species and shall utilize their authorities in furtherance 

of the purposes of this Act.” 

Alternatives A, B, C, and D would have “No Effect” on the northern spotted owl and Oregon spotted 

frog. Alternative A would have “No Effect” on the Pacific fisher. Alternatives B, C, or D would result 

in a determination of “May Impact Individuals or Habitat, But Will Not Contribute To a Trend 

Toward Federal Listing or Loss of Viability To The Population or Species” for the Pacific fisher. 

The Migratory Bird Treaty Act of 1918 

The purpose of this Act is to establish an international framework for the protection and conservation of 

migratory birds. The Act makes it illegal, unless permitted by regulations, to “pursue, hunt, take, 

capture, deliver for shipment, ship, cause to be carried by any means whatever, receive for shipment, 

transportation or carriage, or export, at any time, or in any manner, any migratory bird, including in this 

Convention...for the protection of migratory birds...or any part, nest, or egg of any such bird” (16USC 

703). The original 1918 statute implemented the 1916 Convention between the United States and Great 

Britain (for Canada). Later amendments implemented treaties between the Unites States and Mexico, 

Japan, and the Soviet Union (now Russia). 
Environmental Impact Statement BLT Project 

 Appendix A 

391

The National Environmental Policy Act (NEPA) of 1969, as amended 

The purposes of this Act are “To declare a national policy which will encourage productive and 

enjoyable harmony between man and his environment, to promote efforts which will prevent or 

eliminate damaged to the environment and biosphere and stimulate the health and welfare of man; to 

enrich the understanding of the ecological systems and natural resources important to the Nations; and 

to establish a Council on Environmental Quality” (42 U.S.C. Sec. 4321). The law further states “it is 

the continuing policy of the Federal Government, in cooperation, to use all practicable means and 

measures, including financial and technical assistance, in a manner calculated to foster and promote the 

general welfare, to create and maintain conditions under which man and nature can exist in productive 

harmony, and fulfill the social, economic, and other requirements of the present and future generations 

of Americans. This law essentially pertains to public participation, environmental analysis, and 

documentation. 

The BLT project followed the format and content requirements of environmental analysis and 

documentation. The entire process of preparing this environmental impact statement was undertaken to 

comply with NEPA. Cumulative effects were assessed and displayed where they occur in the manner 

most informative and logical to display. Also, the depth of analysis was tailored to the degree of effect. 

For example, the olive flycatcher is a generalist avian wildlife species that favors edge habitat and 

openings. Implementation of any action associated with the BLT project would have very little effect. 

Therefore, a brief discussion is most useful to decision makers and the public to reduce paperwork and 

the accumulation of extraneous background data and to emphasize real environmental issues and 

alternatives (CEQ, 1500.2b). In many instances within this analysis, past and present activities, 

including timber sales, were included in the existing condition. Foreseeable actions were also 

addressed if there was a proposed action and if it is in the public domain. 

The National Forest Management Act (NFMA) 

This final rule describes the National Forest System land management planning framework; establishes 

requirements for sustainability of social, economic, and ecological systems and developing, amending, 

revising, and monitoring land management plans; and clarifies that land management plans under this 

final rule, absent extraordinary circumstances, are strategic in nature and are one stage in an adaptive 

cycle of planning for management of National Forest System lands. The intended effects of the final 

rule are to streamline and improve the planning process by making plans more adaptable to changes n 

social, economic, and environmental conditions; to strengthen the role of science in planning; to 

strengthen collaborative relationships with the public and other governmental entities; and to reaffirm 

the principle of sustainable management consistent with the Multiple-Use Sustained-Yield Act and 

other authorities. 

The BLT project does not contain any vegetative prescriptions that are considered regeneration harvest. 

Project activities are consistent with the Deschutes Land and Resource Management Plan and the 

associated amendments including the Northwest Forest Plan for Matrix and Administratively 

Withdrawn Lands and Eastside Screens, as displayed in Chapter 3 and this Appendix. The design 

criteria common to all alternatives is to retain all existing snags except those that pose a hazard (FEIS, 

Resource Protection Measures and Project Design Features). The BLT project seeks to manage snags 

and down wood habitat at various densities across the landscape utilizing a reference condition based 

on the historical range of variability as described in the FEIS. Managing within the historical range 

would provide for those species that survived to the present with those densities meeting NFMA 

objectives. The best available science on dead wood relationships to wildlife habitat was compiled in 

the form of DecAID, and local data sets. Effectiveness monitoring is ongoing in terms of research and 

DecAID will be continually updated with the new science as it becomes available. As this information 

is updated management will adapt to the new information. This project demonstrates the Forest Service 

commitment to adaptive management to meet the needs of wildlife. NEPA requires a disclosure of 

effects of federal actions. The direct, indirect and cumulative effects of implementation of the 
BLT Project Environmental Impact Statement 

Appendix A 

392

alternatives on snag habitat are disclosed in Chapter 3 of the FEIS. The effects analysis is based on 

habitat needs determined by research 

The Clean Water Act, as amended in 1977 and 1982 

The primary objective of this Act is to restore and maintain the integrity of the Nation’s waters. This 

objective translates into two fundamental national goals: 1. Eliminate the discharge of pollutants into 

the nation’s waters; and 2. Achieve water quality levels that are fishable and swimmable. This Act 

establishes a non-degradation policy for all federally proposed projects. Under Section 303(d) of the 

Clean Water Act, the State has identified water quality-limited water bodies in Oregon. The Little 

Deschutes and Hemlock Creek are the only water bodies in the analysis area that are on the 303(d) list. 

There would be no effect to the Little Deschutes River or Hemlock Creek parameters for which they are 

listed 303(d). 

All alternatives in the BLT project comply with the Riparian Reserve Standards and Guidelines as 

specified in the Northwest Forest Plan. Only one unit (1061) overlaps reserve boundaries within 

INFISH and Riparian Habitat Conservation Area objectives. Activities include non-mechanical small 

diameter thinning and prescribed burning. 

Action alternatives follow State of Oregon requirements in accordance with the Clean Water Act for 

protection of waters. Application of Best Management Practices (BMPs) are selected and designed on 

site-specific conditions for waters potentially affected in the BLT analysis area. The interdisciplinary 

team has reviewed and incorporated applicable BMP water quality objectives in the design of 

alternatives and their mitigation measures. Standards and Guidelines for the Northwest Forest Plan 

(Aquatic Conservation Strategy) and the Inland Native Fish Strategy where developed (in part) to 

maintain and restore aquatic ecosystems for dependent species (Chapter 3, Fisheries and Water 

Quality). These standards and guidelines afford the same or greater protection of stream courses as 

direction found in the 1988 USDA publication “General Water Quality – Best Management Practices.” 

Protection of water quality is also provided by incorporation of BMPs in timber sale contract provisions 

and direction for road maintenance and reconstruction. 

These findings, plus consistency with Aquatic Conservation Strategy and Riparian Habitat 

Conservation Area objectives is disclosed in Chapter 3, Hydrology and Water Quality. 

The Clean Air Act, as amended in 1990 

The purposes of this Act are “to protect and enhance the quality of the Nation’s air resources so as to 

promote the public health and welfare and the productive capacity of its population; to initiate and 

accelerate a national research and development program to achieve the prevention and control of air 

pollution; to provide technical and financial assistance to state and local governments in connection 

with the development and execution of their air pollution prevention and control programs; and to 

encourage and assist the development and operation of regional air pollution prevention and control 

programs.” 

Action alternatives are designed to be consistent with the Clean Air Act. The Oregon Department of 

Environmental Quality (DEQ) is responsible for assuring compliance with the Clean Air Act. In 1994, 

the Forest Service, in cooperation with the DEQ, the Oregon Department of Forestry and the Bureau of 

Land Management, signed a Memorandum of Understanding (MOU) to establish a framework for 

implementing an air quality program in Northeast Oregon. All prescribed burning is coordinated with 

the DEQ through the State of Oregon smoke management program. All prescribed fire activities 

authorized by this Record of Decision would be conducted in compliance with the State of Oregon 

Smoke Management System and would meet smoke management objectives for total emissions 

(Chapter 3, Clean Air Act). 
Environmental Impact Statement BLT Project 

 Appendix A 

393

Executive Orders 11988 and 11990 

Direct Federal agencies to avoid, to the extent possible, both short-term and long-term adverse impacts 

associated with the modifications of floodplains and wetlands. All alternatives have no specific actions 

that adversely affect wetlands and floodplains. Proposed activities are compliant with the orders and 

USDA Departmental Regulation 9500-3. See discussions related to this topic in the hydrology, fishery 

and soils resource sections in Chapter 3 for more information. 

Multiple-Use Sustained-Yield Act of 1960 

The Multiple Use – Sustained Yield Act of 1960 requires the Forest Service to manage National Forest 

System lands for multiple uses (including timber, recreation, fish and wildlife, range, and watershed). 

All renewable resources are to be managed in such a way that they are available for future generations. 

The harvesting and use of standing timber can be considered a short-term use of a renewable resource. 

As a renewable resource, trees can be re-established and grown in again if the productivity of the land is 

not impaired. 

All lands proposed for active management in the BLT analysis area are classified “suitable”. Actions 

proposed in comply with LRMP standards and guidelines SL-3 and SL-4, and Regional policy (FSM 

2520, R-6 Supplement No. 2500-98-1) for maintaining soil productivity (Chapter 3, Soil Quality). 

Migratory Bird E.O. 13186 

On January 10, 2001, President Clinton signed an Executive Order (E.O. 13186) titled “Responsibilities 

of Federal Agencies to Protect Migratory Birds.” This E.O. requires the “environmental analysis of 

Federal actions, required by NEPA or other established environmental review processes, evaluates the 

effects of actions and agency plans on migratory birds, with emphasis on species of concern.” 

Forest Order 12962 (aquatic systems and recreational fisheries) 

This 1995 order’s purpose is to conserve, restore, and enhance aquatic systems to provide for increased 

recreational fishing opportunities nationwide. It requires federal agencies to evaluate the effects of 

federally funded actions on aquatic systems and document those effects relative to the purpose of this 

order. 

Executive Order 13112 (invasive species) 

This 1999 order requires Federal agencies whose actions may affect the status of invasive species to 

identify those actions and within budgetary limits, “(i) prevent the introduction of invasive species; (ii) 

detect and respond rapidly to and control populations of such species... (iii) monitor invasive species 

populations... (iv) provide for restoration of native species and habitat conditions in ecosystems that 

have been invaded;...(vi) promote public education on invasive species... and (3) not authorize, fund, 

or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive 

species... unless, pursuant to guidelines that it has prescribed, the agency had determined and made 

public... that the benefits of such actions clearly outweigh the potential harm caused by invasive 

species; and that all feasible and prudent measures to minimize risk of harm will be taken in 

conjunction with the actions.” 

There is a high risk for spreading or introducing noxious weeds for all action alternatives in this project. 

The risk is proportional to the area of ground disturbance and miles of roads used in each action 

alternative. Highest risk is for Alternative B, followed by Alternative C, Alternative D and the no 

action Alternative A. Weeds are already present in the analysis area, particularly along Highways 58 

and 61, but do not overlap activity units. The Region 6 Invasive Plant Final Environmental Impact 

Statement (FEIS) Record of Decision (ROD) (USDA Forest Service, 2005) adopted Standards and 

Guidelines that will be followed (Chapter 3, Invasive Plants). 

Civil Rights Impact Analysis 
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Civil Rights Impact Analysis (CRIA) identifies the potential social impacts of a decision on employees 

and customers, so that these impacts will be considered and appropriately mitigated as part of the 

decision-making process. CRIA is required for any major decision which has a significant social or 

civil rights impact (FSM 1730.3). Decisions include natural resource management decisions that 

potentially impact Forest Service employees or customers. A decision with a significant civil rights 

impact is one that abolishes positions or reduces services or programs offered to the public (SocioEconomic, Chapter 3). 

Deschutes National Forest Land and Resource Management Plan 

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

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

Deschutes National Forest. The Standards and Guidelines apply where the amendments (Northwest 

Forest Plan and Revised Continuation of Interim Management Direction Establishing Riparian, 

Ecosystem and Wildlife Standards for Timber Sales) provide no particular guidance or where the Forest 

Plan provides more restrictive direction than found within the amendment. 

The Deschutes National Forest Land and Resource Management Plan (Forest Plan; page 4-2) contains 

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

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

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

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

diversity spectrum, (4) aesthetic appeal. 

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

environmental constraints, and economic efficiency. 

All alternatives considered in detail in this EIS are consistent with the Deschutes National Forest Plan. 

The following Forest Plan Management Areas (MAs) are found in the analysis area: 

M15: Old Growth (1,171 acres) – The goal of this MA is to provide naturally evolved old growth 

forest ecosystems for the following purposes: habitat for plant and animal species associated with old 

growth forest ecosystems; representations of landscape ecology; public enjoyment of large, old-tree 

environments; and the needs of the public from an aesthetic spiritual sense. There are two designated 

old growth areas within the project. Particularly, portions that contain large sugar pine and other large 

tree species are at risk to understory competition. 

The activities proposed within each OGMA in BLT have been found to be consistent with the 

assessments and the requirement of the Deschutes LRMP because all vegetation manipulations are 

designed to “enhance and perpetuate old growth characteristics” Deschutes LRMP (M15-4) and provide 

habitat for the focal species; the goal of the activity is to retain the largest diameter trees in each OGMA 

for the longest period possible and no tree over 21 inches in diameter would be harvested; no standing 

or downed dead trees would be removed except those for occupational safety; prescriptions are 

designed to meet the minimum habitat needs of the focal species and maintain vegetative species 

diversity; and no temporary roads would be constructed and interior habitat and edge effect would not 

change (Chapter 3, Old Growth Management). 

M8: General Forest (32,473 acres) – This MA emphasizes timber production while providing forage 

production, visual quality, wildlife habitat, and recreational opportunities for public use and enjoyment. 

While adhering to the Eastside Screens and Matrix lands (described further in this document), these are 

the areas of the Forest Plan where a broad spectrum of goods and services would be available to 

contribute to the local and regional economic well-being. 
Environmental Impact Statement BLT Project 

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M9: Scenic Views (3,434 acres) – The goal of Scenic Views management areas is to provide high 

quality scenery that represents the natural character of Central Oregon. Landscapes seen from selected 

travel routes and use areas will be managed to maintain or enhance their appearance. To the casual 

observer, results of activities either will not be evident, or will be visually subordinate to the natural 

landscape. 

All activities planned in Alternatives B, C and D are consistent with Goals, Objectives, and Standards 

and Guidelines in the Deschutes National Forest Plan because in Foreground areas, visible results of 

active management would not be noticeable to the casual forest visitor within two years in Partial 

Retention (Medium Scenic Integrity). The greatest potential for change would be on Highway 58 near 

Odell Butte in the ponderosa pine where vegetative prescriptions would be characterized as understory 

thinning, favoring the largest diameter trees and the healthiest crowns and forms (M9-6). Mitigation 

measures to comply with M9-12 and M9-58 (for Partial Retention) include handpiling and disposal of 

tops and limbs within two years, and measures to minimize evidence of management activities such as 

marking guidelines that are discreet from viewer locations. Measures such as these have been 

successfully implemented for activities along sensitive viewer locations such as the Charlie Brown 

project and the Davis Fire Recovery EIS and have proven to be successful (Chapter 3, Scenery). 

M17: Wild and Scenic Rivers (1,887 acres) – The primary objectives for managing waterways that are 

components of the National Wild and Scenic Rivers System will be to protect the outstandingly 

remarkable values identified for each and for maintaining the free-flowing nature of the river. Within 

the analysis area, the Little Deschutes River is designated as Wild and Scenic. A management Plan has 

been completed and it is classified as a Recreational River. 

All activity along the Little Deschutes River would occur outside the riparian buffers, which is a 

minimum of 300 feet on both sides of the river. All activities have been found to be consistent with the 

Little Deschutes Wild and Scenic Management Plan by maintaining activities subordinate to the 

landscape and reducing risk of a wide-scale disturbance event and improve the appearance of stands 

that resulted from the 1990s beetle epidemic. Unit description and findings are in Chapter 3, Wild and 

Scenic. 

Oregon Cascades Recreation Area (7,940 acres) - The goal of OCRA is to conserve, protect, and 

manage in a substantially undeveloped condition the unique values associated with the area. Dispersed 

recreation opportunities and wildlife, fish, and scenic resources are featured. 

The BLT project proposes no activity within the OCRA. 

Key Elk Area (2,368 acres) – Although not a specific management area designation, elk are found in 

certain key habitat areas, within which management will provide conditions needed to support certain 

numbers of summering and wintering elk. The Hemlock and Fly Key Elk Areas overlap the analysis 

boundary. Standards and Guidelines address recreation, road, and vegetation management. 

Activity is only planned in the Hemlock Key Elk area. While Alternatives B and C propose 223 acres 

and 92 acres of activities (respectively) that would result in a short-term loss of hiding and thermal 

cover, they would be proactive measures, and reduce the risk of long-term loss of forest, benefiting the 

Key Elk Area and adjacent homeowners (Chapter 3, Big Game). 

Management Indicator Species – This is not a specific management area; however, the Deschutes 

LRMP identifies a group of wildlife species as management indicator species (MIS). These species 

were selected because their welfare could be used as an indicator of other species dependent upon 

similar habitat conditions. The species selected for the Deschutes National Forest include the redtail 

hawk, golden eagle, osprey, peregrine falcon, northern bald eagle, northern spotted owl, northern 
BLT Project Environmental Impact Statement 

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396

goshawk, coopers hawk, sharp-shinned hawk, three-toed woodpecker, American marten, osprey, 

woodpeckers, great gray owl, great blue heron, waterfowl, wolverine, elk, mule deer, western big-eared 

bat, species associated with logs and down woody debris, and species associated with various plant 

communities and successional stages. 

Roadless – The analysis area does not contain any Inventoried Roadless Areas. The western boundary 

of activity abuts the Oregon Cascades Recreation Area, which may be considered unroaded for large 

portions. The BLT project would not likely forego future designation of potential roadless designation 

as it is surrounded by roads right up to the unroaded boundary, and it does not create any permanent 

roads. Therefore, access to OCRA would not change. For specific effects to unroaded characteristics, 

reference Unroaded in Chapter 3. 

Revised Continuation of Interim Management Direction Establishing Riparian, Ecosystem and 

Wildlife Standards for Timber Sales (Eastside Screens 53,718 acres) - Approximately two thirds of 

the project is within the area covered by this Regional Forester’s Forest Plan amendment. This 

amendment, referred to as the “Eastside Screens,” was the result of a large-scale planning effort to 

determine the best approach for maintaining future options concerning wildlife habitat associated with 

late and old structural stages, fish habitat, and old forest abundance. 

This project meets the Eastside Screens by: 

 Maintaining snags, down wood and Green Tree Replacements at specified levels. There would 

be minor loss of snags or down wood associated with occupational safety, clearing areas to 

deck logs, and for construction of temporary roads (Wildlife, Management Indicator Species). 

 Connections to Late and Old Structured forests are maintained (Chapter 3, Connectivity and 

Fragmentation). 

 There would be no loss of Late and Old Structured forests and no trees over 21 inches in 

diameter within the boundary of the eastside screens would be harvested (Chapter 3, Forested 

Vegetation). 

Inland Native Fish Strategy - Approximately two thirds of the project is within the area covered by this 

and it was intended to provide interim direction to protect habitat ad populations of resident fish outside 

of anadromous fish habitat. 

This project is consistent with the strategy and Riparian Management Objectives because: 

TM-1, RF-2a: Only one activity would occur within the Riparian Habitat Conservation Area, unit 1061 

(22 acres), and it would non-mechanically thin small diameter trees 3 inches and less in diameter and 

prescribed underburn outside permanently wetted areas. Otherwise, all other activities are outside of 

Category 1 for fish-bearing streams (300 feet on each side of the river). 

RF-2: The Deschutes National Forest has a road management plan that specifies road management for 

each road, criteria that govern road operation and maintenance and monitoring. No roads or landings 

are located within RHCAs. Potential sediment delivery to streams is discussed in the Hydrology 

section (Chapter 3) and it is considered a very low potential. 

For specific discussions regarding riparian goals and how this project meets or exceeds specific criteria 

such as water quality, stream channel integrity, and instream flows, reference the Hydrology section in 

Chapter 3 and Aquatic Conservation Strategy findings. 

Wildlife Standards and Guidelines 

Wildlife 
Environmental Impact Statement BLT Project 

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397

Goshawk

There would be no timber harvest or burning conducted within known northern goshawk nest stands. 

Nest stands would also be available in the 15 percent retention blocks and untreated stands across the 

BLT analysis area. If new occupied nests are discovered during project implementation Forest Plan 

standards and guidelines would be met. The project is consistent with the Forest Plan. 

Osprey

There would be no removal of existing nest trees. Thinning prescriptions would primarily remove trees 

less than 21 inches in diameter and maintain the largest trees in the stands as potential nesting habitat. 

Mitigation measures would protect active nest sites through seasonal restrictions. The project is 

consistent with the Forest Plan. 

Great Blue Heron

There would be no removal of existing nest trees. The live tree thinning prescription would primarily 

remove trees less than 21 inches in diameter and maintain the largest in the stands as potential nesting 

habitat. Emphasis is placed on providing large ponderosa pine (WL-36). Mitigation measures would 

protect active rookeries through seasonal restrictions on disturbing activities; however, there is no 

activity proposed within 1⁄4 mile of a known rookery. The project is consistent with the Forest Plan. 

Golden Eagle

There are no known golden eagle nests in the analysis area. There would be no removal of existing nest 

trees since none are known to occur. The live tree thinning prescription would primarily remove trees 

less than 21 inches in diameter and maintain the largest in the stands as potential nesting habitat. 

Restrictions for disturbance are included in mitigation measures. The project is consistent with the 

Forest Plan. 

Red-tailed Hawk

There would be no removal of existing nest trees. The green tree thinning prescription would primarily 

remove trees less than 21 inches in diameter and maintain the largest in the stands as potential nesting 

habitat. Active nest sites would be protected (WL-2, WL-3); restrictions on disturbance are included in 

mitigation measures. The project is consistent with the Forest Plan. 

Sharp-shinned and Cooper’s hawks

There would be no timber harvest or burning conducted within known or sharp-shinned or Cooper’s 

hawk nest stands; the one known Cooper’s hawk nests in the analysis area is located greater than one 

mile from the nearest proposed activity. Mitigation has been provided to prohibit disturbance to nesting 

pairs if located in the analysis area; active nest sites would be protected (WL-33). The BLT project 

would be consistent with the Deschutes LRMP. 

Northwest Forest Plan 

Approximately one third, 26,287 acres, of the project is within Northwest Forest Plan allocations, 

located in the western-most part of the analysis area. The purpose of the Northwest Forest Plan is for 

the management of habitat for late-successional and old-growth forest related species within the range 

of the northern spotted owl. The following Northwest Forest Plan land allocations are found in the 

analysis area: 

Matrix (10,190 acres) – Most timber harvest and silvicultural activities were specified to occur within 

these lands where suitable (ROD, C-39). 

The BLT project is consistent with Standards and Guidelines for Matrix lands because (Chapter 3, 

Forested Vegetation): 
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398

 At least fifteen (15) percent of each cutting unit is retained in a passive management scenario 

(NWFP Standard and Guideline, C-41). In addition, this Project Design Feature was applied to 

the entire BLT analysis area. 

 Prescriptions in the BLT analysis area call for thinning (HTH) and Improvement Cuts (HIM); 

therefore, green tree retention is met in patches greater than 2.5 acres and greater than 70 

percent of the cutting unit (NWFP Standard and Guideline, C-41). 

 Landscape areas where little late-successional forest persists should be managed to retain latesuccessional patches. This standard and guideline will be applied in fifth field watersheds (20 

to 200 square miles) in which federal forest lands are currently comprised of 15 percent or less 

late-successional forest (NWFP Standards and Guideline, C-44). 

 No trees over 21 inches in diameter would be harvested (Chapter 2, Project Design Features). 

 No activities planned in the BLT project would reduce LOS. Actually, LOS characteristics 

may be increased in stands classified as “mid” because the large structure would become more 

dominant after thinning. 

Congressionally Reserved (14,954 acres) – These areas maintain management direction of the 

Deschutes Forest Plan. They include lands with congressional designations that normally preclude 

scheduled timber harvest. In this analysis area, this allocation overlays Wild and Scenic Rivers 

designation for the Little Deschutes River. The BLT project has been designed to be consistent with 

the Little Deschutes Wild and Scenic Management Plan (Chapter 3). 

Riparian Reserve (11,998 acres) – As part of the Northwest Forest Plan’s Aquatic Conservation 

Strategy and Inland Native Fish Strategy (east of the Northwest Forest Plan), Riparian Reserves are 

lands along streams and unstable and potentially unstable areas where special standards and guidelines 

direct land use. The objective is to restore and maintain the health of watersheds and the aquatic 

ecosystems they contain. Riparian Reserves overlap the Management Allocations listed above. The 

BLT Vegetation Management Project only proposes small diameter thinning and prescribed burning in 

one unit within Riparian Reserves. 

“The intent is to ensure that a decision maker must find that the proposed management activity is 

consistent with the Aquatic Conservation Strategy objectives. In order to make the finding that a 

project or management action ‘meets’ or ‘does not prevent attainment’ of the Aquatic Conservation 

Strategy objectives, the analysis must include a description of the existing condition, a description of 

the range of natural variability of the important physical and biological components of a given 

watershed, and how the proposed project or management action maintains the existing condition or 

moves it within the range of natural variability” (1994 ROD, Attachment B, p. B-10). 

The existing condition discussion, including biological and physical components of the riparian 

condition, is found in soil quality, hydrology, and fisheries sections in Chapter 3 of this FEIS. These 

components are closely associated with the vegetative condition. Additional discussion on the 

transportation system, Best Management Practices, and effects on Riparian Reserves is also found in 

this analysis (Chapter 3 and Appendix A). 

All alternatives in the BLT project comply with the Riparian Reserve Standards and Guidelines as 

specified in the Northwest Forest Plan. Only one unit (1061) overlaps reserve boundaries within 

INFISH and Riparian Habitat Conservation Area objectives. Activities include non-mechanical small 

diameter thinning and prescribed burning. 
Environmental Impact Statement BLT Project 

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In summary, this active management would maintain the components of the nine objectives. The 

project follows the Aquatic Conservation Strategy by meeting the nine objectives through an 

interdisciplinary process, as described in the section titled “Hydrology” in this analysis. Retention of 

large trees on the landscape while reducing risk of wide-scale disturbance processes is the goal for this 

project. This action would more closely follow the reference condition, or Historic Range of 

Variability as defined “...vegetation, disturbance regimes, and environmental conditions that are 

minimally altered by 20th century management activities, but may reflect patterns or conditions 

resulting from interactions of aboriginal peoples with their environments.” Active management 

prescribed under Alternatives B, C and D would not change that condition. In the District Landscape 

Analysis Process, the following priorities in upland vegetation were identified: 

• Retention of large trees on the landscape. 

• Development of replacement trees as large trees inevitably are lost from the landscape. 

• Resilience of forest stands to disturbance agents (insects and fire). 

Proposed activities within the BLT Project were developed to address these priorities. 

Standards and Guidelines 

The BLT project is consistent with the Deschutes National Forest Plan, including all plan 

amendments in effect on the date of decision because: 

Bats

The BLT project is consistent with the standards and guidelines for the protection of bat species by: 

• Conducting searches – There are no known caves, mines, or wooden bridges within the analysis 

area to search and buildings that may provide roosting habitat are scarce on the District. Nondestructive searches are not feasible for snags and there are very few known rock outcroppings 

and pressure ridges within the analysis area. Therefore, measures and project design criteria for 

15 percent retention within units, retention of snags, and avoidance of land features with 

potential for bats has been incorporated. 

• Identifying likely bat use – existing condition and discussions in the consequences section 

identifies likely seasonal use and biological requirements. 

• Identifying conditions which specific measures will be applied to project plans – No special 

conditions are needed. 

• Establishing conditions under which specific mitigation measures will be applied – No seasonal 

restrictions are needed. 

• Describing various no-harvest buffer widths to fit specific habitat conditions – No no-harvest 

buffers are needed because there are no known potential habitats within the BLT analysis area. 

Great gray owl

Thinning and fuels reduction activities would focus on the retention of the largest and most dominant 

live trees on the landscape. There are no known nests within the analysis area, however if discovered, 

Project Design Features include a no-harvest buffer of 300 feet around meadows and natural openings, 

and a 1⁄4 mile protection zone around known nest sites. 

Threatened, Endangered, and Sensitive Plants: Bryophytes, Fungi, Lichens and Vascular Plants

There are no known Threatened, Endangered or Sensitive (TES) plants in or near the analysis area. 

The project was updated to include the most current sensitive plant list for January 2008 (Chapter 3, 

Botany).

White-headed woodpecker, black-backed woodpecker, pygmy nuthatch, and flammulated owl

(Northwest Forest Plan Implementation Strategy and Deschutes National Forest Wildlife Tree 

and Log Strategy) 
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“Snags over 20 inches dbh may be marked for cutting only after retaining the best 

available snags (considering size, longevity, etc.) in sufficient numbers to meet 100 

percent of the potential population levels of these four species.” 

The Record of Decision puts those levels for white-headed woodpeckers at 0.6 snags per acre at least 

15 inches in diameter, black-backed woodpecker at 0.12 snags per acre at least 17 inches in diameter. 

Meeting standards for white-headed woodpecker was presumed in the amendment to provide for the 

pygmy nuthatch since they share the same habitat. 

Flammulated owls utilize cavities occurring naturally or created by woodpeckers. The assumption is 

that standards and guidelines for snags and green-tree replacements for woodpeckers and other primary 

cavity nesting species in existing National Land and resource Management Plans would provide for 

flammulated owls. The Record of Decision also states that provision must be additive, “provisions of 

snags for other cavity-nesting species, including primary cavity nesters, must be added to the 

requirements for these two woodpecker species (black-backed and white-headed woodpeckers).” 

 

The Deschutes National Forest developed their Wildlife Tree and Log Implementation Strategy to 

provide for various levels of percent populations levels. It includes adding the various woodpeckers 

together by habitat types. These standards call for 3.87 snags/acre in ponderosa pine, and 4.05 snags 

per acre in mixed conifer (adding in black-backed from NWFP), with 0.6 snags/acre greater than 20 

inches in diameter. 

The action alternatives do not remove any snags. Only those that pose an occupational hazard, 

associated with log landings or construction of temporary roads would be felled. Monitoring by harvest 

inspectors show approximately 1 percent of snags are lost through harvest. The project is consistent 

with the Deschutes National Forest Wildlife Tree and Log Strategy and NWFP implementation strategy 

(Chapter 3, Management Indicator Species). 

National Fire Plan 

The National Fire Plan (2000) established an intensive, long-term hazardous fuels reduction program in 

response to the risks posed by heavy fuel loads across the National Forest System. Hazardous fuels 

reduction treatments encouraged by the National Fire Plan are designed to reduce the risks of 

catastrophic wildland fire to people, communities and natural resources while moving forest and 

rangeland ecosystems toward their historical structure, function, diversity, and dynamics. Goals are 

accomplished by removing or modifying wildland fuels to reduce the potential for severe fire behavior, 

lessen the post-fire damage, and limit the spread and/or proliferation of invasive species and forest 

diseases. Management activities may include prescribed fire, mechanical and non-mechanical thinning 

of forested stands, application of herbicides, and grazing. Fuels reduction activities are increasingly 

focused within the expanding wildland/urban interface areas, where private homes and communities lie 

in close proximity to public land. 

Walker Range Community Wildfire Protection Plan (CWPP) 

The purpose of the Walker Range CWPP is to protect human life and reduce property loss due to 

wildland fire in the communities and surrounding areas of the Crescent, Crescent-Odell Lakes, 

Chemult, and Oregon Outback Rural Fire Protection Districts and the Walker Range Forest Protective 

Association. Although reducing the threat of wildland fire is the primary motivation behind this plan, 

managing the forests and rangelands for hazardous fuel reduction and fire resilience is only one part of 

the larger picture. Residents and visitors alike want healthy, fire-resilient forests that provide habitat 

for wildlife, recreation opportunities, and scenic beauty (CWPP 2005). 
Environmental Impact Statement BLT Project 

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401

The goals of the CWPP are to increase public understanding of living in a fire-adapted ecosystem, 

instill a sense of personal responsibility for taking preventative actions regarding wildland fire, restore 

fire-adapted ecosystems, and improve the landscape’s fire resilience while protecting other social and 

ecological values. To achieve these goals the plan includes the following objectives: 

• assess the risk and hazard of wildland fire on all lands within the plan boundary, 

• identify priorities for fuel reduction projects, 

• examine emergency operations within the plan area and identify areas to improve community 

response and preparedness for wildland fire, 

• create an action plan that prioritizes actions to reduce hazardous fuels, enhance emergency 

response, and 

• strengthen public education and prevention activities (CWPP 2005). 

Several large recent wildfires on the Deschutes National Forest that have originated well away from 

subdivisions and communities have rapidly burned through forests and threatened many populated 

areas. The entire BLT analysis area is within the Walker Range CWPP. 

Standards and Guidelines and Best Management Practices for 

Protection of Soil and Water Quality 

The following Deschutes National Forest Standards and Guidelines and Best Management Practices 

(BMPs) are applicable to the sites in the analysis area where management activities are proposed. 

These Standards and Guidelines and BMPs would protect soil productivity, maintain slope stability and 

all stream courses would be protected. All levels of instream large woody material would not change 

and would be protected. There are no harvest units proposed within Riparian Reserves or Riparian 

Habitat Conservation Areas. 

Deschutes National Forest Standards and Guidelines 

• SL-1 Soil Productivity "Land management activities shall be planned and conducted to 

maintain or enhance soil productivity and stability.” 

• SL-3 Leave a minimum of 80 percent of an activity area in a condition of acceptable 

productivity potential for trees and other managed vegetation following land management 

activities. Including all system roads, landing, spur roads, and skid roads. 

• SL-4 Any sites where this direction cannot be met will require rehabilitation. Applicable Best 

Management Practices include T-9 and T-11. 

• SL-5 The use of mechanical equipment in sensitive soil areas will be regulated to protect the 

soil resource. Operations will be restricted to existing trails and roads when feasible. 

• SL-6, which provides ground cover objectives to minimize accelerated erosion rates on 

disturbed sites with unprotected soils. 

Guidelines (FSM 2500, R-6 supplement 2500-98-1) describe conditions detrimental to soil productivity 

and outlines Soil Quality Standards to limit the extent of these conditions to less than 20 percent of an 

activity area. Detrimental soil conditions are described in the Soil Quality Standards as follows: 

• Detrimental soil compaction in volcanic ash/pumice soils is an increase in soil bulk density of 

20 percent or greater over the undisturbed level. 

• Detrimental puddling occurs when the depth of ruts or imprints is six inches or greater. 

• Detrimental displacement is the removal of more than 50 percent of the A horizon from an area 

greater than 100 (10’ x 10’) square feet and at least 5 feet in width. 

• Detrimental burn damage requires significant color change of the mineral soil surface in an area 

greater than 100 (10’ x 10’) square feet to an oxidized reddish color, with the next one-half inch 

below blackened from organic matter charring as a result of heat conducted from the fire. 
BLT Project Environmental Impact Statement 

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• Detrimental erosion requires visual evidence of surface loss over an area greater than 100 (10’ 

x 10’) square feet, rills or gullies, and/or water quality degradation from sediment or nutrient 

enrichment. 

Under Alternatives B, C, and D, the amount of disturbed soil associated with log landings and skid 

trails would be limited to the minimum necessary to achieve management objectives. Project Design 

Features, management requirements, and Best Management Practices (BMPs) built into alternative are 

all designed to avoid or minimize potentially adverse impacts to the soil resource. Compliance with 

LRMP standard and guideline SL-5 (LRMP 4-70) is addressed by using advanced logging systems on 

slopes greater than 30 percent, restricting numbers of equipment passes, using existing harvest 

transportation systems, and seasonal restrictions on wet areas. Best Management Practices for Timber 

Management and Road Systems would be applied to protect the soil surface and control erosion on and 

adjacent to roads and logging facilities that would be used during project implementation. These 

conservation practices would be implemented during and following project activities to meet the stated 

objectives for protecting and maintaining soil productivity. The Ranger District and Forest has had 

success using these practices and is assured they can be implemented by contract provision. 

Soil restoration treatments would be applied to rectify impacts by reducing the amount of detrimentally 

compacted soil dedicated to specific management areas of the proposed activity areas. Restoration 

treatments, such as subsoiling, are designed to promote maintenance or enhancement of soil quality. 

These conservation practices comply with LRMP interpretations of Forest-wide standards and 

guidelines SL-3 and SL-4 (Final Interpretations, Document 96-01, Soil Productivity, 1996), and 

Regional policy (FSM 2520, R-6 Supplement No. 2500-98-1) for planning and implementing 

management activities. 

Under Alternative B, detrimental soil conditions after restoration would remain on 1,524 acres, 

followed by 1,166 acres in Alternative C and 468 in Alternative D. These estimates are very 

conservative. All actives would be consistent with Forest and Regional standards and guidelines for 

soil productivity. It is expected that enough fallen trees and other organic materials would be available 

after harvest activities to meet recommended guidelines for coarse woody debris retention in the shortterm. Therefore, the proposed actions comply with Regional and LRMP standards and guidelines for 

maintaining soil productivity within all proposed activity areas. 

Best Management Practices Applied in the BLT Analysis Area 

Best Management Practices were utilized in designing the proposed activities in the BLT analysis area, 

with the following requirements in place: 

1. Select and design BMPs based on site-specific conditions, technical and economic feasibility, and 

water quality standards for those waters potentially impacted. 

2. Implement and enforce BMPs. 

3. Monitor BMPs to ensure correct application and effectiveness as designed in attaining water quality 

standards. 

4. Mitigate to minimize impacts caused by activities when BMPs do not perform as expected. 

5. Adjust BMPs when there is evidence that beneficial uses are not protected and water quality 

standards are not achieved. Evaluate the adequacy of water quality criteria for assuring protection of 

beneficial uses. Recommend adjustments to water quality standards as appropriate.” 

Timber Harvest Best Management Practices: 

• T-2 Title: Timber Harvest Unit Design 

Objective: To ensure that timber harvest unit design will create favorable conditions of 

water flow, water quality, and fish habitat. 

• T-3 Title: Use of Erosion Potentials Assessment for Timber Harvest Design. 
Environmental Impact Statement BLT Project 

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403

Objective: To prevent downstream water quality degradation by the timely identification of 

areas with high erosion potential and adjustment of harvest unit design. 

• T-4 Title: Use of Sale Area Maps for Designating Water Quality Protection Needs. 

Objective: To delineate location of protection areas and available water sources as a guide 

for both the Purchaser and the Sale Administration. 

• T-5 Title: Limiting the Operating Period of Timber Sale Activities. 

Objective: To ensure that the purchaser conducts operations in a timely manner, within the 

time period specified in the Timber Sale Contract. 

• T-6 Title: Protection of Unstable Lands 

Objective: To provide for identification and appropriate management prescription for 

unstable lands. 

• T-7 Title: Streamside Management Unit Designation 

Objective: To designate a riparian area or zone along streams and wetlands where 

prescriptions are made that will minimize potential effects from logging and related land 

disturbance activities on water quality and beneficial uses. 

• T-8 Title: Stream Course Protection 

Objectives: (1) To protect the natural flow of streams, (2) to provide unobstructed passage 

of streamflow and (3) to prevent sediment and pollutants from entering streams. 

• T-10 Title: Log Landing Location. 

Objective: To located landings in such a way as to minimize creation of hazardous 

watershed condition. 

• T-12 Title: Suspended Log Yarding in Timber Harvest. 

Objectives: 1. To protect soils from excessive disturbance, and 2. Maintain the integrity of 

the Riparian Reserve Areas and other sensitive areas. 

• T-13 Title: Erosion Prevention and Control Measures During Timber Sale Operations. 

Objective: To ensure the Purchaser's operations shall be conducted to minimize soil 

erosion. 

• T-14 Title: Revegetation of Areas Disturbed by Harvest Activities. 

Objective: To establish a vegetation cover on disturbed sites and to prevent erosion and 

sedimentation. 

• T-15 Title: Log Landing Erosion Prevention and Control. 

Objective: To reduce the impacts of erosion and subsequent sedimentation, on log landings, 

by use of mitigation measures. 

• T-18 Title: Erosion Control Structure Maintenance. 

Objective: To ensure that the constructed erosion control structures are stabilized and 

working. 

• T-19 Title: Acceptance of Timber Sale Erosion Control measures Before Sale Closure. 

Objective: To assure the adequacy of required erosion control work on timber sales. 

• T-22 Title: Modification of the Timber Sale Contract. 

Objective: To modify the Timber Sale Contract if new circumstances or conditions arise 

and indicate that the timber sale will irreversibly damage soil, water or watershed values. 

 

Road System Best Management Practices: 

• R-1 Title: Guidelines for the Location and Design of Roads. 

Objective: To located and design roads with minimal resource damage. 

• R-2 Title: Erosion Control Plan 

Objective: To limit and mitigate erosion and sedimentation through effective planning 

prior to initiation of road constructions activities and through effective contract 

administration during construction. 

• R-3 Title: Timing of Construction Activities. 
BLT Project Environmental Impact Statement 

Appendix A 

404

Objection: To minimize erosion by conducting road construction operation during minimal 

runoff periods. 

• R-6 Title: Dispersion of Subsurface Drainage Associated with Roads. 

Objective: To minimize the possibilities of roadbed and cut or fill slope failure and 

subsequent production of sediment: 

• R-9 Title: Timely Erosion Control Measures on Incompleted Roads and Stream Crossing. 

Objective: To minimize erosion of and sedimentation from disturbed ground on incomplete 

projects. 

• R-13 Title: Diversion of Flow Around Construction Sites 

Objective: (1) To ensure all stream diversion are carefully planned, (2) to minimize 

downstream sedimentation, (3) to restore stream channels to their natural grade, condition, 

and alignment as soon as possible. 

• R-18 Title: Maintenance of Roads. 

Objective: To maintain roads in a manner which provides for water quality protection by 

controlling the placement of waste material, keeping drainage facilities open, and by 

repairing ruts and failures to reduce sedimentation and erosion. 

Prescribe Fire Best Management Practices 

• F-2 Title: Consideration of Water Quality in Formulating Prescribed Fire Prescriptions. 

Objective: To provide for water quality protection while achieving the management 

objectives through the use of prescribed fire. 

• F-3 Title: Protection of Water Quality during Prescribed Fire Operations. 

Objectives: To maintain soil productivity. 

Additional Consistency _______________________________ 

State and Local Laws 

Implementation of all alternatives would be consistent with State and local laws, land use, and 

environmental policies. Action alternatives have been found consistent with State of Oregon 

requirements in accordance with the Clean Air and Water Acts for protection (Chapter 3, Air and Water 

Quality). Collaboration with the Oregon Department of Fish and Wildlife has occurred, particularly 

with disclosures for effects to big game. 

National Historic Preservation Act 

A cultural resource inventory has been completed for the analysis area. On June 09, 2006, the 

Deschutes National Forest completed the “Project Review for Heritage Resources under the Terms of 

the 2004 Programmatic Agreement” with the Oregon State Historic Preservation Officer (SHPO). The 

activities in the selected alternative have been designed to have No Effect or No Adverse Effect to 

cultural resource sites through both protection and avoidance. 

FEIS for Managing Competing and Unwanted Vegetation and the 

Mediated Agreement 

The BLT project is consistent with the portion of the remaining mediated agreement because vegetative 

prescriptions have adopted a prevent strategy to forego the need for future reduction of competing and 

unwanted vegetation. There is no planting of conifer seedlings prescribed for this project. 
Environmental Impact Statement BLT Project

 Appendix B 

405

APPENDIX B – HISTORICAL RANGE OF VARIATION 

(HRV) FOR SNAGS AND DOWN WOOD 

To simplify analysis, a single HRV for snag and down wood densities for each habitat type was 

developed. HRV was determined by combining structure classes using a weighted average based on 

the DecAID vegetation data for snags on unharvested plots and HRV from Viable Ecosytems modeling. 

Data from unharvested stands provides a reference condition in the various habitat types for distribution 

of snag and down wood size and densities across a large landscape. 

DecAID structural stages include Open, Small and Large. In DecAID, the Open structural stage is 

everything from grass/forbs to sapling and pole sized trees where tree stocking is less than 10 percent or 

where tree stocking is equal to or greater than 10 percent and quadratic mean diameter (QMD) is 1-9 

inches in diameter. The small structural stage includes a range of conditions that consists of small trees 

with an open canopy to medium trees with a closed multi-storied canopy where tree stocking is equal to 

or greater than 10 percent and QMD is 10-19 inches in diameter. The Large structural stage includes 

the conditions that have stocking greater than or equal to 10 percent and trees with QMD greater than or 

equal to 20 inches in diameter and includes open and closed multistoried canopies. 

Viable Ecosystems has 5 structural stages: 

• Grass/forb/shrub – trees may be present but are not the dominant vegetation 

• Seedling and sapling – the majority of the trees are less than 4.9 inches in diameter 

• Pole – the majority of trees are between 5 and 8.9 inches in diameter 

• Small – the majority of trees are between 9 and 20.9 inches in diameter 

• Medium and Large – the majority of trees are 21 inches in diameter or larger 

The 5 structural stages of Viable Ecosystems were combined to match with the three structural stages in 

DecAID as follows: 

Table B-1. Structural Stages in DecAID 

DecAID Viable 

Open Grass/forb/shrub, Seedling and sapling, Pole 

Small Small 

Large Medium and Large 

HRV from Viable Ecosystems was lumped to include the lowest and the highest values from the 

structural categories to develop a range for the DecAID structural stage. Then a matrix was set up to 

weight densities using the minimum and maximum values. For example, the table is the matrix set up 

for Ponderosa Pine/Douglas Fir (PP/DF) habitat type. Values for densities were taken DecAID Figures 

PP/DF_O.Inv-14, PP/DF_S.Inv-14 and PP/DF_S.Inv-14. So the data from the Figure below shows up 

in second line of shaded data in the table. Numbers have been converted from metric to English units. 
BLT Project Environmental Impact Statement 

Appendix B 

406

Results of Snag and Down Wood Analysis 

Analysis of changes in dead wood over time showed there were little to no differences between 

alternatives. The following tables provide additional information on the snag density and distribution 

analysis over time. All tables include the percent of the landscape at the various density levels by year 

post harvest. This is followed by tables that provide additional information on the results of the 

analysis for down wood over time. 
Environmental Impact Statement BLT Project

 Appendix B 

407

Table B-2. Ponderosa Pine/Douglas-fir Habitat 

For Snags 

≥10" dbh 

Snag/acre 

in PP/DF 0 0 - 4 4 - 12 12 - 24 24 - 36 36+ 

current 62.3% 25.5% 11.0% 0.9% 0.3% 0.1% 

Existing Min. HRV 54.0% 17.0% 11.0% 3.0% 0.0% 0.0% 

Max. HRV 62.0% 27.0% 16.0% 5.0% 1.0% 1.0% 

 

Yrs Post 

Harvest 

10 61.6% 26.0% 11.0% 1.0% 0.3% 0.1% 

ALT A 20 61.2% 26.3% 11.0% 1.1% 0.4% 0.1% 

50 60.3% 26.9% 11.1% 1.2% 0.4% 0.2% 

 

10 61.7% 25.8% 11.0% 1.0% 0.3% 0.1% 

ALT B 20 61.2% 26.1% 11.0% 1.0% 0.4% 0.1% 

50 60.2% 26.6% 11.0% 1.2% 0.4% 0.2% 

 

10 61.7% 25.8% 11.0% 1.0% 0.3% 0.1% 

ALT C 20 61.3% 26.2% 11.0% 1.0% 0.4% 0.1% 

50 60.4% 26.7% 11.1% 1.2% 0.4% 0.2% 

 

10 61.6% 25.9% 11.0% 1.0% 0.3% 0.1% 

ALT D 20 61.2% 26.2% 11.0% 1.0% 0.4% 0.1% 

50 60.1% 26.7% 11.0% 1.2% 0.4% 0.2% 

For Snags 

≥20" dbh 

Snag/acre 

in PP/DF 0 0-2 2-4 4-6 6-10 10-18 18+ 

current 84.8% 12.4% 2.1% 0.7% 0.0% 0.0% 0.0% 

Existing Min. HRV 67.0% 14.0% 6.0% 0.0% 1.0% 0.0% 0.0% 

Max. HRV 77.0% 20.0% 10.0% 2.0% 2.0% 0.0% 0.0% 

 

Yrs Post 

Harvest 

10 84.4% 12.6% 2.2% 0.8% 0.0% 0.0% 0.0% 

ALT A 20 84.1% 12.8% 2.3% 0.8% 0.0% 0.0% 0.0% 

50 83.4% 13.2% 2.5% 0.9% 0.0% 0.0% 0.0% 

 

10 84.3% 12.6% 2.3% 0.7% 0.0% 0.0% 0.0% 

ALT B 20 84.0% 12.8% 2.3% 0.8% 0.0% 0.0% 0.0% 

50 83.2% 13.1% 2.5% 0.9% 0.0% 0.0% 0.0% 

 

10 84.4% 12.6% 2.3% 0.7% 0.0% 0.0% 0.0% 

ALT C 20 84.1% 12.8% 2.3% 0.8% 0.0% 0.0% 0.0% 

50 83.4% 13.2% 2.5% 0.9% 0.0% 0.0% 0.0% 

 

10 84.4% 12.6% 2.2% 0.8% 0.0% 0.0% 0.0% 

ALT D 20 84.0% 12.8% 2.3% 0.8% 0.0% 0.0% 0.0% 

50 83.2% 13.1% 2.5% 0.9% 0.0% 0.0% 0.0% 
BLT Project Environmental Impact Statement 

Appendix B 

408

Table B-4. Eastside Mixed Conifer Habitat 

For Snags 

≥10" dbh 

Snag/acre 

in EMC 0 0 - 6 6-12 12-24 24 - 36 36+ 

current 27.9% 42.2% 11.6% 14.0% 3.0% 1.3% 

Existing HRV Min 18.0% 31.0% 15.0% 15.0% 7.0% 5.0% 

HRV Max 25.0% 37.0% 17.0% 23.0% 10.0% 8.0% 

 

Yrs Post 

Harvest 

10 25.8% 42.9% 11.6% 14.6% 3.3% 1.7% 

ALT A 20 24.0% 43.5% 11.7% 15.1% 3.7% 2.0% 

50 19.9% 45.1% 11.8% 16.2% 4.4% 2.6% 

 

10 25.9% 42.9% 11.6% 14.5% 3.3% 1.7% 

ALT B 20 24.1% 43.5% 11.6% 15.1% 3.7% 2.0% 

50 19.9% 45.1% 11.8% 16.1% 4.4% 2.6% 

 

10 25.9% 42.9% 11.6% 14.5% 3.3% 1.7% 

ALT C 20 24.1% 43.5% 11.6% 15.1% 3.7% 2.0% 

50 19.9% 45.1% 11.8% 16.1% 4.4% 2.6% 

 

10 25.9% 42.9% 11.6% 14.6% 3.3% 1.7% 

ALT D 20 24.0% 43.5% 11.6% 15.1% 3.7% 2.0% 

50 19.9% 45.1% 11.8% 16.2% 4.4% 2.6% 

For Snags 

≥20" dbh 

Snag/acre 

in EMC 0 0-2 2-4 4-6 6-10 10-18 18+ 

current 47.4% 36.2% 12.1% 0.0% 1.3% 0.2% 0.1% 

Existing Miin. 31.0% 14.0% 14.0% 10.0% 10.0% 5.0% 1.0% 

Max. 40.0% 20.0% 18.0% 13.0% 15.0% 7.0% 2.0% 

 

Yrs Post 

Harvest 

10 43.8% 38.9% 11.9% 0.0% 1.4% 0.3% 0.3% 

ALT A 20 40.9% 41.2% 11.8% 0.0% 1.5% 0.3% 0.4% 

50 34.7% 46.0% 11.6% 0.0% 1.6% 0.4% 0.6% 

 

10 44.0% 38.8% 11.9% 0.0% 1.4% 0.3% 0.3% 

ALT B 20 41.0% 41.1% 11.8% 0.0% 1.5% 0.3% 0.4% 

50 34.8% 45.9% 11.6% 0.0% 1.6% 0.4% 0.6% 

 

10 44.0% 38.8% 11.9% 0.0% 1.4% 0.3% 0.3% 

ALT C 20 41.0% 41.1% 11.8% 0.0% 1.5% 0.3% 0.4% 

50 34.8% 45.9% 11.6% 0.0% 1.6% 0.4% 0.6% 

 

10 43.9% 38.9% 11.9% 0.0% 1.4% 0.3% 0.3% 

ALT D 20 40.9% 41.1% 11.8% 0.0% 1.5% 0.3% 0.4% 

50 34.8% 46.0% 11.6% 0.0% 1.6% 0.4% 0.6% 
Environmental Impact Statement BLT Project

 Appendix B 

409

Table B-5. Lodgepole Pine Habitat 

For Snags 

≥10" dbh 

Snag/acre 

in LP 0 0-6 6-12 12-24 24-36 36+ 

current 58.2% 32.0% 7.5% 1.5% 0.3% 0.5% 

Existing Min 9.0% 5.0% 8.0% 6.0% 4.0% 4.0% 

Max 33.0% 18.0% 20.0% 15.0% 10.0% 9.0% 

 

Yrs Post 

Harvest 

10 57.2% 32.3% 7.9% 1.7% 0.4% 0.5% 

ALT A 20 56.5% 32.6% 8.2% 1.8% 0.4% 0.6% 

50 55.3% 33.2% 8.4% 2.1% 0.4% 0.7% 

 

10 57.3% 32.4% 7.8% 1.6% 0.4% 0.5% 

ALT B 20 56.6% 32.6% 8.0% 1.8% 0.4% 0.6% 

50 55.3% 33.2% 8.3% 2.1% 0.4% 0.6% 

 

10 57.3% 32.4% 7.8% 1.6% 0.4% 0.5% 

ALTC 20 56.5% 32.6% 8.1% 1.8% 0.4% 0.6% 

50 55.3% 33.2% 8.3% 2.1% 0.4% 0.6% 

 

10 57.2% 32.3% 7.9% 1.7% 0.4% 0.5% 

ALT D 20 56.5% 32.6% 8.1% 1.8% 0.4% 0.6% 

50 55.2% 33.2% 8.3% 2.1% 0.4% 0.7% 

For Snags 

≥20" dbh 

Snag/acre 

in LP 0 0-2 2-4 4-6 6-10 10-18 18+ 

current 86.3% 10.6% 1.7% 1.3% 0.1% 0.0% 0.0% 

Existing Min. HRV 25.0% 4.0% 4.0% 1.0% 1.0% 0.0% 0.0% 

Max. HRV 79.0% 9.0% 10.0% 4.0% 2.0% 1.0% 0.0% 

 Yrs Post 

Harvest 

10 85.7% 10.9% 1.8% 1.4% 0.1% 0.0% 0.0% 

ALT A 20 85.2% 11.2% 1.9% 1.5% 0.1% 0.0% 0.0% 

50 84.1% 11.9% 2.0% 1.8% 0.1% 0.0% 0.0% 

 

10 85.8% 10.9% 1.8% 1.4% 0.1% 0.0% 0.0% 

ALT B 20 85.2% 11.2% 1.9% 1.5% 0.1% 0.0% 0.0% 

50 84.1% 11.9% 2.0% 1.8% 0.1% 0.0% 0.0% 

 

10 85.8% 10.9% 1.8% 1.4% 0.1% 0.0% 0.0% 

ALT C 20 85.2% 11.2% 1.9% 1.5% 0.1% 0.0% 0.0% 

50 84.1% 11.9% 2.0% 1.8% 0.1% 0.0% 0.0% 

 

10 85.7% 10.9% 1.8% 1.4% 0.1% 0.0% 0.0% 

ALT D 20 85.2% 11.2% 1.9% 1.5% 0.1% 0.0% 0.0% 

50 84.0% 11.9% 2.0% 1.8% 0.1% 0.0% 0.0% 
BLT Project Environmental Impact Statement 

Appendix B 

410

DOWN WOOD DISTRIBUTION OVER TIME ANALYSIS RESULTS 

All tables include the percent of the landscape at the various densities levels by year post harvest. 

Table B-6. Ponderosa Pine/Douglas-Fir Habitat 

Down wood 

≥5" dbh 

% down wood 

cover in PP/DF 0 0 - 4 4-8 8-10 >10 

current 10.5% 82.7% 4.9% 0.8% 1.1% 

Existing HRV Min 37.0% 51.0% 2.0% 0.0% 0.0% 

HRV Max 46.0% 60.0% 3.0% 0.0% 0.0% 

 Yrs post harvest 

10 10.3% 82.7% 5.1% 0.8% 1.2% 

ALT A 20 10.2% 82.6% 5.2% 0.8% 1.2% 

50 10.0% 82.5% 5.5% 0.8% 1.2% 

 

10 10.4% 82.7% 5.0% 0.8% 1.1% 

ALT B 20 10.3% 82.6% 5.1% 0.8% 1.2% 

50 10.0% 82.3% 5.4% 0.8% 1.2% 

 

10 10.4% 82.7% 5.0% 0.8% 1.1% 

ALT C 20 10.3% 82.7% 5.1% 0.8% 1.2% 

50 10.0% 82.5% 5.4% 0.8% 1.2% 

 

10 10.3% 82.6% 5.0% 0.8% 1.2% 

ALT D 20 10.2% 82.6% 5.1% 0.8% 1.2% 

50 10.0% 82.3% 5.4% 0.8% 1.2% 

Down wood 

≥20" dbh 

% down wood 

cover in PP/DF 0 0 - 4 4-8 8-10 >10 

current 84.8% 15.2% 0.1% 0.0% 0.0% 

Existing HRV Min 69.0% 19.0% 0.0% 0.0% 0.0% 

HRV Max 80.0% 30.0% 0.0% 0.0% 0.0% 

 Yrs post harvest 

10 84.6% 15.4% 0.1% 0.0% 0.0% 

ALT A 20 84.3% 15.6% 0.1% 0.0% 0.0% 

50 83.5% 16.4% 0.1% 0.0% 0.0% 

 

10 84.6% 15.2% 0.1% 0.0% 0.0% 

ALT B 20 84.3% 15.5% 0.1% 0.0% 0.0% 

50 83.3% 16.3% 0.1% 0.0% 0.0% 

 

10 84.7% 15.3% 0.1% 0.0% 0.0% 

ALT C 20 84.4% 15.5% 0.1% 0.0% 0.0% 

50 83.5% 16.4% 0.1% 0.0% 0.0% 

 

10 84.5% 15.3% 0.1% 0.0% 0.0% 

ALT D 20 84.2% 15.5% 0.1% 0.0% 0.0% 

50 83.2% 16.3% 0.1% 0.0% 0.0% 
Environmental Impact Statement BLT Project

 Appendix B 

411

Table B-7. Eastside Mixed Conifer Habitat 

Down wood 

≥5" dbh 

% down wood 

cover in EMC 0 0 - 4 4-8 8-10 >10 

current 4.5% 75.6% 16.1% 4.3% 1.3% 

Existing HRV Min 22.0% 53.0% 13.0% 2.0% 1.0% 

HRV Max 30.0% 54.0% 19.0% 3.0% 2.0% 

 Yrs post harvest 

10 4.3% 74.5% 16.9% 3.6% 1.2% 

ALT A 20 4.2% 74.0% 17.5% 3.1% 1.2% 

50 4.1% 73.6% 18.6% 2.5% 1.2% 

 

10 4.3% 74.4% 16.9% 3.6% 1.2% 

ALT B 20 4.2% 74.0% 17.5% 3.2% 1.2% 

50 4.1% 73.6% 18.6% 2.5% 1.2% 

 

10 4.3% 74.4% 16.9% 3.6% 1.2% 

ALT C 20 4.2% 74.0% 17.5% 3.2% 1.2% 

50 4.1% 73.6% 18.6% 2.5% 1.2% 

 

10 4.3% 74.4% 16.9% 3.6% 1.2% 

ALT D 20 4.2% 74.0% 17.5% 3.1% 1.2% 

50 4.1% 73.6% 18.6% 2.5% 1.2% 

Down wood 

≥20" dbh 

% down wood 

cover in EMC 0 0 - 4 4-8 8-10 >10 

current 78.3% 21.0% 0.7% 0.0% 0.0% 

Existing HRV Min 61.0% 27.0% 1.0% 1.0% 0.0% 

HRV Max 71.0% 36.0% 2.0% 2.0% 0.0% 

 Yrs post harvest 

10 77.6% 21.8% 0.7% 0.0% 0.0% 

ALT A 20 77.1% 22.3% 0.6% 0.0% 0.0% 

50 76.4% 23.0% 0.5% 0.0% 0.0% 

 

10 77.6% 21.8% 0.7% 0.0% 0.0% 

ALT B 20 77.1% 22.3% 0.6% 0.0% 0.0% 

50 76.4% 23.0% 0.5% 0.0% 0.0% 

 

10 77.6% 21.8% 0.7% 0.0% 0.0% 

ALT C 20 77.1% 22.3% 0.6% 0.0% 0.0% 

50 76.4% 23.0% 0.5% 0.0% 0.0% 

 

10 77.6% 21.8% 0.7% 0.0% 0.0% 

ALT D 20 77.1% 22.3% 0.6% 0.0% 0.0% 

50 76.5% 23.0% 0.5% 0.0% 0.0% 
BLT Project Environmental Impact Statement 

Appendix B 

412

Table B-8. Lodgepole Pine Habitat 

Down wood 

≥5" dbh 

% down wood 

cover in LP 0 0 - 4 4-8 8-10 >10 

current 9.2% 79.7% 8.6% 1.3% 1.2% 

Existing HRV Min 4.0% 18.0% 7.0% 3.0% 1.0% 

HRV Max 14.0% 58.0% 22.0% 7.0% 7.0% 

 Yrs post harvest 

10 8.6% 80.0% 8.9% 1.3% 1.2% 

ALT A 20 8.2% 80.2% 9.0% 1.4% 1.2% 

50 7.4% 80.5% 9.3% 1.4% 1.3% 

 

10 8.7% 80.0% 8.8% 1.3% 1.2% 

ALT B 20 8.3% 80.1% 9.0% 1.4% 1.2% 

50 7.5% 80.4% 9.3% 1.4% 1.3% 

 

10 8.7% 80.0% 8.8% 1.3% 1.2% 

ALT C 20 8.2% 80.2% 9.0% 1.4% 1.2% 

50 7.5% 80.4% 9.3% 1.4% 1.3% 

 

10 8.6% 80.0% 8.8% 1.3% 1.2% 

ALT D 20 8.2% 80.2% 9.0% 1.4% 1.2% 

50 7.5% 80.4% 9.3% 1.4% 1.3% 

Down wood 

≥20" dbh 

% down wood 

cover in LP 0 0 - 4 4-8 8-10 >10 

current 88.9% 11.0% 0.1% 0.0% 0.0% 

Existing HRV Min 27.0% 6.0% 1.0% 0.0% 0.0% 

HRV Max 84.0% 16.0% 2.0% 0.0% 0.0% 

 Yrs post harvest 

10 88.4% 11.5% 0.1% 0.0% 0.0% 

ALT A 20 88.0% 11.9% 0.1% 0.0% 0.0% 

50 87.0% 12.8% 0.1% 0.0% 0.0% 

 

10 88.4% 11.4% 0.1% 0.0% 0.0% 

ALT B 20 88.0% 11.8% 0.1% 0.0% 0.0% 

50 87.0% 12.8% 0.1% 0.0% 0.0% 

 

10 88.4% 11.4% 0.1% 0.0% 0.0% 

ALT C 20 88.0% 11.9% 0.1% 0.0% 0.0% 

50 87.0% 12.8% 0.1% 0.0% 0.0% 

 

10 88.4% 11.5% 0.1% 0.0% 0.0% 

ALT D 20 88.0% 11.9% 0.1% 0.0% 0.0% 

50 86.9% 12.8% 0.1% 0.0% 0.0% 
Environmental Impact Statement BLT Project

 Appendix C 

413

APPENDIX C – RESPONSE TO COMMENTS 

The opportunity to comment on the BLT project was provided in accordance with 36 CFR 215.5. The 

Federal Register notification for opportunity to comment was provided on October 3, 2008. A legal 

notice of the opportunity to comment was also published in The Bulletin, Bend, Oregon on October 3, 

2008. The comment period ended November 17, 2008. A complete environmental impact statement 

was mailed to 13 individuals, organizations, and agencies. All others were mailed a notification letter 

announcing the availability of the EIS, as it was posted to the Forest Service web site. 

During the public comment period, 6 responses were received. All comments are part of the project 

record and are available for review at the Crescent Ranger District office. Substantive comments were 

addressed by improving or clarifying analysis in the EIS, by making editorial and factual corrections in 

the EIS, or by providing a direct response in this appendix. 

Letter 

# Author, Organization 

1 Asante Riverwind, Eastern Oregon Forest Organizer, Oregon Chapter Sierra Club 

2 Charles H. Burley, Consultant, American Forest Resource Council 

3 Denise Smith, Executive Director, Alliance of Forest Workers & Harvesters 

4 Doug Heiken, Conservation and Restoration Coordinator, Oregon Wild 

5 Preston A. Sleeger, Regional Environmental Officer, US Department of the Interior 

6 Christine Reichgott, Manager, NEPA Review Unit, US Environmental Protection Agency 

COMMENTS & CONSIDERATION 

1-1 The EIS is premised upon erroneous and scientifically controversial management 

assumptions and actions, which are incapable of meeting the ecological goals and 

objectives of the project’s purported purpose and need. 

Consideration: Table 2-10 of DEIS page 44 displays how each alternative responds to 

the Purpose and Need. The Council on Environmental Quality defines “scientifically 

controversial” as when experts disagree over the effects to a specific resource on a sitespecific area. In this instance, the commenter does not provide specific science to 

determine how the Forest Service’s cited science and the commenter’s science differ. 

1-2 ... the agency fails to develop a range of reasonable alternatives based upon credible 

scientific research that is not in accord with the myopic logging-permitting research 

cited, thus failing to provide the decision-maker and the public with a full range of 

reasonable scientifically supported alternatives, or even the awareness that the planned 

actions are scientifically controversial at best. 

Consideration: The BLT DEIS considers in detail four alternatives and explains why 

other alternatives were not analyzed in detail (FEIS, page 16 to 41). The Purpose and 

Need includes a need to reduce forest vegetation density so as to lessen the risk that 

disturbance events such as insect, disease, and wildfire will lead to large-scale loss of 

forest. Also a need to contribute to the local and regional economies by providing timber 
BLT Project Environmental Impact Statement 

Appendix C 

414

and other wood fiber products (DEIS at p 2-3). 

 Alternatives considered in detail are found on page 16 and alternatives considered but 

eliminated from detail consideration are found on page 41 of the DEIS. Thinning of 

small diameter trees ranging from 8-15 inches (only) was modeled and did not reduce the 

basal area sufficiently to reduce competition for scarce site resources; thus it did not meet 

the Purpose and Need limiting the extent of disturbance processes nor contributing 

appreciably to the local and regional economies by providing timber and other wood 

fiber products. 

Figure 2-4 of the DEIS displays the results of modeling small-tree (trees 8-12 inches in 

diameter and smaller) thinning in 30 randomly selected stands within the Five Buttes 

project area. The Five Buttes project was a good surrogate for the BLT project because 

there are similar environmental conditions. Points above the typical basal area line are 

where a stand (in general) is at risk to an uncharacteristic loss of large trees. Small 

diameter thinning by itself does not appreciably ameliorate a stand’s competition for 

scarce resources, thus reducing the risk of large loss of forest. 

Also, reintroduction of fire is not a viable option in most stands where only smalldiameter thinning has occurred or where lodgepole pine is the dominate species type. In 

this scenario, trees would remain dense enough that prescribed fire would cause an 

undesired level of mortality to the overstory trees. 

The commenter did not identify specific science thought could be considered. See 

response to Comment 1-2. 

1-3 The agency may not arbitrarily selectively pick only among the limited scientific studies 

that appear to support its logging plans... Analysis must disclose which studies were 

incorporated in the planned actions, and must also disclose which studies recommend 

against such actions, providing the public and decision-maker with NEPA’s requisite 

scientifically and meaningfully informed analysis on which to weigh the impacts, benefits 

and harms, and efficacy or lack thereof, of proposed agency actions. 

Consideration: A robust disclosure of scientific citations can be found throughout the 

analysis as well as Literature Cited on page 355. The commenter did not provide 

specific literature. 

1-4 In its arbitrary dismissal of other potential alternatives, the agency fails to adequately 

address the existence of scientific controversy. Instead the agency misuses its limited 

selective studies, previous agency analysis, and the apparent proposed-alternative 

biased prerogatives of its planning team staff to arbitrarily and capriciously dismiss a 

wealth of substantive pertinent peer reviewed scientific research, management directives, 

the Northwest Forest Plan and Eastside Screens science recommendations and goals, 

and accurate site-specific natural range of variability of conditions. 

Consideration: This Response to Comment section will only address where the 

commenter was specific enough to determine which science and management directives 

were dismissed, as well as recommendations and goals from the Eastside Screens and 

Northwest Forest Plan. Historical Range of Variability was determined by Plant 

Association Group beginning on page 88 of the DEIS followed by snags and down wood 

on page 393 in Appendix B.

1-5 ...the agency fails to effectively and adequately modify its logging plans to incorporate 

the recommendations of scientific research on the habitat and viability needs of the many 

affected native forest-dependent species in the greater project area. Here again, to a 

large extent, the EIS fails to adequately disclose pertinent scientific research on affected 
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native species. 

Consideration: The commenter was not specific enough to identify which pertinent 

scientific research to disclose and how it differs from the science cited. 

1-6 The EIS fails to adequately disclose and address scientific research and Northwest 

Forest Plan science foundations related to LOS and mature forest-dependent species, 

waiving away these outright in favor of the agency’s logging plans without adequately 

informing the public or decision-maker of scientific recommendations against such 

logging, overall wildlife viability recovery objectives, cumulative impacts issues, and the 

accurate extent of the likely harmful consequences of its actions to species of concern 

that are or may be within the project area. 

Consideration: The commenter was not specific as to which scientific research and 

which Northwest Forest Plan science foundations related to LOS and mature forestdependent species need to be disclosed and how it differs from cited material in the 

document. A discussion of the northern spotted owl recovery plan begins on page 182 of 

the FEIS. 

1-7 As a significant number of relatively recent logging projects and cumulative past 

management has already degraded the landscape-scale of project area forests, the BLT 

project would further remove essential forest structure and cover for species of concern. 

Cumulatively these projects effectively degrade many thousands of acres of now 

functioning habitat for species of concern into forest stands that are deficient in 

necessary structure to provide for imperiled native species needs. 

Consideration: Cumulative effects for a variety of species are disclosed in Chapter 3.

1-8 ...contrary to the readily abundant site-specific evidence found throughout historic nonlodgepole pine forests of the planning area (easily verified by numerous old large 

diameter stumps, and downed logs, of fir and pine trees), the Forest Service decision 

would convert areas of historic multi-storied mature and old growth mixed conifer 

forests to unnaturally open pine forest stands. 

Consideration: Mixed conifer stands in the BLT were more open when fire played a 

greater role in maintaining the forest. It is the intent to return many of these stands to a 

condition the supports return of a proper fire interval. The following is from pages 88-89 

of the DEIS: Ponderosa Pine “Includes PPD (ponderosa pine dry, 13,010 acres and 16 

percent of the planning area). These stands tend to be on the lower slopes of the Cascade 

Range and the volcanic buttes in the area. At present, few of these stands are entirely 

ponderosa pine. Due to fire exclusion, prolific seed source, and adjacency of pure 

lodgepole pine stands have aggressively invaded many stands previously dominated by 

ponderosa pine. The largest overstory trees are 200 to 400 years old. Fire scars are 

common.” 

Mixed Conifer - This PAG Includes MCD (mixed conifer dry, 5,425 acres and 7 percent 

of the planning area), MCM (mixed conifer moist, 6,523 acres and 8 percent of the 

planning area), and MCW (mixed conifer wet, 357 acres and 1 percent of the planning 

area). These stands are typically located on the slopes of ridges and buttes ranging from 

about 4500 feet to over 6000 feet in elevation. Stands are dominated by a variety of 

conifer species. Prior to fire exclusion, these stands appeared to have frequent fire 

regimes. 

Ponderosa pine and, in some areas, Douglas-fir comprise the oldest and usually the 

largest trees in the overstories of these stands. Fire scars, scorched bark, and scattered 

charcoal on the ground are very common on these sites. Mid and understories are usually 
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dominated by the true fir in dense, pole-sized thickets. Lodgepole pine is a common 

component of the mid and understories of these stands as well. Down and dead lodgepole 

pine is a common component of these stands. 

In both these dry Plant Association Groups, prior to fire exclusion, frequent fire regimes 

were common. With frequent low intensity fire, these stands were likely more open. 

BLT prescriptions in these stands can be characterized as understory thinning. 

1-9 The EIS does not include a restoration alternative, or a range of other scientificallybased alternatives, even though it is “reasonable” to include a restoration alternative, 

and even though NEPA requires a full range of reasonable scientifically sound 

alternatives. 

Consideration: See response to Comment 1-2. Commenter was not specific what a 

“restoration only” alternative entails, but it is assumed small diameter thinning (only) 

and prescribed fire are the actions that might be included. Those were analyzed and 

disclosed on page 41 of the DEIS.

1-10 “Mechanical fuels treatment, by itself, is not enough to reduce the risk of severe fire; 

treatments must be accompanied by efforts to remove the underlying causes of fire risk, 

like logging and fire-suppression.” (Rhodes, 2007). 

Consideration: The Interdisciplinary Team has reviewed the Jonathan Rhodes “The 

Watershed Impacts of Forest Treatments to Reduce Fuels and Modify Fire Behavior” 

February, 2007 paper and recommendations as it relates to proposed activities in BLT. 

The project appears consistent with the Rhodes “sideboards” to reduce potential adverse 

impacts to watersheds. BLT project was designed to use mechanized fuel activities in 

areas where it can be most effective on a landscape scale. The goal is to retain the 

largest trees. Wildland fire, or “Fire Use Fire” is being considered in appropriate places 

at this time. In this project, the potential effects to hydrologic resources from a direct, 

indirect, or cumulative nature is relatively benign due a range of reasons (DEIS, 

Fisheries and Aquatic Resources starting on page 254), but mostly due to the limited 

activity in proximity to water.

1-11 ...commercial logging is not the only way to reduce the risk of natural disturbances, nor 

is it the best way. Commercial logging has, in fact, not been shown in any scientific 

literature to reduce the incidence of large-scale fire. (Carey and Schumann, 2003) 

Commercial logging in important habitat with no diameter limits does not make sense in 

light of the objective to protect habitat. Cutting large-diameter trees not only degrades 

wildlife habitat, but it exacerbates wildfire severity. (Brown et al, 2004; Carey and 

Schumann, 2003; Noss, et al 2006; Rhodes, 2007; Morrison and Smith, 2005) 

Consideration: The commenter’s cited science does not appear to be contrary to the 

methods proposed in the BLT project. The following are the Forest Service conclusions 

and excerpts from the science: 

Brown et al 2004: “Treating surface fuels, reducing ladder fuels, and opening overstory 

canopies generally produce fire-safe forest conditions, but large, fire-resistant trees are 

also important components of fire-safe forests.” 

Carey and Schumann, 2003: The review indicated that a combination of mechanical 

thinning and prescribed burning is a recommended tool to restore ponderosa pine forests. 

It also indicated that research assessing the effectiveness of commercial harvest as a tool 

for changing fire behavior is lacking in the available body of literature. “The research 

community has not addressed commercial logging as a method for reducing wildland 

fuels. Most of the research on logging and fire behavior focuses on the build-up of fuel 

that results from harvest and on methods for treating slash. We found a single simulation 
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study which touched on the impacts of commercial harvest on fire behavior. We did not 

find any reports of observations, case studies or empirical on research this topic.” 

There is no evidence in the Carey & Schumann paper contrary to proposed methods in 

the BLT project. It should be noted that any inferences made from the Carey & 

Schumann paper are only applicable to ponderosa pine forest and not to mixed conifer or 

other plant association groups in the BLT project area. 

Noss et al 2006: The commenter appears to be using this reference as a reason why the 

Forest Service should retain all large trees; however, the Forest Service is differentiated 

between fire resistant species, such as ponderosa pine and Douglas-fir, and non-fireresistant species, such as the true firs. Thinning prescriptions were designed to retain not 

only the largest of the large trees on the landscape, but also to favor fire-resistant species 

over non-fire-resistant species. 

 “Fires in ponderosa pine and dry, mixed-conifer forests historically burned fine fuels 

(e.g. grasses and litter on the forest floor) at regular intervals. These surface fires rarely 

killed large, fire resistant trees, but did kill smaller trees of all species, thereby helping to 

maintain sparse, open stands”. No trees over 21 inches within the boundary of the 

eastside screens would be harvested. Otherwise, the FEIS categorizes this situation as 

“rare” (FEIS, page 185). 

Morrison and Smith 2005: The authors assert that FRCC should not be used as the 

primary basis for decision making. This paper provides no evidence that the Forest 

Service was in error for using FRCC to determine reference conditions, as in BLT. 

See response to Comment 1-10 (Rhodes, 2007). 

1-12 Managed forests should not only support ecologically appropriate fire regimes and 

forest resiliency, they should also support viable populations of species. (Noss, et al 

2006). ...As the project contains logging units within contiguous viable habitat for 

spotted owls and other species of concern, immediately adjacent to LSR, roadless, and 

wilderness, logging within project units would degrade potential habitat for ESA listed 

and other imperiled species of concern, disrupting forest connectivity and available 

habitat. The EIS fails to adequately disclose and address this significant issue, and 

instead proposes to compound existent cumulative impacts habitat degradation with even 

more logging harms. 

Consideration: It is unclear how the Noss citation is related to the commenters concern. 

Ecologically appropriate fire regimes and forest resiliency, particularly in the dry mixed 

conifer and ponderosa Plant Association groups is the goal for the BLT project. 

Threatened and Endangered species are disclosed on page 174 and 

connectivity/fragmentation are on page 241, of the DEIS. Cumulative effects for 

northern spotted owls and other species are disclosed throughout Chapter 3. Connections 

to Late and Old Structured forests are maintained regardless of where the units lie on the 

landscape. There would be no loss of LOS forest. See Response to Comment 1-67. 

1-13 The Forest Service uses dubious fire models to claim that commercial logging is the only 

way to serve the Forest Service’s needs. These models do not give, nor can they give, an 

adequate explanation of how mechanical fuels treatment can reduce the risk of fire. 

(Morrison and Smith, 2005; Veblen 2003; Carey and Schumann, 2003, and new science 

studies by Veblen, Rhodes,... 

Consideration: Fire modeling is not used to determine the type of equipment or 

treatment to use on the landscape. Fire modeling is used to represent different fire 

behavior and potential fire effects based on stand structure. There are numerous 
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documented successes on the forest where active management has modified fire 

behavior, allowing suppression forces to stop the advance of a flaming front. The west 

flank of the Royce Butte Fire and the east flank of the Davis Fire are good examples 

where thinning and mechanical fuels reduction dropped a crown fire to the ground and 

allowed suppression forces to stop a wildfire before it burned into structures. Raymond 

and Peterson, 2005, support this concept: “Applying fuel reduction treatments 

simultaneously to multiple fuels strata is the most effective approach to reducing fire 

severity.” 

 The commenter was not specific enough to determine how the science cited in this 

comment supports the concern. Also, it is unclear which “new science studies” are 

associated with Veblen and Rhodes.

1-14 The EIS claims that small diameter thinning alternatives do not sufficiently reduce the 

risk of fire, but fails to include sufficient information to support its scientifically 

insupportable and/or controversial conclusions. The EIS similarly dismisses utilizing 

scientifically recommended strategically placed treatments – SPOTS or SPLATS, failing 

to meaningfully and responsibly develop and address these feasible action alternatives. 

Consideration: Small diameter thinning (only) also did not sufficiently reduce the 

competition for scarce resources that puts the largest trees at greater risk to disturbance 

processes such as insects and disease. 

SPOTS was utilized in this analysis and was a way to evaluate efficacy of the 

alternatives (DEIS, page 44). Page iv of the introduction to this analysis: “The entire 

BLT analysis area is within the Walker Range Community Wildfire Protection Plan and 

several small communities are embedded. A great deal of work has been completed 

surrounding these communities; however, this project focuses on identifying and 

maintaining Strategic Placement of Treatments (SPOTS). The potential effectiveness of 

fuels treatments was evaluated using risk modeling procedures using measures for the 

amount of overlap onto SPOTS. Alternative B overlaps active management into these 

areas the most, followed by Alternatives C and D.” 

1-15 The Forest Service must analyze an alternative that will eliminate scientifically 

controversial commercial logging and all fuels treatment that is not based in sound 

ecological principles, as this is reasonably within the stated purpose and need of the 

project. 

Consideration: The commenter was not specific enough to determine which and how 

the cited science relates to commercial logging and how it is considered scientifically 

controversial. 

1-16 Undisturbed mature forests require little or no restoration. (Baker et al, ) Passive 

restoration is the best way to return forests back to the condition first perceived by the 

European settlers. (McIver and Starr, 2001). At a minimum, the Forest Service must 

analyze an alternative that would exclude the most important mixed conifer and 

ponderosa pine mature and old forest habitat from ecologically harmful active forest 

management actions and protect the area’s connective forest habitat, especially 

surrounding and linking LOS, LSR, roadless/unroaded, and wilderness areas with 

adjacent mature and old forest habitat. 

Consideration: It is assumed the commenter is citing Baker, Veblen & Sherriff, 2006. 

Fire, fuels and restoration of ponderosa pine - Douglas-fir forests in the Rocky 

Mountains, USA. In an email correspondence with Ken Boucher (Aug. 17, 2007) the 

author (Baker) cautions that his paper has no inference to east Cascades and without site-
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specific research, he is only able to make inferences and guesses. 

McIver and Starr, page 23, Conclusion, describes why active restoration may be the 

preferred method (over passive restoration) in some degraded systems. The authors 

provide examples of these, including forests in which accumulated fuels are at 

uncharacteristically high levels.

1-17 The EIS only analyzes alternatives that are virtually identical to each other... 

The action alternatives are essentially similar in premise and methods, especially in 

regards to their focus on commercial logging/thinning, varying only in acreage extent 

and board foot volume. 

Consideration: The EIS also analyzed several alternatives on page 41 of the DEIS 

“Alternatives Considered but Eliminated from Detailed Consideration”.

1-18 The Forest Service fails to address cumulative impacts properly, and fails to provide any 

science showing that destroying viable mature and old mixed conifer and ponderosa pine 

forest habitat in the present benefits the area’s many diverse forest species of concern in 

the future. 

Consideration: The Environmental Consequences disclosures in the EIS include 

discussion of cumulative effects. Where there is an overlapping zone of influence, or an 

additive effect, this information is disclosed. In order to understand the contribution of 

past actions to the cumulative effects of the proposed action and alternatives, this 

analysis relies on current environmental conditions as a proxy for the impacts of past 

actions. This is because existing conditions reflect the aggregate impact of all prior 

human actions and natural events that have affected the environment and might 

contribute to cumulative effects. 

This cumulative effects analysis does not attempt to quantify the effects of past human 

actions by adding up all prior actions on an action-by-action basis. There are several 

reasons for not taking this approach. First, a catalog and analysis of all past actions 

would be impractical to compile and unduly costly to obtain. Current conditions have 

been impacted by innumerable actions over the last century (and beyond), and trying to 

isolate the individual actions that continue to have residual impacts would be nearly 

impossible. Second, providing the details of past actions on an individual basis would 

not be useful to predict the cumulative effects of the proposed action or alternatives. In 

fact, focusing on individual actions would be less accurate than looking at existing 

conditions, because there is limited information on the environmental impacts of 

individual past actions, and one cannot reasonably identify each and every action over 

the last century that has contributed to current conditions. Additionally, focusing on the 

impacts of past human actions risks ignoring the important residual effects of past natural 

events, which may contribute to cumulative effects just as much as human actions. By 

looking at current conditions, we are sure to capture all the residual effects of past human 

actions and natural events, regardless of which particular action or event contributed 

those effects. Finally, the Council on Environmental Quality issued an interpretive 

memorandum on June 24, 2005 regarding analysis of past actions, which states, 

“agencies can conduct an adequate cumulative effects analysis by focusing on the current 

aggregate effects of past actions without delving into the historical details of individual 

past actions.” 

The cumulative effects analysis in this (EA or EIS) is also consistent with Forest Service 

National Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 

2008), which state, in part: 
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“CEQ regulations do not require the consideration of the individual effects of all past 

actions to determine the present effects of past actions. Once the agency has identified 

those present effects of past actions that warrant consideration, the agency assesses the 

extent that the effects of the proposal for agency action or its alternatives will add to, 

modify, or mitigate those effects. The final analysis documents an agency assessment of 

the cumulative effects of the actions considered (including past, present, and reasonable 

foreseeable future actions) on the affected environment. With respect to past actions, 

during the scoping process and subsequent preparation of the analysis, the agency must 

determine what information regarding past actions is useful and relevant to the required 

analysis of cumulative effects. Cataloging past actions and specific information about 

the direct and indirect effects of their design and implementation could in some contexts 

be useful to predict the cumulative effects of the proposal. The CEQ regulations, 

however, do not require agencies to catalogue or exhaustively list and analyze all 

individual past actions. Simply because information about past actions may be available 

or obtained with reasonable effort does not mean that it is relevant and necessary to 

inform decision making. (40 CFR 1508.7)”

1-19 Additionally, three scientific research reports exist that clearly conclude spotted owls 

and other species of concern continue to use even severely burned mature and old forest 

habitat, while other spotted owl research concludes that these forest species, including 

threatened-listed owls, are deterred from utilizing LOS habitat that has been degraded 

by commercial logging, including commercial thinning-style logging. Research by 

Monica Bond et al, Jeffrey Jenness et al, and Andrews & Anthony (OSU-OCFWRU) all 

clearly indicate that spotted owls continue to utilize burned LOS habitat. Additional 

research also concludes that logging extirpates and harms populations of goshawks, 

fisher, marten, lynx, eagles, osprey, Lewis’ and other woodpeckers, as well as 

populations of their prey species. The failure of the project EIS to disclose and include 

this pertinent information in its analysis deprives the public and the decision-maker of 

essential information critical to designing a reasonable project with a likelihood of 

accomplishing its purpose and need goals. 

Consideration: It is unclear how the commenter intended this comment to be 

considered. There is very little burned forest within the project area and speculation on 

burned forest as a foreseeable action is not reasonable. Effects related to those species 

mentioned are disclosed in Chapter 3 pages 127- 247 of the DEIS.

1-20 Plans for Reducing Fire, Insect, and Disease Risk do not use the Best Available 

Science and are Scientifically Controversial... 

There is ample scientific controversy about whether mechanical fuels treatment reduces 

fire risk. Mature, old-growth stands have dense, moist interiors and little wind, which 

inhibit the spread of wildfire. (Morrison and Smith, 2005; Rhodes, 2007) Fuels 

treatments that reduce stand density and open up the forest actually enhance fire spread, 

as fire moves more readily through an open environment. (Morrison and Smith, 2005; 

Rhodes, 2007) 

Consideration: It is unclear how these references relate to this subject matter. It is 

agreed open stands have the potential for higher midflame winds and initially are drier 

sites than closed canopy stands. However, during 90 percentile and higher fire weather 

conditions (which equal 86 percent of the fire season), open and closed stands reach 

equilibrium in fuel moisture content. The DEIS on page 118 addressed open versus 

closed stand conditions: “Thinned stands of trees can have a shortened timelag for drying 

fuels and potential increases in surface winds relative to more closed stands. This effect 

becomes less of a factor for fire behavior as summertime weather progresses. Although 
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closed stands take longer to reach low fuel moistures than open sites, as less moisture 

recovery occurs in July, August and September, fuel moistures in closed stands reach 

equilibrium with open sites relatively quickly. When this occurs, crown-driven wildfires 

are much easier initiated. The closed sites have more available flammable fuel due to 

higher levels of biomass across the fuels strata and live tree fuel moisture at its lowest 

level.” 

This effect actually overrides an increase in midflame windspeeds as it relates to 

potential for an increase in fire severity. The more open stands have less ladder fuels 

available to initiate conversion from ground to a more destructive crown-driven fire. In 

contrast, the closed canopy environment during 90 percent percentile weather and higher 

has the greater potential for an increase in fire behavior, regardless of midflame 

windspeeds. 

1-21 Plans for Reducing Fire, Insect, and Disease Risk do not use the Best Available 

Science and are Scientifically Controversial... 

An opened forest allows fuels to dry out faster and winds to blow through the stand. 

(Morrison and Smith 2005; Rhodes, 2007). 

Consideration: See response to Comment 1-20.

1-22 Plans for Reducing Fire, Insect, and Disease Risk do not use the Best Available 

Science and are Scientifically Controversial... 

Thinning the understory is more effective at reducing fire risk than thinning the 

overstory. (Carey and Schumann, 2003) 

Consideration: It is unclear how this reference is scientifically controversial or 

disagrees with the science cited or the activities planned within the BLT project. The 

BLT project outside of the lodgepole pine Plant Association Group would: “Thin from 

below to favor the larger trees with healthy foliage (HTH, 3,550 acres) DEIS, page 3, 

Proposed Action. 

The Carey-Schuman reference relates only to fire-adapted ponderosa pine forests, which 

could be considered a minor component of the BLT project area.

1-23 Plans for Reducing Fire, Insect, and Disease Risk do not use the Best Available 

Science and are Scientifically Controversial... 

Complex and varied canopies may actually prevent the spread of wildfire better than 

dense, young, single-storied canopies. (Morrison and Smith, 2005) 

Consideration: The Forest Service was not able to locate this quote or conclusion in the 

Morrison and Smith paper cited. It appears the science from this paper relates to the 

following: “In this paper, we present a brief assessment and analysis of the concepts 

involved with fire regime condition classes, fire planning, and forest stewardship 

planning. We also address the general forest health situation in the Mt. Hood area and the 

opportunities and risks associated with a variety of forest stewardship activities.” 

See response to Comment 1-20 regarding the risk associated with dense versus open 

forests as it relates to the BLT area. 

1-24 Plans for Reducing Fire, Insect, and Disease Risk do not use the Best Available 

Science and are Scientifically Controversial... 

“Although the assertion is frequently made that reducing tree density can reduce wildfire 

hazard, the scientific literature provides tenuous support for this hypothesis.” (Carey 

and Schumann, 2003, page 14). The Forest Service is at least required to discuss this 
BLT Project Environmental Impact Statement 

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very lively scientific controversy about the role of mechanical fuels treatment in reducing 

the risk of fire in the project EIS. 

Consideration: The Council on Environmental Quality defines “scientifically 

controversial” as when experts disagree over the effects to a specific resource on a sitespecific area. It is unclear how the Carey and Shuman citation meets that test. 

The Carey and Schumann paper reviews published research on the relationship between 

fuel reduction treatments and wildfire behavior, specifically the incidence of crown fire. 

“In sum, the notion that mechanical thinning, or a combination of thinning and 

prescribed fire, reduces the incidence of catastrophic fire needs to be viewed as a 

working hypothesis and needs to be tested through experimentation and site-specific 

evidence.” On the Crescent Ranger District, there is documented evidence to support the 

use of mechanical fuels treatment and its positive effect in slowing the Royce Buttes and 

Davis Fire flanks before they burned into structures. 

1-25 There is insufficient and highly controversial scientific support to show that commercial 

thinning reduces fire risk. (Carey and Schumann, 2003) 

Consideration: The Council on Environmental Quality defines “scientifically 

controversial” as when experts disagree over the effects to a specific resource on a sitespecific area. It is unclear how the Carey and Shuman citation meets that test. Carey 

and Schumann state “the research community has not addressed commercial logging as a 

method for reducing wildland fuels.”

1-26 Science overwhelmingly concludes that cutting large, fire resistant trees does not reduce 

the risk of fire and actually can contribute to more intense fires. (Brown et al 2004; 

Carey and Schumann, 2003; Noss et al, 2006; Rhodes, 2007; Morrison and Smith, 2005; 

Baker et al, 2006) 

Consideration: It is unclear how the commenter’s cited science supports this claim. 

Acknowledging the word “large” as a subjective term, in general, the BLT project is 

focused on small diameter thinning in relation to the larger trees being retained and 

understory removal for the main purpose to limit the extent of disturbance processes, 

especially to address loss of large areas of forest to insect and disease. 

In an email from Baker of Baker et al 2006: “The work we did in the Rockies has not 

been done, so far as I know, in the Eastern Cascades. There is no similar comprehensive 

review of historical documents for your area. I am interested in doing this at some point.” 

Brown et al 2004: Brown et al’s research supports the integrated approach to reducing 

fire extent and severity at a landscape level by reducing ground, ladder and crown fuels. 

Carey and Schumann 2003: Paper does not define the difference between mechanical 

thinning and commercial timber harvest. “This study indicated that thinning which 

specifically reduced crown bulk density restricted the occurrence of crown fire.” 

Morrison and Smith 2005: The authors assert that FRCC should not be used as the 

primary basis for decision making. The comment was too vague and could not be related 

to this paper. 

Noss et al 2006: “Fires in ponderosa pine and dry, mixed-conifer forests historically 

burned fine fuels (eg grasses and litter on the forest floor) at regular intervals. These 

surface fires rarely killed large, fire resistant trees, but did kill smaller trees of all species, 

thereby helping to maintain sparse, open stands” 

Rhodes 2007: The BLT Project is consistent with all recommendations made by Rhodes.
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1-27 A percentage of the trees to be logged in this project will be up to and/or over 21” DBH, 

yet this total is not accurately disclosed in the EIS nor are the impacts adequately 

assessed and disclosed. 

Consideration: All remnant late and old seral and/or structural live trees greater than or 

equal to 21 inches in diameter (Eastside Screens, Scenario A, 2(a)) would be maintained 

as listed on page 30. Circumstances for removal of trees 21 inches and over are specified 

on page 29 of the DEIS. Page 174 of the DEIS that trees 21 inches and greater removed 

would be less than 5 percent and several places in the DEIS characterizes this removal as 

in “limited circumstances”. It also discloses it is highly unlikely any trees greater than 

30 inches would be removed. 

1-28 ...thinning is not needed in mixed-conifer forest to prevent fire. Mixed-conifer forests 

are wetter and have a mixed-severity fire regime. (Noss et al, 2006; Rhodes, 2007) 

Consideration: The Forest Service agrees that mixed conifer forests contain more 

moisture than some other Plant Association Groups; therefore can burn at various mixed 

severity. However, the Forest Service cannot agree with the commenter’s conclusion 

“thinning is not needed” based upon the two references cited.

1-29 If the fire regime is not altered, then fuel “treatments” do not help to reduce the risk of 

severe fire or restore the stand to its natural fire behavior. (Rhodes, 2007) 

Consideration: In comments 1-36 and 1-37, this commenter states fire 

regimes/condition classes are not based on best available science and that they are highly 

controversial. In context with those comments, it is unclear the concern here. 

Page 107 of the DEIS: “Fire Regime Condition Class (FRCC) was used in the analysis 

area to determine reference conditions. Because of the controversy and simplicity of 

using FRCC (Morrison and Smith 2005; Veblen 2003), FRCC was not used as the 

primary basis for decision making. However, fire regimes were used as a reference 

condition to determine ecological capability and reference condition. 

1-30 ...the forest is not outside of its desired condition unless the current time period without 

fire is longer than any time period in the areas’ history. (Rhodes, 2007) 

Consideration: The Forest Service did not find this quote or concept in the paper cited. 

Fire Regimes are based on more that just fire return interval and severity. Fire regimes 

also consider stand structure and composition. A stand may have missed a fire return 

interval or two but still be within Condition Class 1 because the stand structure and 

composition is still within historic reference condition. See DEIS page 107, Table 3-26.

1-31 Fire is a natural and inevitable component in a functioning forest ecosystem, and the 

mixed-conifer forests in the project area are within their natural range of fire behavior. 

The Forest Service has not based its determination to alter the natural fire regime of the 

mixed-conifer forests in the best available science. 

Consideration: The commenter does not cite which is the best available science or 

where the Forest Service science is flawed in order to adequately respond to this concern. 

There is not a natural range of fire behavior; however there is a natural range for fire 

interval and fire severity. Page 110 of the DEIS cites the science used for this analysis 

area regarding fire return intervals and severity in the Douglas-fir Plant Association 

Group, which is a surrogate for mixed conifer. Page 89 in the Forested Vegetation 

section discusses imminent susceptibility. A citation used to determine Fire Regime 

Condition Class was inadvertently omitted from the DEIS and was added to the FEIS: 

Wildland Fire in Ecosystems; Effects of Fire on Flora, Rocky Mountain Research 
BLT Project Environmental Impact Statement 

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Station, Volume 2, General Technical Report 42. 

1-32 The EIS does not adequately address science that shows how slash piles from logging 

create a greater risk of fire. Slash from commercial logging units is generally left sitting 

on the ground for 1 or 2 years or more after a project is implemented. Slash from 

previous logging projects in the area are still largely untreated, exacerbating if not outright causing increased fire risk in the greater project area. The EIS fails to address 

these accumulations of untreated slash, revealing no timeline for the clean-up of 

cumulative slash across the area, despite this being a purported fire risk reduction 

project, and despite slash being a major factor increased fire risk throughout the greater 

project area. 

Consideration: Timing of cleanup and the residual hazard is disclosed on page 118 of 

the DEIS. “In general, harvest and temporary road building operations break up the 

continuity of fuels strata, so fire severity is usually reduced. However, there may be an 

elevated level of fine fuels (one year or less) in the short-term between harvest operations 

and post-sale activities. The risk would be from a human-caused ignition. Typically, 

during the summer months, contract operations are suspended during the times of highest 

industrial fire precaution levels, or mitigated through additional equipment on site, shut 

down times, and fire patrol. Historical records have shown that risk of a fire ignition as a 

result of harvest operations is much lower than from the recreating public, and should a 

fire result, a successful suppression is much more likely due to equipment and personnel 

on site. This risk was accounted for in the modeling; specifically the human-caused 

ignitions.” 

Commercial timber sales require slash to be treated within the timeframe of the contract. 

This is typically one year or less. Disposal of the piled slash is usually as soon as the 

timber sale contract for the area under contract has been fulfilled and released. For 

utilization as biomass or other forest product, the piles may be present for a year or two 

longer, but the fuel continuity has been reduced along with the hazard. 

Slash from past commercial harvest units is treated to a level that is consistent with 

Forest Plan Standards and Guidelines. Specified fuel loadings by size class are specific 

for each vegetative type and management area (i.e. General Forest is listed in the Forest 

Plan under 4-119), which tiers to a Pacific Northwest Research Station Photo Series. 

Slash that remains in an area may be scheduled to be utilized for biomass or could be 

retained for specific wildlife objectives. 

1-33 The EIS fails to adequately address how slash can increase the risk of fire. Mechanical 

fuels treatments generate slash, which are highly flammable and increase the risk of fire. 

(Rhodes, 2007). 

Consideration: The Rhodes paper cited does not state that an increase in mechanical 

fuels will increase fire risk. The only way to increase or reduce the risk of fire is to 

control the ignition source (i.e. lightning or human-caused ignitions). Rhodes does state 

that increasing slash will increase fire severity. Timing of slash cleanup and its effects 

begins on Page 118 of the DEIS.

1-34 Post-wildfire studies have shown that there are severe effects to the landscape if a 

project’s slash is not cleaned up before the next fire occurs. (Carey and Schumann, 

2003). 

Consideration: The Carey and Schumann paper cited: 

• Indicated that assessment of effectiveness of mechanical thinning is confounded 

by untreated slash. Timing of slash cleanup is found on page 118 of the DEIS and is 
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summarized in response to Comment 1-32 and 1-33. 

• Relates to fire-adapted ponderosa pine forests. 

• Supports the concept that pine areas are largely adapted for low-intensity fire, 

not predominantly stand-replacing fires like the 2003 Davis Fire. 

• Suggests that prescribed burning is effective in changing wildfire behavior. 

• Indicated evidence both supporting and opposing mechanical thinning as a 

method to change wildfire behavior, but also indicated that thinning from below, which 

is what the BLT project will accomplish, is assumed to be effective at altering fire 

behavior. 

• Indicated a combination of mechanical thinning and prescribed burning is a 

recommended tool to restore ponderosa pine forests. 

• Indicated that research assessing the effectiveness of commercial harvest as a 

tool for changing fire behavior is lacking in the available body of literature. 

1-35 Slash is not often cleaned up before the next fire; even if the land manager has plans to 

clean up the slash, the clean-up often lags years behind the thinning or fuels treatment 

project occurs. (Rhodes, 2007). The Forest Service must disclose how it will deal with 

the slash that is generated by this project in addition to how it plans to address 

cumulative slash build-up across the greater project area, and analyze the increase in 

fire risk due to slash left in the project area and the backlog of untreated slash needing 

to be removed. 

Consideration: See response to Comments 1-32 through 1-34.

1-36 The Forest Service uses models are not based in best available science. It relies heavily 

on Fire Regime Condition Class (FRCC), which is a highly controversial method of 

determining the ecological status of a forest. (Morrison and Smith, 2005) The FRCC 

model is overly simplistic and is based on subjective estimates and guesses about the 

general fire regime over a large landscape. 

Consideration: Page 107 of the DEIS “Fire Regime Condition Class (FRCC) was used 

in the analysis area to determine reference conditions. Because of the controversy and 

simplicity of using FRCC (Morrison and Smith 2005; Veblen 2003), FRCC was not used 

as the primary basis for decision making. However, fire regimes were used as a 

reference condition to determine ecological capability and reference condition.

1-37 The FRCC model also assumes that a land manager can reduce the risk of fire by 

changing the condition of the forest to Class 1. “However, this idea does not have 

adequate support in practice and is currently the subject of much scientific controversy.” 

The EIS fails to adequately address the scientific controversy surrounding the use of Fire 

Regime Condition Class or the model methodology used in its fire risk modeling for this 

project. 

Consideration: See response to Comment 1-36. The commenter fails to identify which 

risk modeling methodology works better than those used by the Forest Service for this 

project. 

1-38 This project area has been tremendously impacted in the last few years. The project EIS 

does not analyze the cumulative impacts of this project area in the requisite meaningful 

assessment and disclosures. 

Consideration: See response to Comment 1-18 

1-39 As past projects have a direct impact upon both viable wildlife habitat and fire risks in 

the area, in particular Five Buttes, Seven Buttes, and Seven Buttes Return among others, 

which removed forest structure necessary for wildlife species of concern while 
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increasing slash and consequent severe fire risks, it is imperative these issues be 

addressed adequately within the project’s analysis. 

Consideration: The Zone of Influence is identified for each resource area. It is 

bounded by the most logical area (usually a watershed) and where effects may be present 

specific for the resource being discussed. In most cases, the Five Buttes, Seven Buttes, 

and Seven Buttes Return projects is one or more watersheds away and effects do not 

overlap in space or time for the resources being discussed.

1-40 Cumulative effects analysis must also include actions that are “reasonably foreseeable.” 

Mechanical fuel treatments have only transient effects on fuel conditions. (Rhodes, 

2007) 

Consideration: Reasonably Foreseeable Actions are defined as a proposed action that is 

in the public domain such as a scoping letter or where the public has specific details of a 

pending action. The Forest Service has reviewed the Rhodes paper (response to 

Comment 1-10 and others). It is unclear what “transient effects on fuel conditions” the 

commenter believes were omitted from the analysis. 

1-41 The EIS does not adequately discuss or propose mitigation measures... 

The Northwest Forest Plan explicitly prohibits using mitigation or restoration to 

substitute for habitat degradation (S&G page C-37). 

There is no monitoring and enforcement program set up to minimize the environmental 

harm done by this project. Mitigation measures are briefly mentioned, but not as part of 

an enforceable program to lessen the effects of the project. 

Consideration: There are no activities planned within Riparian Reserves. The 

commenter has taken S&G page C-37 for Riparian Reserves out of context. Resource 

Protection Measures are specified on page 29, and Monitoring is discussed throughout as 

a basis for conclusions with page 308 specifying site-specific monitoring to determine 

effects to matsutake production from active forest management. Mitigation measures 

proposed within this document will be identified by the Responsible Official as a part of 

the decision. 

1-42 Soils require rehabilitation under the Deschutes LRMP. Among the only mitigation 

measures intended to off-set the damage to soil conditions is subsoiling. This is not an 

adequate mitigation measure because it does not actually rehabilitate the soil. 

Consideration: Soil restoration (subsoiling) is used to mitigate Forest and Regional 

thresholds for compaction specified under the heading “Management Direction” for soil 

quality. It has been implemented on the Crescent Ranger District with success due to the 

absence of rock fragments on the surface and within soil profiles. Most surface organic 

matter remains in place because the equipment is designed to pick up the soil and drop it 

in the same place to loosen the compacted soils. The tines are adequately separated and 

have enough clearance between the tool bar and the ground, thereby allowing smaller 

slash materials to pass through without building up. Mixing of soil and organic matter 

does not cause detrimental soil displacement because these materials are not removed off 

site. Restoration treatments likely improve subsurface habitat by restoring the soils 

ability to supply nutrients, moisture, and air that support soil microorganisms. Since the 

winged subsoiler produces nearly complete loosening of compacted soil layers without 

causing substantial displacement, subsoiled areas are expected to reach full recovery 

within the short-term (less than 5 years) through natural recovery processes. 

 (DEIS, pages 53, 64). 
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1-43 ...there is insufficient analysis of the effectiveness of subsoiling. 

Consideration: See response to 1-42. Deschutes Soil Monitoring 1995 through 2001 

has demonstrated the efficacy of subsoiling (FEIS, page 66).

1-44 ...Crescent District Ranger and staff involved in planning the similar Five Buttes project, 

stated that they had completed a 200 acre fuels reduction thinning project that later 

burned in the Davis Fire. Despite fuels reduction thinning across approximately 200 

acres, this area burned at similar high fire intensity as did the surrounding un-thinned 

forests, and was ineffective in reducing fire risk or severity impacts. The agency’s failure 

to adequately address this pertinent information in the EIS to the public and decisionmaker(s) violates NEPA. 

Consideration: It is unclear how this information is pertinent to this project. Not all 

200 acres of actively-managed acres burned at the same severity, and 98 percent of the 

successful placement of control lines that ultimately determined the wildfire perimeter 

consisted of areas that were thinned. Two hundred acres of thinning may or not be 

effective in landscape processes, and fire severity has many variable components, 

including weather, topography, fuels, aspect, and where and how much fuel hazard lies 

on the landscape.

1-45 ... the fire models used are a crucial part of the decision to heavily thin. But the fire 

models do not adequately represent the situation on the ground in the forest. They are 

theoretical and do not give enough information for the public to determine whether they 

are based on actual, on-the-ground data. 

Consideration: Page 106 of the DEIS: “Fuel models are a tool used to standardize 

discussion of fuel conditions on a landscape. Fuel conditions, defined by quantity and 

arrangement, have been categorized into 40 standard descriptive fuel models (Scott and 

Burgan, 2005).” 

Areas proposed for activity were field-verified to document the vegetative condition and 

fuel models were assigned.

1-46 The EIS failed to adequately discuss how mycorrhizae will be impacted by the proposed 

timber project... 

Scientific evidence suggests that mycorrhizae and other soil organisms and processes 

are extremely important and are easily destroyed by ground-based logging, including 

thinning using BMPs as well as post-logging subsoiling, which devastates subsurface 

soil microbial communities upon which healthy functioning forests depend. Affected 

wildlife species, including prey species for spotted owls and other raptors and predators 

(such as lynx, marten, wolverine, and fisher among others) also rely on the fungi, but 

there is no discussion of how the project will affect this important food source for these 

species. 

Consideration: Effects to mycorrhizae are discussed on pages 14, 59, 64, 92, 126, 283, 

298-300, 304-305, 307-308, and 348-349 with numerous citations in the literature cited 

section. Effects to marten, wolverine, and fisher are disclosed where present. 

1-47 The USFS should have addressed how further fragmentation of the planning area will 

affect lynx. 

Consideration: The Deschutes National Forest, and specifically the BLT area does not 

have the habitat for lynx based on current habitat definitions. 

1-48 ... it is clear that data is lacking on the food habits of lynx in Oregon’s forests, which 
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represents a critical research need. Ruggiero, 1999; Aubry, 1999. 

Consideration: See response to 1-47

1-49 Hares, squirrels, and forest-dependent species are typically associated with dense forest 

cover, including shrubs and “dog hair” thickets of small trees. McKelevey, 1999. Many 

of these prey species also perform important roles in the recovery of fragmented forest 

habitat, helping to spread seeds of forest plants and trees, distributing nutrients 

throughout area soils, and loosening compacted soil areas—none of which was 

sufficiently disclosed or addressed in the EIS. 

Consideration: Prey is discussed for many species including fisher, wolverine and 

raptors. Connectivity and fragmentation is discussed on page 241 of the DEIS. In 

addition, Project Design Features for all active management alternatives starting on page 

29 retain areas of dense forest managed in a passive management scenario, in part, to 

provide habitat requirements for prey species. The western edge of BLT is bordered by 

wilderness and Oregon Cascades Recreation Area which provides ample habitat for prey 

species. 

1-50 Different timber harvest methods can have detrimental impacts on many of these species, 

including squirrels, rabbits, rodents, and birds, as well as snowshoe hares. Koehler and 

Brittell (1988) predict that it may take up to seven years after logging an area for hares 

to recolonize the site and up to 25 years before they reach their highest densities. Bull 

(1999) examined the results of a variety of harvest prescriptions on hares and found that 

in lodgepole stands, the number of snowshoe hares decreased in all types of harvest. She 

reports that mixed conifer stands appear to be “no longer suitable for hares after 

harvesting.” 

Consideration: The commenter’s concern is unclear. Snowshoe hares are a common 

prey for lynx, but there is no lynx habitat on the Deschutes National Forest and beyond. 

See response to Comment 1-49.

1-51 The EIS fails to provide a thorough examination of how the project will impact both 

hares and squirrels, as well as other wildlife species which are potential lynx prey. 

Without complete analysis of how these prey species will be impacted, it is impossible to 

quantify and qualify the impacts to lynx. The EIS must analyze the cumulative impacts of 

this project on lynx prey in association with other projects on the District, Forest, and 

surrounding lands. 

Consideration: See response to Comment 1-47. 

1-52 The EIS fails to adequately analyze how wolverine will be affected by the proposed 

project. Because it is probable that the species utilizes the planning area for some life 

cycle needs, the USFS is required to accurately address how the commercial logging and 

road building projects will affect those needs and the species itself. 

Consideration: Effects to wolverine begins on page 203 of the DEIS. Page 206 

discloses a potential shift in use patterns within the upper Deschutes River Canyon. 

There are no timber harvest-related activities that would occur within potentially suitable 

denning habitat. 

1-53 ...to ascertain potential Goshawk use, agency surveys must be conducted seasonally 

each year to determine the rotational patterns of Goshawks for the project and adjacent 

area forests. 

Consideration: Goshawk surveys are not required. Page 140 of the DEIS: “Goshawk 

surveys using recorded adult alarm calls and wailing calls have occurred in the BLT 
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429

analysis area since 2001 with the exception of 2002. Since 2003, the surveys have 

focused on previous years’ sightings and audio responses to document pair occupancy 

and location of active nests.” 

1-54 The EIS fails to adequately address impacts to this species such as how logging removal 

of forest canopy cover, and further fragmentation of the area’s forests, will affect adult 

and juvenile Goshawks and other raptors, or other direct, indirect, or cumulative effects 

to goshawks and other raptor species. 

Consideration: The potential effects of active management on selected Deschutes 

National Forest Wildlife Management Indicator Species and their habitat (including 

goshawks) was analyzed as a Key Issue. Page 139 of the DEIS begins the discussion, 

followed by other raptors such as the great grey owl.

1-55 Several scientific studies exist regarding significantly detrimental logging impacts to 

Goshawks due to logging within or near Goshawk PFA’s, as well as from fragmentation 

of natural forest habitat. (Reynolds et al, 1982, 1989, 1991; Moore and Henry, 1983; 

Fleming, 1987; Hall, 1984; Saunders, 1982; Crocker Bedford et al, 1988, 1990, 1991; 

Patla, 1991; Hayward and Escano, 1989; Kennedy, 1988; Shuster, 1980; Speiser and 

Bosakoski, 1987; Woodbridge et al, 1988; Bendire, 1892, Bull, 1988; Hargis et al, 1991; 

Bryan and Forsman, 1987; Andeson and Shommer; among others ). Some of these 

studies were conducted for the agency. However the EIS violates the NEPA by failing to 

adequately and accurately disclose or assess this pertinent information. 

Consideration: The commenter’s cited science is merely a "list" and has not 

demonstrated how this science is relevant to this project, nor demonstrated how the 

references are responsible opposing science. Also, the commenter has not indicated 

which information from the list was omitted from the analysis. The DEIS cites Wisdom 

et al 2000; Reynolds et al, 1991, 1992 and Hargis et al 1994 cited in Wisdom; Reynolds, 

1995; Greenwald et al, 2005; Marshall et al, 2003; in disclosing effects to the goshawk. 

The remaining scientific studies are all similar in content. In addition, Chapter 3 of the 

DEIS discloses effects to nesting habitat within unsustainable conditions and benefits 

associated with long-term maintenance of foraging conditions. 

1-56 The failure of the project’s action alternatives to protect goshawk habitat would further 

reduce potential nesting and foraging habitat and thus violate NFMA’s requirement to 

maintain viable populations of these and many other forest canopy-dependent species,... 

The analysis discloses it is anticipated that goshawk populations on the Deschutes 

National Forest would decline in response to the loss of habitat due to wildfires over the 

last 6-8 years. DEIS, page 140. Passive management scenarios do not always protect a 

species, in especially disturbance-prone landscapes east of the Cascade Mountains. 

Effects to goshawks are disclosed starting on page 139 of the DEIS. 

1-57 ... the Forest Service failed to accurately and adequately assess how the proposed timber 

sale will impact marten and/or fishers. 

Consideration: Effects to American Marten are discussed on page 153 and Pacific 

Fishers on page 181 of the DEIS.

1-58 There is very little analysis of the effects to the Canada lynx, the Oregon Spotted Frog, 

and the Pacific Fisher. Requisite analysis must be done to ensure the long-term survival 

of these species. Surveys should be conducted on a regular basis and potential habitat 

should not be negatively affected. 

Consideration: There is no habitat for the lynx on the Deschutes National Forest, the 
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Oregon spotted frogs are discussed on page 180, and the Pacific Fishers on page 181 of 

the DEIS. 

1-59 The EIS does not provide a significant analysis on how introducing or disbursing 

invasive species over the project area will be prevented. The EIS provides a list of 

standards that must be followed and Project Design Features (PDFs) that should be 

followed, but it doesn’t actually describe how the project will follow the Standards and 

PDFs. 

Consideration: The basic feature for prevention of invasive plants is to have clean 

equipment and clean materials for all roadwork. The Forest Service requires this for all 

service contracts and timber sale operators, as well as for their on equipment. 

Monitoring has shown this has been a very successful program for prevention in the past. 

The commenter is unclear what more detail needs to be disclosed. A risk rating can be 

found starting on page 288 of the DEIS. 

1-60 Neo-tropical migrant and native forest-dependent birds (as well as numerous other 

forest species) are in serious decades-long population declines due to the adverse 

cumulative impacts from over a century of commercial logging in Oregon (see “Avian 

Population Trends” by Brian Sharp). The EIS for this planned project fails to fully and 

adequately disclose the current population status and trends of native forest dependent 

Neotropical migrant and native avian species within the analysis area and adjacent 

forest. 

Consideration: The research by Sharp cited by the commenter has previously been 

reviewed by the Wildlife Biologist assigned to assess the effects of the BLT Project and 

this review did not change the effects disclosed in the document. Recent and localized 

information has been published regarding neotropical and resident bird species and it is 

incorporated where applicable. Current population status and trends are disclosed for 

numerous avian species beginning on page 127.

1-61 The proposed timber sale(s) would significantly impact migratory birds in violation of 

the Migratory Bird Treaty Act, 16 U.S.C. §§ 703—712 (1994). 

Consideration: Consistency with habitat recommendations found in the Landbird 

Strategic Plan, which is a strategy developed for the Migratory Bird Treaty Act, starts on 

page 220 of the DEIS. 

1-62 Further loss or fragmentation of habitat could lead to a collapse of regional populations 

of some forest birds (Robinson et al. 1995). 

Consideration: Forest fragmentation is discussed on page 245 of the DEIS. The 

Interdisciplinary Team has reviewed the Robinson et al. citation. Robinson calls the 

effect “loss of continuity of habitat/fragmentation.” Proposed activities would not create 

additional habitat fragmentation to mid- or late-seral forested stands in the analysis area

(DEIS page 246). Further, numerous Project Design Features (DEIS, page 29) such as 

retention of 15 percent of each activity unit in a passively-managed scenario, retention of 

snags and down wood, and prescribed burning in a mosaic pattern maintains habitat for a 

variety of avian species. 

1-63 The past and continuing logging-oriented management of the forests of Oregon and 

Washington, which provide nesting and fledgling habitat for numerous migratory birds, 

has resulted in severe ongoing population declines in forest canopy-dependent migratory 

and native birds. (reference: “Avian Population Trends in the Pacific Northwest” by 

Brian Sharp). Among the many avian species experiencing population declines due to 
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431

Forest Service logging projects are: band-tailed pigeon, rufous hummingbird, olivesided flycatcher, winter wren, song sparrow, golden-crowned kinglet, pine siskin, 

solitary vireo, willow flycatcher, tree swallow, brown creeper, Lewis’ woodpeckers, 

black-backed woodpeckers, red-eyed vireo, yellow warbler, yellow-breasted chat, and 

others as well. This information was not adequately addressed in the EIS despite the 

obvious direct adverse impacts to many migratory and native bird species from the 

removal of forest canopy cover and forest structural continuity which would occur with 

the implementation of this project. 

Consideration: Decline of some avian species is due to many factors, not solely “Forest 

Service logging projects”. The word “migratory” implies some species do not fulfill all 

their life cycle requirements in one place. Further, what is good for one species may not 

be good for another. Birds of Conservation Concern are addressed on page 218 of the 

DEIS where many of the species the commenter has listed are discussed in detail. 

1-64 ...the EIS did not accurately address the direct, indirect and cumulative impacts that the 

project would have on migratory birds. The USFS has on record a study by Brian Sharp 

(“Avian Population Trends in the Pacific Northwest” as cited above), which concludes 

that commercial logging in public forest lands in Oregon plays a significant role in the 

continuing population declines of several neotropical migrant bird species. The failure 

to disclose the full conclusions and implications of this study in the EIS is particularly 

egregious in that the study was done for Region 6 of the Forest Service specifically on 

Central/Eastern Oregon forests. There are numerous management projects that have 

recently been completed, with others still be implemented or planned in this same project 

area. 

Consideration: See responses to 1-60 through 1-63. The 1992 Brian Sharp citation 

used empirical data from harvest practices in the 1960s on and concluded: “In summary, 

it is difficult to assess the relative importance of habitat alterations on breeding and 

wintering grounds to observed bird population changes in the region. At this stage, 

however, it appears safe to say that habitat changes on the fragmented forests of the 

Pacific Northwest are implicated in the observed population changes as much as, if not 

more so, than tropical reforestation.” Proposed activities in the BLT project would not 

create additional habitat fragmentation to mid- or late-seral forested stands in the analysis 

area (DEIS page 246). 

1-65 ... the Forest Service fails to consider that Spotted Owls will, in fact, use burned forest 

for habitat. 

Consideration: It is unclear the commenter’s concern. There are relatively unburned 

forests in the BLT area and although one aspect of the Purpose and Need is to reduce the 

risk of loss of forest to disturbances processes, it is unclear the relevancy of this 

disclosure. 

1-66 See USFWS. 2008 Final Recovery Plan for the Northern Spotted Owl. In general, the 

EIS fails to develop action alternatives capable of adhering to and accomplishing the 

above management objectives. 

Consideration: The DEIS discusses the 2008 Final Recovery Plan starting on page 176. 

A Final Recovery Plan for the Northern Spotted Owl was signed on May 13, 2008. For 

lands east of the Cascade crest, a landscape management approach is recommended due 

to the landscape being strongly influenced by natural disturbances such as wildfire and 

insect outbreaks. The Plan recognizes the need to manage entire landscapes to meet 

spotted owl objectives. It lists a series of recovery actions to identify, maintain, and 

restore a percentage of the habitat capable lands to provide spotted owl habitat patches 
BLT Project Environmental Impact Statement 

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while also reducing the potential of significant loss by stand replacement fires, insects, 

and disease by active forest management. The Recovery Plan recommended the 

formation of a Dry Forest Province workgroup which will be led by Brian Woodbridge 

of the U.S. Fish and Wildlife Service. Appendix E of the Recovery Plan provides 

information on managing for sustainable spotted owl habitat in the dry Eastern Cascades 

forests of the Inland Northwest. On page 110 of the Recovery Plan, the panel of experts 

recommended five stand restoration and fuel treatment principles: 

6) favor fire tolerant species 

7) retain large and very large fire tolerant species 

8) apply treatments unevenly within stands 

9) apply treatments unevenly among stands 

10) develop silvicultural prescriptions for entire landscapes that integrate fuel 

reduction activities with those maintaining or improving habitat for northern 

spotted owl prey, habitat for other species and restoration of dry forest ecological 

processes and function. 

These stand restoration and fuel treatment principles have been applied to BLT. 

1-67 The project intends to reduce the complexity of late-successional reserves by thinning the 

understory and reducing the complexity of the canopy. The canopy cover will be 

reduced, the stem density reduced, and downed wood will be reduced in the project area. 

It is unclear whether the BLT Project will reduce the amount of late-successional forest 

below the required 15% at the fifth- field watershed level, especially when including the 

effects of the numerous other recent and concurrent projects. 

Consideration: The BLT project does not propose any activity in a Late Successional 

Reserve. Regarding consistency with the Standard and Guideline for fifth-field 

watersheds and Late-Successional Forest (ROD C-41 and C-44), consistency is disclosed 

on pages 98 and 99 of the DEIS. 

 No activities planned in the BLT project would reduce LOS. Actually, LOS 

characteristics may be increased in stands classified as “mid” because the large structure 

would become more dominant after thinning (page 99, DEIS).

1-68 ...new so-called “temporary” roads will be constructed and old roads will be reopened. 

Roads fragment habitat, introduce invasive species, and reduce wildlife’s privacy from 

human interaction. Roads are not “temporary” ecologically on the landscape. How will 

these roads affect the remnant stands of old growth on the project area? There is 

inadequate discussion of the impacts of the roads on wildlife and important habitat and 

connectivity of that habitat. 

Consideration: Connectivity and fragmentation begins on page 241 of the DEIS; 

Transportation System on page 316; and Old Growth Management (page 259) which 

states: No temporary roads would be constructed and interior habitat and edge effect 

would not change. 

1-69 The project does not comply with the Aquatic Conservation Strategy... 

Activities of the BLT Project would create new “temporary” roads, open closed roads, 

initiate extensive road maintenance, logging actions, and road hauling - affecting a 

number of water bodies, including two 303(d) listed waterways. The water quality of 

some of these water bodies is already compromised. The proposed project would violate 

a number of ACS objectives, as the project would not “maintain and restore” important 

riparian characteristics. 

Consideration: A robust discussion on the Aquatic Conservation Strategy starts on page 
Environmental Impact Statement BLT Project

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433

267 of the DEIS and there are no activities within Riparian Reserves. The hydrology of 

the area can be characterized as porous soils and relatively flat terrain (DEIS, page 262). 

1-70 Even though the Forest Service claims that logging will not increase sediment, turbidity, 

or water temperature in the surrounding bodies of water, the body of science on these 

subjects shows otherwise. (Robichaud, et al; Brown 2004; Rhodes, 2007) The Forest 

Service does not actually have data to back up its claims that there will be no increase in 

sediment, turbidity, or water temperature. 

Consideration: The commenter was not specific enough with the literature cited to 

determine how the author’s conclusions differ from the Forest Service. However the 

Robichaud paper cited roads, vegetation management, and prescribed fire may cause 

erosion. The FEIS acknowledges this potential effect and describes the Resource 

Protection Measures on page 19 that will be used to minimize this effect. The Forest 

Service is consistent with the Rhodes “sideboards” to reduce potential adverse impacts to 

watersheds (Response to Comment 1-10). It is unclear how the Brown 2004 reference is 

related to this comment. 

Page 264 of the DEIS: “Additionally, the deep, highly drained pumice soils of the area 

are not prone to convey overland flow which could deliver sediment from upslope 

sources. This has been witnessed throughout the district within projects such as the Davis 

Fire Recovery, Crescent Lake Wildland Urban Interface Fuels Reduction, Seven Buttes, 

and Seven Buttes return. This potential is further reduced by the relatively low stream 

densities within the planning area.” There are no activities planned within the Riparian 

Reserve, and a small 22-acre restoration project within a Riparian Habitat Conservation 

Area that involves no heavy machinery, removal of small trees encroaching into a 

meadow, and prescribed burning of decadent willows. 

The Crescent Ranger District monitors 20 streams for temperature on a yearly basis, 

including the Little Deschutes and Hemlock Creek. Since no shade would be removed, 

there would be no increase in temperature. 

1-71 ...the Forest Service must describe how the action alternatives for the BLT Project 

timber sale(s) complies with Oregon’s water quality standards. 

Consideration: The Clean Water Act requires the State of Oregon to develop water 

quality standards that protect the beneficial uses of the water within the Upper and Little 

Deschutes sub basins. The act also requires the state to establish a list of water bodies 

that do not meet such standards and develop a management plan to meet these standards. 

Currently, the State of Oregon has postponed identification of the Total Maximum Daily 

Load effort until 2009 and the Deschutes National Forest is working on the draft Water 

Quality Management Plan. 

The Little Deschutes River and Lower Hemlock Creek have been identified as water 

quality impaired (303(d). Water temperatures and water quality within the analysis area 

and downstream into the Deschutes River are not expected to be affected as the result of 

active management. There would be no change to the 303(d) parameters for which both 

streams are listed. Page 261 of the DEIS starts the discussion. 

See Response to Comment #170. 

1-72 ...the accuracy of the amount of detrimental soils is questionable, as the detrimental soil 

conditions were generally determined through aerial photos, not on the ground surveys. 

Consideration: Page 58 of the DEIS discloses field reconnaissance, along with 

Geographical Information System (GIS), aerial photos, best available research, past 
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monitoring of logging systems on the Deschutes National Forest, and personal 

communication with Timber Sale Administrators and other district personnel was used to 

determine detrimental soil conditions. In addition, personnel performed transects in 

proposed activity units to ground-truth detrimental conditions.

1-73 The roads are intended to be temporary, but the EIS provides insufficient scientific 

disclosures on long-term impacts to forest soils, structure, hydrology, and continuity. 

There will still be impacts to the soil long after the road is closed. 

Consideration: A discussion of temporary roads is found on page 321 of the DEIS. 

Temporary road construction has not been observed on the District or Forest to 

contribute to sediment delivery or increase in turbidity, particularly on the Davis Fire 

Recovery Project, Seven Buttes, or Seven Buttes Return harvest or salvage operations. 

This is because of the distance from water bodies, relatively flat terrain, and porous soils 

(DEIS, page 265). 

There are no roads, temporary or permanent, being constructed within riparian resources, 

and protection of water quality is also provided by incorporation of BMPs in timber sale 

contract provisions and direction for road maintenance and reconstruction (FEIS, page 

394).

1-74 Surveys for sensitive or listed species that have been reported or are likely to utilize the 

project area should be conducted if reliable population estimates are not available. ...No 

surveys have been conducted for Pacific Fisher, bats, Horned Grebe, Red-necked Grebe, 

Harlequin Duck, Peregrine Falcon (one conducted by Davis Lake in 2005), or the 

Tricolor Blackbird: all regionally sensitive species. The Forest Service also has not 

conducted surveys for Osprey, Great Blue Heron, Golden Eagles, Redtail Hawk, Sharpshinned and Cooper’s Hawk... 

Consideration: The Forest Service has followed the Deschutes Management Plan

direction, essentially using habitat as a proxy. Also, Management Indicator Species are 

used to represent the habitat requirements of all fish and wildlife species found within the 

analysis area. By managing habitat of indicator species, the other species associated with 

the same habitat would also benefit. There is no habitat present and/or the following 

species are not expected to occur within the analysis area and therefore, were not 

analyzed: horned grebe, red-necked grebe, pygmy rabbit, western sage grouse, and the 

yellow rail. 

Carnivore surveys on the district were conducted in 1993-1996 and 1998 (DEIS page 

183). In addition, species observations, nests, den sites, etc. are noted in the existing 

condition section regardless of whether surveys have been conducted or not, which 

contributes to the knowledge base. When surveying for a particular species it is quite 

common to have non-target species respond or fly in (i.e. other raptors) which are 

entered into the wildlife observation databases. 

1-92 Timber Volume Targets Driving NW Timber Sales... 

The failure of the EIS to disclose the existence of Pacific Northwest Regional and 

Deschutes NF timber volume target quotas driving agency projects and influencing the 

design and selection of alternatives violates the clear disclosure requirements of the 

NEPA. (referring to letter from Linda Goodman) 

Consideration: Within the Northwest Forest Plan, the BLT project and alternatives are 

consistent with direction, reflecting neither minimum nor maximum levels of volume 

that must be met nor maximum levels that can be exceeded. The Deschutes National 

Forest Plan as amended by the Northwest Forest Plan identifies Matrix lands and General 
Environmental Impact Statement BLT Project

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Forest as where most scheduled timber harvest should occur and these are the bulk of the 

areas harvested within the BLT Project area. The Responsible Official (John Allen) has 

the discretion in deciding when and where to offer timber sales, given the complex 

nature of many of the standards and guidelines (ROD, page 19) and the decision to be 

made (DEIS, vii).

1-93 “Desired Condition” & Ecological Incongruities 

The EIS describes the “desired condition” as fuels supporting generally low intensity 

fire. Throughout the project’s extensive lodgepole pine forest acres this “desired 

condition” does not comport with ecological reality. ...The District’s proposal to remake such a large portion of the area’s natural forests is not in accord with the historic 

natural ecological composition and necessary fire ecology process of the extensive 

lodgepole pine forests in the project area. 

Consideration: There are many factors to consider, one of which is public health and 

safety for those that live adjacent to the forest, as well as visitors and firefighters. 

1-94 The grandiose geographic extent of this project is scientifically unjustifiable, failing to 

prioritize areas of high residential and human resource value, high hazard, and high risk 

by responsibly and reasonably limiting logging-thinning actions to areas located nearest 

to communities and high priority travel routes. The most important feature of a CWPP, 

and any EIS based in-part upon it, should be to establish a clear set of ecologically 

feasible priorities, recognizing there are limited resources and the most important focus 

of WUI efforts should be within 1⁄2 mile of residential population areas. 

Consideration: The CWPP, finalized in 2005, was developed by Klamath County 

through a collaborative process and agreed to by local governments and other 

organizations. The CWPP process involved identification of WUI areas and areas of 

importance. Some specific areas of the BLT project are categorized as WUI; however, 

the CWPP and the identification of WUI are outside the scope of the BLT project 

environmental impact statement. 

As witnessed many times on the Deschutes National Forest, many fires that threaten 

communities originate much farther than 1/2 mile away. 

1-95 The EIS fails to assess, and needs to disclose and analyze, the consequences of 

disrupting natural disturbance processes in lodgepole pine and mixed conifer forest 

ecosystems. Among the integral necessary benefits of periodic high severity fires are 

containing natural forest pathogens within the checks and balances of nature, including 

mistletoe, bark beetles, ips, root/fungal and other diseases, increasing nutrient 

availability, botanical diversity, stand vigor and growth, habitat diversity and rotation, 

and a host of other interrelated processes as old as the evolution of these forests 

themselves. The EIS must address pertinent scientific research assessing the costs and 

impacts of altering natural processes in the project area’s lodgepole pine and mixed 

conifer forests. 

Consideration: The proposed treatments will not eliminate natural processes. The 

effects to lodgepole and mixed conifer forests are described in the EIS starting on page 

84. The analysis is based on the best available science, as referenced throughout the EIS. 

The commenter has failed to identify which specific and pertinent scientific research is 

missing. 

2-1 ...somewhere along the line, the proposed action went from 14,000 acres give or take 

(2003) to 12,800 acres (2005). Now we see in the DEIS that the Proposed Action is to 

treat approximately 7,499 acres. 
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AFRC realizes that things obviously change over time, especially when it takes five years 

to go from the original scoping notice to the DEIS. But AFRC also believes it is 

incumbent on the agency to document how and why things changed over the course of 

time. 

...if the original proposal was to treat twice as much as is currently being proposed, 

there needs to be documentation on why the reduction and what does that mean for the 

untreated acres originally proposed for treatment. 

Consideration: The Crescent Ranger District requested feedback on the changes to the 

Proposed Action, as well as alternatives, in March 2008, when early responses would be 

most meaningful in drafting the DEIS. AFRC was sent the letter among other interested 

parties. Responses were received from three stakeholders. 

The reduction in acreage is largely due to additional analysis and economic efficiency. 

A more thorough explanation was added to the FEIS under “Scoping”.

2-2 ...the Forest did not take advantage of the new authorities under the Healthy Forests 

Initiative (HFI) and the Healthy Forests Restoration Act (HFRA). Specifically, AFRC 

asked, “Why not use the expedited process available le under these new authorities?” 

There does not appear to be any discussion about this in the DEIS. So AFRC’s question 

remains and we would like a specific response to this. 

Consideration: The Responsible Official considered all tools that would streamline the 

process, including the HFRA authority. Within the Wildland Urban Interface, recent 

implementation of fuels reduction projects such as 5825, Baja, and CE97 have reduced 

the immediate hazard surrounding communities within the BLT analysis area (DEIS, 

page 104). Also, most of the proposed activities where outside the Wildland Urban 

Interface boundary, and any at-risk municipal watershed. In addition, the BLT project 

did not meet the tests for determining the existence of an insect and disease epidemic, or 

for the threat of fire and the need for enhanced protection for Threatened or Endangered 

species. 

2-3 “AFRC strongly urges the District to consider a project-specific forest plan amendment 

to allow the harvest of trees over 21 inches. Please do not arbitrarily limit the project 

design to harvesting trees less than 21 inches without adequate scientific rationale. As 

you know, the Regional Forester sent a memo to the field on June 11, 2003 pointing out 

the problems with this arbitrary, interim policy. In that memo, she also encouraged you 

to consider site-specific Forest plan amendments where this would better meet LOS 

objectives. We all know that diameter limits are not the best way to manage the forest 

and you should have to justify, using sound silvicultural rationale, why such limits are 

necessary.”[From AFRC scoping letter] 

... AFRC asked for and never got a justification for why these limits are necessary on 

this project. 

Consideration: It was determined there was not a need to amend the Eastside Screens in 

this site-specific circumstance, because there are very few trees, if any, within the 

boundary of the project area 21 inches in diameter and over that would need to be 

removed to meet site objectives.

2-4 ...we[AFRC] ... must insist on knowing under what authorities, policies, or plans is the 

Forest justified to apply these Eastside criteria to lands covered under the Northwest 

Forest Plan? 

Consideration: The BLT project has not applied Eastside criteria to lands covered 
Environmental Impact Statement BLT Project

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under the Northwest Forest Plan.

3-1 Many multiethnic mushroom harvesters as reflected in the Draft BLT EIS have 

expressed interest and concern over land management practices in Matsutake mushroom 

areas in the Deschutes National Forest. 

Consideration: Many of the harvester’s concerns are reflected in development of Key 

Issue #2, Alternative D which responds to that issue, various Project Design Features and 

Mitigation Measures that limit soil disturbance for all action alternatives (such as harvest 

over frozen ground), and a disclosure in the Economic and Social section in Chapter 3 of 

the FEIS. The Special Concern Plant section also in Chapter 3 discloses potential effects 

the matsutake harvest.

3-2 Many harvesters are actually opposed to any timber harvest at all in high production 

Matsutake areas within the proposed alternative areas. 

Consideration: The harvesters concerns were noted and many changes, along with 

Project Design Features to maintain matsutake production were incorporated to respond 

(DEIS, pages 8 and 29). Also, Alternative D focuses on the short term production and 

harvest of matsutake mushrooms by excluding active management in the most 

productive matsutake areas, primarily west of Highway 58 (DEIS, page 26). 

3-3 While many harvesters agree that no timber harvest in high production Matsi areas is 

preferred, there is agreement that if logging in any of these areas does occur it be done 

in a way as to minimize soil damage. These include over snow, large equipment staying 

on skid roads with machine arms accessing downed material, helicopter logging etc. 

Consideration: The Forest Service has responded to this concern by incorporating a 

measure where matsutake mushrooms have been determined or are suspected to be 

present. Tractor skidding and mechanized felling shall be on frozen ground or sufficient 

snow depth as determined by the Forest Service (DEIS, page 39). In addition, there is a 

Project Design Feature to restrict grapple skidders to designated areas (i.e., roads, 

landings, designated skid trails) at all times, and limit the amount of traffic from other 

specialized equipment off designated areas. The use of harvester machines will be 

authorized to make no more than two equipment passes on any site-specific area to 

accumulate materials (DEIS, page 31). Helicopter, or advanced harvest systems, are 

prescribed in areas where the majority of the unit is greater than 30 percent slope (DEIS, 

page 56).

3-4 For the BLT alternatives B, C, and D many harvesters we spoke with preferred 

Alternative D. Although all three alternatives will affect high production Matsi areas 

Alternative D will impact less areas than Alternatives B or C. 

Consideration: No response is necessary.

3-5 Concerns were raised about canopy closure, soil compaction, monitoring before, during 

and after treatments. 

Consideration: These concerns generated development of Alternative D (DEIS, page 

26) to respond and a robust analysis on effects of the alternatives (DEIS, page 298). 

Monitoring is proposed for all alternatives (DEIS, page 208).

3-6 Specific concerns about units in the Alternative D including units 15, 30, 45, 60, 125, 

135 170, 195, 265, 790, 815, 820, 840. All of these units are considered high production 

areas for Matsi’s and harvesters are concerned about habitat destruction. 

If Alternative B or C are chosen more units are of concern for harvesters than those 
BLT Project Environmental Impact Statement 

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listed above from Alternative D. 

Consideration: Alternative D was developed (in part) using input from the harvesters. 

The input provided (at that time) identified units where very little, if any, mushroom 

harvest occurs. This information was field-verified by specialists on the interdisciplinary 

team. 

3-7 It is a good precedent to consult with the harvesters and to include harvesters’ concerns 

in findings and project development and design. 

Consideration: The Forest Service agrees with this comment and is committed to further 

collaboration with the harvesters and the public at large.

3-8 There is overwhelming concern that appropriate monitoring of short-term and long-term 

effects of the project treatments on Matsutake production is adequately prioritized and 

FUNDED. Ideally harvesters should be involved in this monitoring. 

Consideration: The Responsible Official has indicated a commitment to monitoring 

and the Forest Service is actively pursuing funding at this time. 

3-9 It is also important to us that, as the project moves into implementation, communication 

with Matsutake harvesters be maintained. This will ensure they are aware of areas that 

are being treated and may be less likely to be productive, at least in the short term. 

Consideration: The Forest Service agrees with this comment.

4-1 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by: 

retaining more untreated “skips” within harvest areas; 

Consideration: Project Design Features for all action alternatives includes harvest over 

frozen ground or snow for units where matsutake presence has been determined or 

suspected (except where it affects groomed snowmobile trails), DEIS, page 39. There 

are numerous other measures that will benefit matsutake production (starting on page 

19), such as retention of large trees, maintenance of soil quality, and measures for 

prescribed burning that retains mushroom habitat. One measure that was designed 

specifically for this resource was to limit machinery off designated skid trails, including 

for post-sale operations. This will (by default) provide areas that are skipped from more 

intensive management. Areas untreated, or “skips” are also provided by 15 percent of 

each activity unit where it is managed in a passive scenario.

4-2 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by:... 

• Retaining all large fire resistant trees; 

Consideration: In all management areas, the intent is to retain the largest of the large 

trees across the landscape. The diversity of species on the site is retained, though the 

proportion of one species over another may change considerably. Generally, the 

preference for conifer species to retain is (from highest to lowest): Douglas-fir, sugar 

pine, western white pine, Shasta red fir, mountain hemlock, ponderosa pine, white 

fir/grand fir, and lodgepole pine. These preferences may vary on specific sites 

depending on the abundance of a given species, presence of pathogens, vegetative 

potential, and/or site-specific objectives (DEIS, page 29).

4-3 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by:... 
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439

• Retaining all old trees regardless of size; 

Consideration: It is unclear what the commenter defines as “old” and for what specific 

biological objective that benefits Management Indicator Species or matsutake production 

in order to consider this comment.

4-4 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by:... 

• Use more prescribed fire instead of harmful ground-based logging; Well-trained 

fire crews could go in ahead of the fire and pre-treat the stands and strategically 

arrange fuel in such a way to reduce the chances that large and old trees will die 

and increase the chances that some of the small and young trees will die. 

Consideration: Opportunities for use of prescribed fire were assessed and it would be 

applied to maintain or enhance fire-dependent ecosystems on 2,312 acres (DEIS, page 

iv). Reintroduction of fire prior to any other active management such as thinning is not a 

viable option in many dense stands because it would cause an undesired level of 

mortality to the overstory trees; retention of overstory trees is desirable and is part of the 

Purpose and Need of the BLT project. 

4-5 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by:... 

• Minimize road construction; 

• Avoid road construction in de facto unroaded areas including in the Oregon 

Cascades Recreation Area; 

Consideration: No permanent roads would be constructed and temporary roads are 

discussed in several resource areas, including Transportation starting on page 321 of the 

DEIS. There is no permanent or temporary road construction within the Oregon 

Cascades Recreation Area.

4-6 We urge the Forest Service to include more mitigation for management indicator species 

and commercial mushroom production by:... 

• Avoid overstory removal (Figure 3-10 page 96 makes “improvement cut” look 

like overstory removal. Treatments like this would be bad for wildlife and bad 

for fire hazard.) 

Consideration: Generally, most improvement cuts are prescribed in lodgepole pine. A 

considerable portion of these stands have a legacy of salvage operations during the 1980s 

(DEIS, page 87). There is a compelling need for active management because overall 

stand health was not addressed at that time. Since then, dense regeneration has come in 

under some very unhealthy conditions. In this case, Improvement Cuts would remove 

diseased trees and thin the understory, which would be similar in appearance to an 

overstory removal with suitable live (green) tree replacements. If the stand is relatively 

healthy, the only overstory trees to be removed would be those that are competing and 

the stand would look more like a thinning.

4-7 The Viable Ecosystems Guide is a non-NEPA document. The Forest Service must 

consider alternatives to it. The guide should be placed on the FS website and made 

available for public review and comment. 

Consideration: Viable Ecosystems is a modeling tool and is explained on page 85. It is 

unclear why the commenter believes the Forest Service needs public comment on it as 

this is their opportunity. Also, the commenter provided no alternative or reasons why 

this model might be inaccurate. 
BLT Project Environmental Impact Statement 

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440

4-8 The Northwest Forest Plan requires the FS to maintain habitat to support 100% 

potential populations of certain species such as the black-backed woodpecker, 

flammulated owl. The Eastside Screens has similar requirements that apply to a number 

of species associated with cavities in dead wood. Potential population is a discredited 

methodology, but it suggests a non-degradation policy. The FS is using DecAID even 

though it does not directly translate into potential population terms. Nonetheless the FS 

should be using 80% tolerance levels for large snags because it most closely compares 

to the non-degradation policy inherent in the 100% potential population requirement. 

Consideration: Tolerance levels do not equate to population potential, nor imply 

viability, but they are assumed to provide habitat at varying snag densities (DEIS, page 

129). “Across the forest, snags are to be managed at 100 percent of Maximum 

Population Potential for primary cavity excavators (MPP). The forest determined 

guidelines for meeting this standard and documented them in the Deschutes National 

Forest Wildlife Tree and Log Implementation Strategy (USDA 1994). This strategy 

estimates the number of hard snags per acre by vegetative series and species” (DEIS, 

page 132). Page 33 displays minimum snag levels based on this strategy. Table 2-41 on 

page 135 of the FEIS displays Maximum Population Potential snag levels for within the 

Northwest Forest Plan and east within the Eastside Screens. Consistency with the 

Northwest Forest Plan regarding maximum Population Potential is displayed in the FEIS 

on pages 401-402. 

4-9 Consider the recommendations for dry forest landscapes found in the final spotted owl 

recovery plan. Even though some of this project area is outside the range of the spotted 

owl, the recovery plan makes some nice recommendations for restoring ecological 

process in dry forests such as these. There are a number of species other than the spotted 

owl that prefer complex forests (e.g. goshawk, pileated woodpecker, marten, fisher, 

flammulated owl, three-toed woodpecker) so there is no reason that these 

recommendations should not be relevant here. 

Consideration: The Final Recovery Plan and its applicability to the BLT project is 

disclosed starting on page 175 of the DEIS.

4-10 Recognize the Many Values of Snags, Decayed Wood And Associated Functions And 

Species 

...In a dynamic ecosystem life may be fleeting but the snags and logs that survive 

disturbance provide very critical temporal links from one stand to the next. Under 

natural conditions, a forest hands down a large legacy of living and dead material from 

one stand to another even after an intense disturbance. Even non-stand-replacing 

disturbance creates pulses of dead material that are critical for forest ecosystems. 

Consideration: The value of dead wood is recognized on page 132 of the DEIS. All 

existing snags would remain except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety (DEIS, page 33). 

4-11 New information on Snags. 

The 9th Circuit recently reiterated that “species viability may be met by estimating and 

preserving habitat ‘only where both the Forest Service’s knowledge of what quality and 

quantity of habitat is necessary to support the species and the Forest Service’s method 

for measuring the existing amount of that habitat are reasonably reliable and accurate.’ 

Earth Island Inst. v. U.S. Forest Serv., 442 F.3d 1147, 1175-76 (9th Cir. 2006) (quoting 

Native Ecosystems Council v. U.S. Forest Serv., 428 F.3d 1233, 1250 (9th Cir. 2005))” 

ONRC v. Goodman (Mt Ashland case, 9th Circuit Sept 24, 2007) (emphasis added). 

http://www.ca9.uscourts.gov/ca9/newopinions.nsf/499E49C2E3B21A128825736000533
Environmental Impact Statement BLT Project

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BBA/$file/0735110.pdf The Forest Service cannot provide any assurance that it’s plans 

and projects will assure viable populations of native wildlife that depend on dead trees. 

The Forest Service does not know how many snags are necessary to support viable 

populations of cavity associated species. The Forest Service has provided no credible 

link between DecAID tolerance levels, potential population levels, and/or viable 

populations. The Forest Service has also failed to reliably quantify existing and 

projected habitat for snag associated species. 

Consideration: The best available science on dead wood relationships to wildlife habitat 

was compiled in the form of DecAID, and local data sets. Methods and their reliability 

for determining habitat, models and datasets are described in the DEIS pages 127-132. 

Species that are present in the project area remain through a historical range of 

conditions. The BLT project seeks to manage snags and down wood habitat at various 

densities across the landscape utilizing a reference condition based on the historical 

range of variability as described in the EIS. Managing within the historical range would 

provide for those species that survived to the present with those densities meeting 

NFMA objectives. This is explained in the DEIS page 133: “By retaining all existing 

snags and down wood except those that must be removed under limited circumstances, 

the analysis area is on a pathway to shift closer to the Historical Range of Variability 

(HRV). This management strategy recognizes the need of high densities of dead wood 

for wildlife, and the varying densities historically present.” The Forest Service and this 

DEIS do not link DecAID to tolerance levels, potential population levels, and/or viable 

populations. Tolerance levels provide assurance of meeting individual needs. “Basically 

the higher the tolerance level, the more assurance that you are providing habitat to meet 

the needs of more individuals in the population (Mellen et al 2006)” (DEIS, page 128). 

DecAID is a web-based dataset, it is not a model. It is a synthesis of all of the best 

available research on dead wood. DecAID does not provide information on all life needs 

of a given species. It integrates current research/studies on wildlife use of dead wood 

(snags, down wood, dead portions of live trees) in various habitat types. From this, 

tolerance levels are generated. DecAID was not used to set snag levels in BLT. The 

Deschutes National Forest Plan, as amended, specifies standards and guidelines for snags 

and down wood. Across the forest, snags are to be managed at 100 percent of Maximum 

Population Potential for primary cavity excavators (MPP). The forest determined 

guidelines for meeting this standard and documented them in the Deschutes National 

Forest Wildlife Tree and Log Implementation Strategy (USDA 1994). This strategy 

estimates the number of hard snags per acre by vegetative series and species. 

Minimum snag levels are specified on page 33 of the DEIS. Project activities are 

consistent with the Deschutes Land and Resource Management Plan and the associated 

amendments including the Northwest Forest Plan for Matrix and Administratively 

Withdrawn Lands and Eastside Screens, as displayed in Chapter 3 and this Appendix. 

The design criteria common to all alternatives is to retain all existing snags except those 

that pose a hazard (FEIS, Resource Protection Measures and Project Design Features). 

The DEIS, pages 132-138, contains the analysis of changes in snags and down wood 

overtime, by alternative across the landscape by habitat type. This is followed by snag 

associated species, such as wood peckers and American marten. This analysis includes 

snag densities required for nesting and denning with disclosure on effects of use of the 

area post-harvest. 

4-12 An unavoidable impact of all commercial logging is to “capture mortality” which 

reduces valuable snag habitat in the short-term (via hazard tree felling) and in the longterm (via delayed recruitment and reduced overall recruitment). For example, in a 

thinning project on the Siuslaw National Forest “modeling stand #502073 over a 100-

year cycle [using ORGANON] predicts a total stand mortality of 202 trees (>10 inches 
BLT Project Environmental Impact Statement 

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442

dbh) for the unthinned stand, while mortality for the thinned stand was two trees. 

Therefore, thinning will reduce density-dependent mortality within the stand by 99%.”36 

There is no reason to think that thinning in densely stocked forests elsewhere would be 

any different. 

Consideration: The Siuslaw and the Deschutes National Forests have a different 

moisture regime, soil productivity, and stand composition. Therefore, this citation and 

conclusion is not relevant to this project. Because of the different environmental 

conditions, the Siuslaw thinning prescriptions, rates of growth, and mortality (snag 

recruitment) cannot be applied to this analysis. In general, thinning in densely stocked 

forest reduces density-dependent mortality. However, the prescriptions for his project 

area are such that potential density-related mortality is not eliminated. The DEIS 

discloses this in several places including page 149: “Thinning activities would lessen the 

risk of future large scale bark beetle outbreak, but endemic levels of beetles would 

remain present and result in much lower levels of future tree mortality.” A landscape 

analysis is also necessary to determine the scale and intensity of effects. Landscape 

analysis of changes in dead wood over time showed there were little to no differences 

between alternatives (DEIS, page 394). The modeling methodology is explained 

beginning on page 127. Analysis of changes in dead wood over time showed there were 

little to no differences between alternatives (DEIS, page 394). 

Also, a Project Design Feature for all action alternatives would retain 15 percent of each 

harvest unit in a condition that allows passive mortality processes to take place. 

4-13 The agencies need to prepare a EIS to consider a replacement methodology for 

maintaining species and other values associated with dead wood. This is especially 

critical because adequate dead wood is recognized as an essential feature of healthy 

forests and the Forest Service has identified lots of “management indicator species” 

associated with dead wood habitat. 

... the current direction of managing for 100 percent population potential levels of 

primary excavators may not represent the most meaningful measure of managing for 

cavity-nesters and that these snag levels, under certain conditions, may not be adequate 

for some species. 

Consideration: This is outside the scope of this project.

4-14 The potential population models are based on the number of trees needed for nesting 

cavity-excavator birds, however, “[t]he high value of large, thick-barked snags in 

severely burned forests has as much to do with feeding opportunities as it does with 

nesting opportunities they provide birds.” (Hutto. ConBio 20(4). 2006. 

http://avianscience.dbs.umt.edu/documents/hutto_conbio_2006.pdf ). The number of 

snags needed to support bird feeding, escape from predators, and other life functions, is 

different than, and likely higher than, the number of snags needed to support nesting, so 

the agencies’ existing “potential population” snag standards are arbitrary and 

capricious. 

Consideration: The BLT project does not include “severely burned forest”. Potential 

population calculations are disclosed on page 388 of the DEIS. 

4-15 The bottom line is that current management at both the plan and project level does not 

reflect all this new information about the value of abundant snags and down wood. The 

agency must avoid any reduction of existing or future large snags and logs (including as 

 

36 NOAA April 4, 2006 Magnuson Act consultation on Essential Fish Habitat and Response to Siuslaw NF Lobster 

Project BA. 
Environmental Impact Statement BLT Project

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443

part of this project) until the applicable management plans are rewritten to update the 

snag retention standards. (See letter for more detail) 

Consideration: See response to Comment 4-11. DecAID includes a compilation of the 

best available science on deadwood relationship. Also, it is important to recognize the 

value of larger snags that develop sooner when a stand is thinned (DEIS, page 136). 

Landscape analysis of changes in dead wood over time showed there were little to no 

differences between alternatives (DEIS, page 394). 

1-75 Although DecAID helps bring together lots of useful information about snag associated 

species, the agency must recognize and account for the short-comings of DecAID and 

cannot rely on DecAID to provide the project-level snag standards because: DecAID is a 

tool designed for plan level evaluations, because DecAID itself has not been subjected to 

NEPA analysis and comparison to alternatives, and because DecAID is an inadequate 

tool for the purpose. 

4-16 Although DecAID helps bring together lots of useful information about snag associated 

species, the agency must recognize and account for the short-comings of DecAID and 

cannot rely on DecAID to provide the project-level snag standards because: DecAID is a 

tool designed for plan level evaluations, because DecAID itself has not been subjected to 

NEPA analysis and comparison to alternatives, and because DecAID is an inadequate 

tool for the purpose. 

Consideration: DecAID is a website, an Internet-based meta-analysis (based on proven 

scientific and statistical methods) of scientific papers, research data, wildlife and 

vegetation data bases that can be utilized by the public as well as the Forest Service. It 

should be viewed as a scientific publication, not a Forest Plan with standards and 

guidelines. While DecAID was originally developed for plan level analysis, there is a 

guide for correct the use of DecAID on projects: 

http://www.fs.fed.us/r6/nr/wildlife/decaid/. 

Caveats and limitations for DecAID are displayed in the DEIS starting on page 129. 

DecAID was not used to provide the project-level snag standards for BLT.

1-76 Before relying on DecAID, the agency must prepare a comprehensive NEPA analysis to 

consider alternative ways of ensuring viability of all species dependent upon snags and 

dead wood. While it is true that the “potential population” or “habitat capability” 

method is no longer considered scientifically valid, the agency has not yet considered a 

full range of alternative methods to replace the habitat capability method mandated in 

the forest plans. 

4-17 Before relying on DecAID, the agency must prepare a comprehensive NEPA analysis to 

consider alternative ways of ensuring viability of all species dependent upon snags and 

dead wood. While it is true that the “potential population” or “habitat capability” 

method is no longer considered scientifically valid, the agency has not yet considered a 

full range of alternative methods to replace the habitat capability method mandated in 

the forest plans. 

Consideration: The agency does not rely on DecAID to ensure viability of all species 

dependent upon snags and dead wood. This comment is outside the scope of the project 

and the project meets or exceeds Forest Plan Standards and Guidelines and NFMA (see 

response to Comment 4-11).

4-18 While it is true that the new DecAID tolerance levels cannot be directly translated to 

“potential population” requirements in the LRMP and Eastside Screens, it should be 

obvious that 100% potential population is much more like “high” assurance than 
BLT Project Environmental Impact Statement 

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moderate or low assurance, so the Forest Service should be striving to meet 80% 

DecAID tolerance levels which provide a high level of assurance of meeting the needs of 

primary cavity excavators consistent with the Eastside Screens requirement to maintain 

enough snags to support 100% potential populations. 

Consideration: This project seeks to retain all existing snags as a start to managing 

towards Historical Range of Variability and utilizes several methods for improving 

habitat for many species, such as limiting the extent of a disturbance event and thinning 

to increase tree size. Tolerance levels provide assurance of meeting individual needs. 

Mellon et al, 2006 states “Basically the higher the tolerance level, the more assurance 

that you are providing habitat to meet the needs of more individuals in the population 

(DEIS, page 128).” 

Tolerance levels do not equate to population potential, nor imply viability, but they are 

assumed to provide habitat at varying snag densities (DEIS, page 129). “Across the 

forest, snags are to be managed at 100 percent of Maximum Population Potential for 

primary cavity excavators (MPP). The forest determined guidelines for meeting this 

standard and documented them in the Deschutes National Forest Wildlife Tree and Log 

Implementation Strategy (USDA 1994). This strategy estimates the number of hard 

snags per acre by vegetative series and species (DEIS, page 132).” Page 33 displays 

minimum snag levels based on this strategy.

1-77 Before using DecAID, the agency must establish a rational link between the tolerance 

levels in DecAID and the relevant management requirements in the applicable resource 

management plan. For instance, since the Northwest Forest Plan and the Eastside 

Screens require maintenance of 100% potential population of at least some cavitydependent species, the agency must explain why that does not translate into maintaining 

100% of the potential tolerance level. If the site is capable of supporting 80% tolerance 

levels, the agency should not be able to manage for 30-50% tolerance levels and still 

meet the 100% potential population requirement. 

4-19 Before using DecAID, the agency must establish a rational link between the tolerance 

levels in DecAID and the relevant management requirements in the applicable resource 

management plan. For instance, since the Northwest Forest Plan and the Eastside 

Screens require maintenance of 100% potential population of at least some cavitydependent species, the agency must explain why that does not translate into maintaining 

100% of the potential tolerance level. If the site is capable of supporting 80% tolerance 

levels, the agency should not be able to manage for 30-50% tolerance levels and still 

meet the 100% potential population requirement. 

Consideration: See Response to Comment 4-18.

1-78 DecAID does not replace the discredited forest plan standards because DecAID is 

informational only. DecAID does not specify management objectives. The agency must 

specify the management objective based on RMP objectives for the land allocation or 

based on natural “range of variation.” Since large snags are outside the natural range 

of variability across the landscape, the agency must retain all large snags to start 

moving the landscape toward the natural range of variability, or the agency must 

carefully justify in the NEPA analysis every large snag it proposes to remove. See 

Jerome J. Korol, Miles A. Hemstrom, Wendel J. Hann, and Rebecca A. Gravenmier. 

2002. Snags and Down Wood in the Interior Columbia Basin Ecosystem Management 

Project. PNW-GTR-181. http://www.fs.fed.us/psw/publications/documents/gtr181/049_Korol.pdf This paper estimates that even if we apply enlightened forest 

management on federal lands for the next 100 years, we will still reach only 75% of the 
Environmental Impact Statement BLT Project

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445

historic large snag abundance measured across the interior Columbia Basin, and most 

of the increase in large snags will occur in roadless and wilderness areas. 

4-20 DecAID does not replace the discredited forest plan standards because DecAID is 

informational only. DecAID does not specify management objectives. The agency must 

specify the management objective based on RMP objectives for the land allocation or 

based on natural “range of variation.” Since large snags are outside the natural range 

of variability across the landscape, the agency must retain all large snags to start 

moving the landscape toward the natural range of variability, or the agency must 

carefully justify in the NEPA analysis every large snag it proposes to remove. 

Consideration: The project biologists have reviewed this publication and do not 

disagree with the findings. The Deschutes National Forest set the standard for snags and 

down wood based on the in the Deschutes National Forest Wildlife Tree and Log 

Implementation Strategy (USDA 1994). This strategy meets or exceeds specified levels 

in both the Northwest Forest Plan and the Eastside Screens. The BLT Project uses this 

strategy, and it is applied across all management areas. 

Snag habitat, post-implementation, would generally remain in its current state. All 

existing snags would remain, except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety (DEIS, page 33). 

Landscape analysis of changes in dead wood over time showed there were little to no 

differences between alternatives (DEIS, page 394). Deadwood range of variation begins 

on page 131 of the DEIS.

4-21 DecAID snag levels for “unharvested” stands represent snags levels from a world where 

disturbances (e.g. fire, insects, disease) are artificially suppressed. The goal should not 

be to conduct a disturbance (such as thinning) that results in snag levels similar to an 

undisturbed stand. That makes no sense. Natural stands have periodic disturbances and 

pulses of snags that go along with those disturbances. The agencies need to get creative 

and learn to mimic natural disturbance which would always leave behind lots of dead 

trees. Logging that leaves behind only a few snags per acre is an UNusual disturbance 

event. 

Consideration: The DEIS discloses the effects of disturbance (pages 131 and 132). 

The Forest Service must consider multiple goals for an area, including, in some cases, 

retaining large quantities of dead wood (reference the Purpose and Need on page 2 of the 

DEIS). The goal of thinning is not to mimic natural disturbances. 

The management of snags relies on active and passive management. Active 

management is occurring on 7,499 acres of an 80,000-acre 5th field watershed. The 

heaviest concentrations of dead and down wood that provide the highest quality habitat 

for both species is located in the Mt. Thielsen Wilderness and Oregon Cascades 

Recreation Area (OCRA), adjacent to the BLT area, where timber harvest would not 

occur (DEIS, page 150). In addition, 15 percent of each activity unit would be managed 

in a passive management scenario (DEIS, page 29).

1-79 The agency cannot use “average” snag levels (e.g. 50% tolerance level) as a 

management objective within treatment areas, because treatments are essentially 

displacing natural disturbance events which would normally create and retain large 

numbers of snags, so disturbance areas should have abundant snags, not average levels 

of snags. It would be inconsistent with current science and current management 

direction to manage only for the mid-points and low points. The agency should manage 

for the full natural range dead wood levels, including the peaks of snag abundance that 
BLT Project Environmental Impact Statement 

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446

follow disturbance. 

4-22 The agency cannot use “average” snag levels (e.g. 50% tolerance level) as a 

management objective within treatment areas, because treatments are essentially 

displacing natural disturbance events which would normally create and retain large 

numbers of snags, so disturbance areas should have abundant snags, not average levels 

of snags. It would be inconsistent with current science and current management 

direction to manage only for the mid-points and low points. The agency should manage 

for the full natural range dead wood levels, including the peaks of snag abundance that 

follow disturbance. 

Consideration: The Forest Service does not use tolerance levels as a management 

objective; only to display effects for individual species. See Response to Comment 4-

21. Snag level variability can be found in the adjacent areas managed in a passive 

management scenario and within the activity units themselves which retains existing 

snags plus the 15 percent retention areas where densities have potential to increase.

1-80 Be sure to use the DecAID tool appropriately. The agency must address the dynamics of 

snag habitat over time, by ensuring that recommended snag levels are maintained over 

time given typically high rates of snag fall and low rates of snag recruitment following 

fire. These dynamics are not accounted for in the DecAID advisor. The agency often 

misuses the DecAID decision support tool by looking at only a snap-shot in time. The 

agency relies on DecAID to analyze impacts on snag dependent species, but the agency 

fails to recognize that 

“DecAID is NOT: ... a snag and down wood decay simulator or recruitment model [or] 

a wildlife population simulator or analysis of wildlife population viability. ... Because 

DecAID is not a time-dynamic simulator ... it does not account for potential temporal 

changes in vegetation and other environmental conditions, ... DecAID could be 

consulted to review potential conditions at specific time intervals and for a specific set of 

conditions, but dynamic changes in forest and landscape conditions would have to be 

modeled or evaluated outside the confines of the DecAID Advisor.” 

Marcot, B. G., K. Mellen, J. L. Ohmann, K. L. Waddell, E. A. Willhite, B. B. Hostetler, S. 

A. Livingston, C. Ogden, and T. Dreisbach. In prep. “DecAID -- work in progress on a 

decayed wood advisor for Washington and Oregon forests.” Research Note PNW-RNXXX. USDA Forest Service, Pacific Northwest Region, Portland OR. (pre-print) 

http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf/HomePageLinks/44C813BC574B

DFCC88256B3E006C63DF

To clearly and explicitly address the issue of “snag dynamics” the can start by reading 

and responding to the snag dynamics white paper on the DecAID website which says 

“To achieve desired amounts and characteristics of snags and down wood, managers 

require analytical tools for projecting changes in dead wood over time, and for 

comparing those changes to management objectives such as providing dead wood for 

wildlife and ecosystem processes” and includes “key findings” and “management 

implications” including “The high fall rate (almost half) of recent mortality trees needs 

to be considered when planning for future recruitment of snags and down wood. Trees 

that fall soon after death provide snag habitat only for very short periods of time or not 

at all, but do contribute down wood habitat. In fact, these trees are a desirable source of 

down wood as they will often begin as mostly undecayed wood and, if left on the forest 

floor, will proceed through the entire wood decay cycle with its associated ecological 

organisms and processes that are beneficial to soil conditions and site productivity.” 

http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf/HomePageLinks/863EEA66F397

52C088256C02007DF2C0?OpenDocument 

4-23 Be sure to use the DecAID tool appropriately. The agency must address the dynamics of 
Environmental Impact Statement BLT Project

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447

snag habitat over time, by ensuring that recommended snag levels are maintained over 

time given typically high rates of snag fall and low rates of snag recruitment following 

fire. These dynamics are not accounted for in the DecAID advisor. The agency often 

misuses the DecAID decision support tool by looking at only a snap-shot in time. 

Consideration: DecAID was used appropriately. The analysis includes disclosure of 

existing snags, post harvest, and snag levels over time. See methodology starting on 

DEIS page 127, Deadwood Historical Range of Variation disclosures begin on page 132 

of the DEIS and in Appendix B. Deadwood Historical Range of Variation disclosures 

begin on page 132 of the DEIS and in Appendix B.

1-81 The tolerance levels from DecAID may be too low to support viable populations of 

wildlife associated with dead wood, because anthropogenic factors that tend to reduce 

snags (e.g., firewood cutting, hazard tree felling, fire suppression, and salvage logging) 

may have biased the baseline data that DecAID relies upon to describe “natural” 

conditions. See Kim Mellen, Bruce G. Marcot, Janet L. Ohmann, Karen L. Waddell, 

Elizabeth A. Willhite, Bruce B. Hostetler, Susan A. Livingston, and Cay Ogden. DecAID: 

A Decaying Wood Advisory Model for Oregon and Washington in PNW-GTR-181, citing 

Harrod, Richy J.; Gaines, William L.; Hartl, William E.; Camp, Ann. 1998. Estimating 

historical snag density in dry forests east of the Cascade Range. PNW-GTR-428. 

http://www.fs.fed.us/pnw/pubs/gtr_428.pdf

4-24 The tolerance levels from DecAID may be too low to support viable populations of 

wildlife associated with dead wood, because anthropogenic factors that tend to reduce 

snags (e.g., firewood cutting, hazard tree felling, fire suppression, and salvage logging) 

may have biased the baseline data that DecAID relies upon to describe “natural” 

conditions. 

Consideration: See Response to Comment 4-11. The project is consistent with the 

Deschutes National Forest Plan and NFMA by following levels specified in the 

Deschutes National Forest Wildlife Tree and Log Implementation Strategy (USDA 

1994). 

The commenter does not specify which tolerance levels from DecAID are too low, 

suggest a resolution, or cite better data to utilize. Species Tolerance Levels are based on 

actual use studies and vegetation tolerance levels area based on years of plot data. The 

paper cited by the commenter is outdated and the website has been updated. See Kim 

Mellen, Bruce G. Marcot, Janet L. Ohmann, Karen Waddell, Susan A. Livingston, 

Elizabeth A. Willhite, Bruce B. Hostetler, Catherine Ogden, and Tina Dreisbach, 2006: 

DecAID: The Decayed Wood Advisor for Managing Snags, Partially Dead Trees, and 

Down Wood for Biodiversity in Forests of Washington and Oregon. Version 2.0. USDA 

Forest Service, Pacific Northwest Region and Pacific Northwest Research Station; USDI 

Fish and Wildlife Service, Oregon State Office; Portland, Oregon. 

http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf . Further, for a discussion on 

“natural conditions” see: Comparison of Historical Range of Variability for Dead Wood: 

DecAID vs. Other Published Estimates at http://www.fs.fed.us/r6/nr/wildlife/decaid/hrvdead-wood-comparison.shtml

1-82 DecAID is still an untested new tool. The agencies must conduct effectiveness monitoring 

to determine whether the snag and down wood retention recommendations in the 

DecAID advisor will meet management objectives for wildlife and other resource values. 

4-25 DecAID is still an untested new tool. The agencies must conduct effectiveness monitoring 

to determine whether the snag and down wood retention recommendations in the 
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448

DecAID advisor will meet management objectives for wildlife and other resource values. 

Consideration: This is outside the scope of this project. DecAID includes a 

compilation of the best available science on deadwood relationship. “DecAID does not 

replace standards and guidelines within Forest Land and Resource Management Plans 

(LRMPs). It does not dictate or prescribe levels of snags and down wood to leave in a 

treatment unit, planning area or landscape. It does provide the scientific bases for 

management of decayed wood to meet objectives outlined in LRMPs and analyzing the 

effects of implementation of those standards and/or objectives. Any deviations from 

Forest LRMPs must be justified and documented based on the best available science. 

Prescribing snag levels below existing LRMP levels would require either a nonsignificant LRMP amendment or a larger scale analysis during revision of the LRMP.” 

Mellen et al 2007 at http://www.fs.fed.us/r6/nr/wildlife/decaid/

1-83 The “unharvested” inventory data used in DecAID may represent but a snapshot in time, 

and fail to capture the variability of dead wood over time, including the pulses of 

abundant dead wood that follow disturbances and may prove essential for many wildlife 

species. 

4-26 The “unharvested” inventory data used in DecAID may represent but a snapshot in time, 

and fail to capture the variability of dead wood over time, including the pulses of 

abundant dead wood that follow disturbances and may prove essential for many wildlife 

species. 

Consideration: See Response to Comments 4-21, 4-23 and 4-24 regarding deadwood 

variation over the landscape, analysis of dead wood over time, and DecAID discussion 

of use of “unharvested” inventory data. 

1-84 DecAID must be used with extreme caution in post-fire landscapes because the data 

supporting DecAID does not include natural post-fire landscapes. (“The inventory data 

likely do not represent recent post-fire conditions very well ... young stands originating 

after recent wildfire are not well represented because they are an extremely small 

proportion of the current landscape ... The dead wood summaries cannot be assumed to 

apply to areas that are not represented in the inventory data.” “DecAID caveats” 

http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf. 

4-27 DecAID must be used with extreme caution in post-fire landscapes because the data 

supporting DecAID does not include natural post-fire landscapes. (“The inventory data 

likely do not represent recent post-fire conditions very well ... young stands originating 

after recent wildfire are not well represented because they are an extremely small 

proportion of the current landscape ... The dead wood summaries cannot be assumed to 

apply to areas that are not represented in the inventory data.” “DecAID caveats” 

http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf

Consideration: The BLT project does not include a post-fire landscape.

1-85 DecAID relies on a wide range of sources in the literature, some of which recommend 

much higher levels of snag retention than reflected in the advisor. The agency NEPA 

analysis should disclose the published literature with higher levels of snag and wood 

retention and discuss their potential relevance for the project. (“the agency must 

disclose responsible opposing scientific opinion and indicate its response in the text of 

the final statement itself. 

4-28 DecAID relies on a wide range of sources in the literature, some of which recommend 

much higher levels of snag retention than reflected in the advisor. The agency NEPA 
Environmental Impact Statement BLT Project

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449

analysis should disclose the published literature with higher levels of snag and wood 

retention and discuss their potential relevance for the project. (“the agency must 

disclose responsible opposing scientific opinion and indicate its response in the text of 

the final statement itself. 40 C.F.R. § 1502.9(b).” Center for Biological Diversity v. 

United States Forest Service, No. 02-16481 (9th Cir., Nov. 18, 2003).) 

Consideration: The commenter is not specific enough with this request. It is unclear 

which literature is opposed to the science cited by the Forest Service. DecAID literature 

specifies a particular use of a species for a specific research site. It does not include 

recommendations for snag retention.

1-86 DecAID tolerance levels need careful explanation. These tolerance levels are very 

difficult to put in terms that are understandable by the general public, but if the Forest 

Service is going to use this tool they must make it understandable. The NEPA analysis 

should provide cumulative species curves for each habitat type and each forest structural 

stage and should explain the studies and publications that support the data points on the 

curves. What kind of habitat were the studies located in? What was the management 

history of the site? Was the study investigated nesting/denning, or roosting and foraging 

too? 

4-29 DecAID tolerance levels need careful explanation. These tolerance levels are very 

difficult to put in terms that are understandable by the general public, but if the Forest 

Service is going to use this tool they must make it understandable. The NEPA analysis 

should provide cumulative species curves for each habitat type and each forest structural 

stage and should explain the studies and publications that support the data points on the 

curves. What kind of habitat were the studies located in? What was the management 

history of the site? Was the study investigated nesting/denning, or roosting and foraging 

too? 

Consideration: A disclosure of Tolerance Levels is found on page 128 of the DEIS. 

The BLT interdisciplinary team used specific data for individual species and vegetative 

data for the snag Historical Range of Variation analysis based on habitat types. Habitat, 

management history, and individual life requirements are disclosed for each individual 

species discussed. The interdisciplinary team did not use cumulative species curves to 

discuss effects. It is unclear how adding an additional analysis of these curves would 

enhance the public’s or Responsible Official’s understanding of the effects of this 

project.

1-87 DecAID does not account for the unique habitat features associated with some types of 

snags. DecAID primarily just counts snags and assumes that all snags of approximately 

the same size have equal habitat value, but this fails to account for the fact that certain 

types of snags and dead wood features are unique, such as: hardwood snags, hollow 

trees and logs, different decay classes, etc. The NEPA analysis must account for these 

features and the agency should disproportionately retain dead wood likely to serve these 

unique habitat functions. 

4-30 DecAID does not account for the unique habitat features associated with some types of 

snags. DecAID primarily just counts snags and assumes that all snags of approximately 

the same size have equal habitat value, but this fails to account for the fact that certain 

types of snags and dead wood features are unique, such as: hardwood snags, hollow 

trees and logs, different decay classes, etc. The NEPA analysis must account for these 

features and the agency should disproportionately retain dead wood likely to serve these 

unique habitat functions. 

Consideration: DecAID was not the sole source of information used in the analysis. 
BLT Project Environmental Impact Statement 

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450

Individual species that require a unique habitat feature associated with snags is disclosed 

in the analysis (e.g. Lewis’ woodpecker, page 197, DEIS). All existing snags would 

remain except where snags must be felled for temporary and Maintenance Level 1 roads, 

log landings, or occupational safety (DEIS, page 33). Post-implementation, the 

alternatives would generally remain similar to the existing snag habitat. DecAID 

addresses unique habitat features and decay classes as well as a wealth of other 

information.

1-88 DecAID authors caution that “it is imperative, however, to not average snag and down 

wood densities and sizes across too broad an area, such as across entire watersheds, 

leaving large areas within watersheds with snags or down wood elements that are too 

scarce or too small” Kim Mellen, Bruce G. Marcot, Janet L. Ohmann, Karen L. 

Waddell, Elizabeth A. Willhite, Bruce B. Hostetler, Susan A. Livingston, and Cay Ogden. 

DecAID: A Decaying Wood Advisory Model for Oregon and Washington in PNW-GTR181. http://www.fs.fed.us/psw/publications/documents/gtr-181/042_MellenDec.pdf While 

we agree that snags and down wood must not be averaged over wide areas, we also must 

emphasize that snags and down wood are far below historic levels on non-federal lands, 

so in order to ensure viable populations of wildlife and avoid trends toward ESA listing, 

federal lands must be managed to compensate for the lack of down wood on non-federal 

lands. 

4-31 DecAID authors caution that “it is imperative, however, to not average snag and down 

wood densities and sizes across too broad an area, such as across entire watersheds, 

leaving large areas within watersheds with snags or down wood elements that are too 

scarce or too small” Kim Mellen, Bruce G. Marcot, Janet L. Ohmann, Karen L. 

Waddell, Elizabeth A. Willhite, Bruce B. Hostetler, Susan A. Livingston, and Cay Ogden. 

DecAID: A Decaying Wood Advisory Model for Oregon and Washington in PNW-GTR181. http://www.fs.fed.us/psw/publications/documents/gtr-181/042_MellenDec.pdf While 

we agree that snags and down wood must not be averaged over wide areas, we also must 

emphasize that snags and down wood are far below historic levels on non-federal lands, 

so in order to ensure viable populations of wildlife and avoid trends toward ESA listing, 

federal lands must be managed to compensate for the lack of down wood on non-federal 

lands. 

Consideration: The interdisciplinary team looked at stand and landscape level for 

disclosure of effects. BLT meets or exceeds the Deschutes National Forest Standards 

and Guidelines by using the Deschutes National Forest Wildlife Tree and Log 

Implementation Strategy (USDA 1994). This strategy estimates the number of hard 

snags per acre by vegetative series and species (DEIS, page 132). In most cases, the best 

available habitat exists on Federal lands and this was disclosed in the analysis. 

Snag habitat, post-implementation, would generally remain in its current state. All 

existing snags would remain, except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety (DEIS, page 33). 

Landscape analysis of changes in dead wood over time showed there were little to no 

differences between alternatives (DEIS, page 394). Deadwood range of variation begins 

on page 131 of the DEIS. 

1-89 DecAID appears to be based on the idea that the habitat needs of certain key wildlife 

species represent the best determinant of how much dead wood to retain, and this may in 

fact be true, but DecAID should also include cumulative curves for other ecological 

functions provided by dead wood, including: site productivity, nutrient storage and 

release, erosion control, sediment storage, water storage, water infiltration and 

percolation, post-fire micro-site maintenance, biological substrate, thermal mass, etc. 
Environmental Impact Statement BLT Project

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451

How much dead wood is needed for these functions? 

4-32 DecAID appears to be based on the idea that the habitat needs of certain key wildlife 

species represent the best determinant of how much dead wood to retain, and this may in 

fact be true, but DecAID should also include cumulative curves for other ecological 

functions provided by dead wood, including: site productivity, nutrient storage and 

release, erosion control, sediment storage, water storage, water infiltration and 

percolation, post-fire micro-site maintenance, biological substrate, thermal mass, etc. 

How much dead wood is needed for these functions? 

Consideration: What should and should not be included in DecAID is outside the scope 

of this analysis. The DEIS discloses the effects to other ecological functions provided by 

dead wood in Chapter 3. All existing snags would remain except where snags must be 

felled for temporary and Maintenance Level 1 roads, log landings, or occupational safety 

(DEIS, page 33). Except in areas maintained over time for fuels reduction (SPOTS) and 

firewood collection areas, the intent is to retain all existing levels of down wood 7 inches 

and greater in lodgepole pine and 9 inches and greater in all other Plant Association 

Groups. Only activity-created slash below these maximum diameters would be piled and 

utilized or disposed (DEIS, page 34).

1-90 DecAID may be best used for program level planning rather than project level planning. 

See Dallas Emch and Gary Larson, 2006. Review & Analysis of Remainder of Comments 

on EA Supplements for Multiple Timber Sales on Mt. Hood & Willamette National 

Forests on Remand in ONRCA v. Forest Service CV-03-613-KI (D.Or.). 4-10-06. 

4-33 DecAID may be best used for program level planning rather than project level planning. 

See Dallas Emch and Gary Larson, 2006. Review & Analysis of Remainder of Comments 

on EA Supplements for Multiple Timber Sales on Mt. Hood & Willamette National 

Forests on Remand in ONRCA v. Forest Service CV-03-613-KI (D.Or.). 4-10-06. 

Consideration: No response is necessary.

1-91 Any activity that degrades snag habitat is arbitrary and capricious until the agency 

develops new procedures in compliance with NEPA and NFMA or LFPMA. Compliance 

with old standards is meaningless, and in the absence of new standards, the agency 

cannot draw any credible conclusions about impacts to snag associated species. There is 

no way to use DecAID to comply with the east side screens’ requirement to maintain 

100% potential populations of cavity species (until the Forest Service develops some 

credible way to translate DecAID tolerance levels into potential population levels) 

4-34 Any activity that degrades snag habitat is arbitrary and capricious until the agency 

develops new procedures in compliance with NEPA and NFMA or FLPMA. Compliance 

with old standards is meaningless, and in the absence of new standards, the agency 

cannot draw any credible conclusions about impacts to snag associated species. There is 

no way to use DecAID to comply with the east side screens’ requirement to maintain 

100% potential populations of cavity species (until the Forest Service develops some 

credible way to translate DecAID tolerance levels into potential population levels). 

Consideration: Across the forest, snags are to be managed at 100 percent of Maximum 

Population Potential for primary cavity excavators (MPP). The forest determined 

guidelines for meeting this standard and documented them in the Deschutes National 

Forest Wildlife Tree and Log Implementation Strategy (USDA 1994). This strategy 

estimates the number of hard snags per acre by vegetative series and species (DEIS, page 

132). Page 33 displays minimum snag levels based on this strategy.
BLT Project Environmental Impact Statement 

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4-35 The traditional snag habitat model used by the agency is based on outdated science37

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: 

1. the model does not explicitly consider snag height so some snags may be too 

short for some species; 

Consideration: The agency has utilized a great number of snag habitat models, so it is 

unclear which “traditional model” the commenter is referencing. Viable Ecosystems was 

used for this project. The use of 2004 Greatest Nearest Neighbor (GNN) and 2006 

DecAID is very current in modeling methodology and explained starting on page 127 of 

the DEIS. The BLT project meets or exceeds standards given in the amended Deschutes 

National Forest Land and Resource Management Plan by following the Deschutes 

National Forest Wildlife Tree and Log Implementation Strategy (USDA 1994). All 

existing snags would remain except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety (DEIS, page 33). The 

BLT project seeks to manage snags and down wood habitat at various densities across 

the landscape utilizing a reference condition based on the historical range of variability 

as described in the DEIS on page 132. Managing within the historical range would 

provide for those species that survived to the present with those densities meeting 

NFMA objectives. The best available data on dead wood relationships to wildlife habitat 

was used in the form of DecAID, GNN, and local data sets. Effectiveness monitoring is 

ongoing in terms of research and DecAID will be continually updated with the new 

science as it becomes available. As this information is updated, management will adapt 

to the new information. The effects analysis is based on habitat needs determined by the 

best available science. 

Further, Project Design Features (DEIS, page 29) retain 15 percent of each activity unit 

in a passively-managed scenario where retention and recruitment of snags and down 

wood can occur.

4-36 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

2. snag recruitment rates over time; 

3. rates of snag fall rates over time; 

Consideration: See Response to Comment 4-35. Snag recruitment and fall rates were 

factored into the analysis using stand condition. Where relevant (e.g. black-backed 

woodpecker, page 148, DEIS), recruitment and fall rates are disclosed.

4-37 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

4. use of space by each species; 

Consideration: See response to Comment 4-35.

4-38 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

 

37 THOMAS, J. W., TECHNICAL EDITOR. 1979. Wildlife habitats in managed forests-the Blue Mountains of 

Oregon and Washington. U.S. Dep. Agric. Agric. Handb. No. 553. 512pp; CLINE, S. P., A. B. BERG, AND H. M. 

WIGHT. 1980. Snag characteristics and dynamics in Douglas-fir forests, western Oregon. J. Wildl. Manage. 

44:773786; NEITRO, W. A., V. W. BINKLEY, S. P. CLINE, R. W. MANNAN, B. G. MARCOT, D. TAYLOR, AND 

F. F. WAGNER. 1985. Snags. Pages 129-169 in E. R. Brown, tech. ed. Management of wildlife and fish habitats 

in forests of western Oregon and Washington. U.S. Dep. Agric. For. Serv. Publ. R6F& WL-192-1985. 
Environmental Impact Statement BLT Project

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453

to consider important factors such as: ... 

5. the need for roosting structures [and foraging trees, and escape cavities] as well 

as nesting structures; 

Consideration: See response to Comment 4-35. Effects associated with nesting, 

roosting, and foraging requirements by individual species is disclosed where applicable.

4-39 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

6. recent data on species needs from the Cascades and Blue Mountains has not 

been incorporated into the model 

Consideration: See response to Comment 4-35 on most recent data used.

4-40 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

7. Numbers and sizes (dbh) of snags used and selected by secondary cavity-nesters 

often exceed those of primary cavity excavators. 

Consideration: See response to Comment 4-35.

4-41 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

8. the fact that snags should be retained in clumps AND dispersed to meet various 

species needs and ecological functions. 

Consideration: See response to Comment 4-35. Snag variability is discussed in 

response to Comment 4-21.

4-42 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

9. non-equilibrium conditions are ignored, i.e. some species rely on the natural 

large pulses of snags associated with large disturbances which are too often 

salvaged; 

Consideration: See response to Comment 4-35. Currently, the Deschutes National 

Forest and surrounding areas currently have large pulses of snags which have not been 

salvaged. 

4-43 The traditional snag habitat model used by the agency is based on outdated science 

which vastly overestimates habitat capability for snag-dependent species because it fails 

to consider important factors such as: ... 

10. federal managers attempting to maintain viable populations of native cavitydwellers need to consider generally degraded snag habitat conditions in heavily 

roaded areas and on adjacent and nearby non-federal lands. 

Consideration: See Response to Comment 4-35. Existing condition for both Federal and 

private lands is disclosed in the analysis.

4-44 The agency’s analysis of snag retention and habitat for cavity dependent species is faulty 

at both a programmatic level and at a project level. The agency must defer any decision 

on this project until it reviews all the available new information and amends its 

management plan standards to provide adequate snags for wildlife and all other 

ecosystem functions. 

Consideration: The BLT Project meets or exceeds standards given in the amended 
BLT Project Environmental Impact Statement 

Appendix C 

454

Deschutes National Forest Land and Resource Management Plan by following the 

Deschutes National Forest Wildlife Tree and Log Implementation Strategy (USDA 

1994). All existing snags would remain except where snags must be felled for temporary 

and Maintenance Level 1 roads, log landings, or occupational safety (DEIS, page 33). 

4-45 The DEIS p 143 includes unsupported assertions that logging is beneficial to goshawks. 

A recent review of the most accurate information on goshawk habitat selection confirms 

that goshawks select late successional forest structure (e.g. high canopy closure, large 

tree for forest type, canopy layering, abundant course woody debris). This review 

continues to support Reynolds’ 1992 recommendations to manage nest core areas and 

post-fledging areas for late successional forest characteristics. 

This review also does not find support for a few of the assumptions underlying Reynolds’ 

1992 management recommendations. ......This comprehensive review of telemetry 

studies does not find support for the hypothesis that thinning improves goshawk foraging 

habitat. Absent clear scientific support, the agency should clearly label the statement as 

an unsupported hypothesis. 

[Greenwald, Crocker-Bedford, Broberg, Suckling, and Tibbitts. 2005. A review of 

Northern goshawk habitat selection in the home range and implications for forest 

management in the western United States. Wildlife Society Bulletin 33(1):120-129.] 

This is the review that the respondent is referring to in this comment. 

Consideration: The Greenwald et al. 2005 document was reviewed by the project 

wildlife biologist. This document reviewed the most current research on goshawk 

telemetry studies and reached some of the same conclusions of Reynolds 1992 

recommendations on managing habitats for goshawks. However, the Greenwald et al. 

review also did not find support for a few of the assumptions underlying Reynolds 

management recommendations. The Greenwald et al. review stated that most but not all 

of the studies cited showed that goshawks tend to select stands for foraging that are 

similar to those used for nesting. A contrary view in Bloxton (2002) in a western 

Washington study of managed forests confirmed goshawk prey captures in forested 

stands ranging from 13 year-old regeneration units to 200 year-old complex, old-growth 

forests. He also determined that goshawks hunted in all forest types and successional 

stages except for recent clearcuts and shrub/sapling stages though they tended to hunt in 

stands (greater than 30 years old) with larger diameter trees and avoided areas composed 

primarily of small trees (sapling/pole). Bloxton (2002) also stated that goshawk used 

areas containing high densities of small trees less than expected based on availability and 

used areas composed of fewer, but larger, trees more than expected based on availability 

and that goshawks may benefit if young stands in managed forests were thinned. 

Greenwald’s et al. review would suggest that thinning forested stands could enhance the 

quality of goshawk foraging habitat is inconclusive at this time. In light of this recent 

paper, the FEIS will reflect this information. The remaining disclosure of effects to the 

goshawk, including the number of acres of nesting habitat affected and the return interval 

of actively-managed stands to functioning nesting habitat is unchanged.

5-1 Chapter 3, Wildlife, Threatened, Endangered, and Sensitive Species, page 180

The USGS (2003) reference cited in the section on the Oregon Spotted Frog (Rana 

pretiosa) R6 Sensitive, Federal Candidate Species, is not included in the Literature Cited 

Chapter. 

Consideration: This technical edit has been addressed and corrected.

5-2 Chapter 4, Literature Cited 
Environmental Impact Statement BLT Project

 Appendix C 

455

USDI (2002) (page 371) is incorrectly cited and also has been updated. The reference 

should be listed in the Literature Cited chapter as provided below as well as cited in 

pertinent sections of the DEIS (e.g. page 164). 

USGS (U.S. Geological Survey). 2005. Ospreys in Oregon and the Pacific Northwest. 

USGS Forest and Rangeland. Ecosystem Science Center. USGS Fact Sheet 153-02, 

Revised September 2005. http://fresc.usgs.gov/products/fs/fs-153-02.pdf

Consideration: This technical edit has been addressed and corrected.

5-3 The Internet link to the Sauer et al (1996) on page 368 needs to be updated. The correct 

link is http://www.mbr-pwrc.usgs.gov/bbs/bbs.htm. 

Also, note that a more recent report (see below) is available and it is suggested that any 

additional information be incorporated into the assessments in the FEIS. 

Sauer, J. R., J. E. Hines, and J. Fallon. 2008. The North American Breeding Bird Survey, 

Results and Analysis 1966 - 2007. Version 5.15.2008.U.S. Geological Survey Patuxent 

Wildlife Research Center, Laurel, MD. 

Consideration: The updated information will be incorporated into the FEIS.

6-1 EPA has assigned a rating of “EC-2” (Environmental Concerns – Insufficient 

Information) to the Draft EIS due to concerns about potential impacts to air and water 

quality. We recommend that additional information be included in the Final EIS 

regarding air quality impacts and emissions resulting from prescribed fire treatments. 

Consideration: The Forest Service will include the suggested additional disclosure on 

air quality in the FEIS.

6-2 We recommend that the Final EIS disclose the ambient air quality data, atmospheric 

information, and other parameters and assumptions used in the FOFEM that generated 

the fire emission results for each alternative. The Final EIS should identify the location 

of the nearest ambient air quality monitoring stations within or outside the BLT project 

area. If there are no representative monitoring stations available, then additional 

measures should be taken to ensure that a representative monitoring program is in place 

prior to initiating prescribed fire treatments. The Final EIS should include information 

that demonstrates monitors are approved for measuring NAAQS , can measure 

particulate matter in real time, and that sufficient background monitoring is performed 

to accurately predict if a prescribed treatment would not exceed the NAAQS. If the 

monitoring results indicate that NAAQS would be exceeded, then fire treatments should 

be postponed. 

Consideration: The FOFEM parameters used for the analysis were for moist, spring 

conditions coupled with site-specific fuel loading by size class and vegetative series 

using the Pacific Northwest Research Station Photo Series 52 and 105. 

The location of the nearest ambient air quality monitoring station is in Bend, Oregon, 

approximately 47 miles north of the BLT project area. The Forest Service voluntarily 

follows the guidelines assigned by Oregon Smoke Management to limit state-wide 

exposure on a cumulative basis, in compliance with the Clean Air Act. The State of 

Oregon monitors the cumulative effects of a certain airshed and then assigns how much 

the Forest Service and other stakeholders can burn on a particular day given the 

environmental parameters (as specified by the Sate of Oregon Smoke Management 

Plan). National Ambient Air Quality Standards are a critical component of the State of 

Oregon Smoke Management Plan. 

6-3 The Final EIS should discuss how the prescribed fire treatments would meet the visibility 
BLT Project Environmental Impact Statement 

Appendix C 

456

requirements of the Class I areas of the Diamond Peak Wilderness. Mitigation measures 

should be included to ensure that Class I areas are appropriately protected and is 

consistent with air quality plans. The Final EIS should identify appropriate monitoring 

requirements to ensure that visual impacts are minimized. 

Consideration: Page 36 of the DEIS includes measures to protect the Class 1 airshed. 

The objective is to minimize human-caused visual impacts to the Class 1 airshed 

(Diamond Peak Wilderness and Maiden Peak Inventoried Roadless Area). Prescribed 

burning operations would be restricted during the period of July 1- September 30. 

Outside of this timeframe, the Forest Service follows the attainment levels assigned by 

the State of Oregon for a particular day given a set of predicted environmental 

parameters. Both the Sate of Oregon and the Forest Service monitor the Class 1 airshed, 

and prescribe burn operations to dissipate smoke away (i.e. burn during forecasted 

westerly winds). 

6-4 We recommend that if chemical treatments are being considered for use as treatments, 

then the FEIS should identify what chemicals would be used and analyze the direct, 

indirect and cumulative effects to public health and wildlife. In particular, the EIS 

should disclose the potential acute and chronic impacts these chemicals may pose. The 

Final EIS should include requirements for the development of monitoring plans to assess 

the acute and chronic chemical treatment impacts from the management activities. 

Consideration: There are no chemical treatments being proposed for the BLT Project.

6-5 We recommend that the Final EIS include a discussion of the potential health effects 

resulting from the prescribed fire treatments and other vegetation management 

activities. A screening process should be conducted to determine which aspects of human 

health could be impacted. The USFS should partner with local, state, and federal health 

departments to conduct the appropriate analysis, and to determine appropriate and 

effective mitigation measures to address potential adverse health impacts. 

Consideration: Potential health effects are disclosed on page 332 of the DEIS. All 

personnel involved in fire and fuels management activities get their health regularly 

screened with a health care provider. In addition, every five years there is a required 

personal health baseline set. Employees are monitored for smoke exposure as a product 

of the site-specific Burn Plan and rotated in and out of the smoke. 

6-6 We recommend that the Final EIS describe the approximate dimensions (width and 

height) of the temporary roads, and the type, number, size and location of culverts along 

the roadbed. Best Management Practices (BMPs) should be implemented during road 

construction and operation to control erosion and sedimentation and down slope 

impacts. The Final EIS should also discuss how temporary forest roads would be 

obliterated, culverts removed, and the area restored to a hydrologically functional 

condition. The Final EIS should include a commitment to field monitor the temporary 

roads during construction, operation, and road closure to ensure the BMPs are effective. 

Corrective actions should be taken in the event of road failures and excessive erosion 

and sedimentation. The ROD should include a commitment to develop a road design and 

construction plan and a road closure plan. 

Consideration: Temporary roads, the effects associated with those roads, and how they 

are returned to a hydrologic condition is disclosed on page 321 of the DEIS in the 

Transportation section. Best Management Practices will be implemented as part of the 

timber sale contract. Those are listed on page 391. Monitoring of those roads occurs 

through timber sale contract provisions, routine inspections with field personnel during 

other routine operations, and through the local Transportation Engineer assigned to the 
Environmental Impact Statement BLT Project

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457

Crescent Ranger District. Needed corrective actions on the Deschutes National Forest 

are considered a very rare condition due to gentle terrain and porous soils which reduces 

this risk considerably (ACS, page 267, DEIS).