School Fire Salvage 

Recovery Project 

Final Supplemental Environmental Impact 

Statement 

Pomeroy Ranger District, Umatilla National Forest 

Columbia and Garfield Counties, Washington 

 United States 

 Department of 

 Agriculture

 Forest 

 Service

 May 2007 
The United States Department of Agriculture (USDA) prohibits discrimination in all its programs and

activities on the basis of race, color, national origin, age, disability, and where applicable, sex marital

status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs,

reprisal, or because all of part of an individual’s income is derived from any public assistance program, 

(Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means 

of 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 to

USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-

9410, or call (800) 795-3272 (voice) or (202) 720 –6382 (TDD). USDA is an equal opportunity provider

and employer. 

Publication Number F14-POM-02-07
School Fire Salvage Recovery Project 

Final Supplemental Environmental Impact Statement 

Columbia and Garfield Counties, Washington 

Lead Agency: USDA Forest Service 

Responsible Official: Kevin D. Martin, Forest Supervisor 

 Umatilla National Forest 

 2517 S.W. Hailey Avenue 

 Pendleton, Oregon 97801

For Information Contact: Dean R. Millett, Project Leader 

 Pomeroy Ranger District

 71 W. Main Street 

 Pomeroy, Washington 99347 

 (509) 843-1891 

Abstract: The USDA Forest Service is proposing to amend the Umatilla National Forest Land and 

Resource Management Plan (Forest Plan) to address a recent opinion of the 9th Circuit Court of Appeals 

(Appeals Court) concerning the School Fire Salvage Recovery Project (the Project). 

On February 12, 2007 the Court issued an opinion that the Project was inconsistent with the Forest Plan 

(Eastside Screens) by inappropriately implementing the "prohibition on logging of any “live tree" > 21 

inches diameter at breast height (dbh) that currently exists in the sales areas – i.e., any tree of the requisite 

size that is not yet dead." The Appeals Court went on to conclude that the agency could not harvest 

“dying” trees because they were not dead. The Appeals Court recognized that the Forest Service could 

correct this situation by amending the Forest Plan to include a definition of the term “live tree.” On 

February 15, 2007 the Eastern District Court of Washington (District Court) issued an injunction 

requiring that “the Forest Service shall not harvest from the three timber sales areas any “live tree" > 21 

inches dbh. This includes any tree of requisite size with green needles or that is not yet dead." The 

proposed action addressed in this Final Supplemental Environmental Impact Statement (FSEIS) clarifies 

the agency's definitions of live and dead trees. 

Two alternatives, including the No Action alternative, are analyzed in the FSEIS. Alternative A is the No 

Action alternative. It would be implemented as enjoined by the Appeals Court, and would exclude further 

harvest of any "live trees" > 21 inches dbh, including any tree of requisite size with green needles or that 

is not yet dead. Alternative B, the proposed action and preferred alternative, would amend the Forest Plan 

to modify the Eastside Screens to include definitions of live and dead trees. The amendment applies to, 

and only for the duration of, the Project. 

Emergency Situation Determination: 

The Forest Supervisor will seek a determination from the Chief of the Forest Service that an emergency

situation exists in the Project area pursuant to 36 CFR 215.10 (b). This emergency situation exists 

because substantial loss of economic value to the Federal Government would occur if implementation of 

the decision were delayed. The final determination by the Chief will be published in the legal notice of 

the decision, 36 CFR 215.10 (d), that the Forest Service made a determination that all or part of a project 

decision is an emergency situation.
Table of Contents

Title Page

Table of Contents.....................................................................................................................................i 

Summary................................................................................................................................. S-1 

Chapter 1– Purpose and Need

Changes Between Draft SEIS and Final SEIS.................................................................................... 1-1 

Introduction......................................................................................................................................... 1-1 

Background......................................................................................................................................... 1-2 

Purpose and Need for Action ............................................................................................................. 1-3 

Proposed Action.................................................................................................................................. 1-3 

Decision Framework........................................................................................................................... 1-4 

Chapter 2 - Alternatives 

Changes Between Draft SEIS and Final SEIS.................................................................................... 2-1 

Alternatives Considered in Detail....................................................................................................... 2-1 

Alternatives Considered but Eliminated from Detailed Study............................................................ 2-2 

Comparison of Alternatives................................................................................................................ 2-6 

Chapter 3 – Affected Environment and Environmental Consequences 

Changes Between Draft SEIS and Final SEIS.................................................................................... 3-1 

Introduction......................................................................................................................................... 3-1 

Affected Environment......................................................................................................................... 3-1 

Environmental Consequences............................................................................................................. 3-2 

Literature Citations..........................................................................................................................L-1 

Index ...................................................................................................................................................I-1 

Appendices 

Appendix B – Implementation and Marking Guides..........................................................................B-1 

Appendix M – Forest Service Response to Comments......................................................................M-1 

Appendix N –Eastside Screens - Appendix B .................................................................................. N-1

i 
Summary 

SUMMARY 

INTRODUCTION 

The Forest Service has prepared this Final Supplemental Environmental Impact Statement (FSEIS) in 

response to a recent opinion of the 9th Circuit Court of Appeals (Appeals Court) concerning the School 

Fire Salvage Recovery Project (the Project). The Final Environmental Impact Statement (FEIS) for the 

Project was issued July 2006 and a Record of Decision (ROD) signed August 14, 2006, which authorized 

about 9,430 acres of salvage harvest. Also in August 2006, three timber sales (Milly, Oli, and Sun) were 

awarded covering about 4,200 acres with an estimated volume of 28 million board feet (MMBF). 

On February 12, 2007 the Appeals Court issued an opinion that the Project was inconsistent with the 

Forest Plan (Eastside Screens) by inappropriately implementing the prohibition on logging of any "live 

tree" > 21 inches dbh that currently exists in the sales areas – i.e., any tree of requisite size that is not yet 

dead. The Appeals Court reasoned that in the absence of an adopted technical definition of "live trees," 

the common understanding of the word "live" from the Merriam Webster’s Collegiate Dictionary (10th ed. 

1993) meant "to be alive" which meant "not dead." The Appeals Court went on to conclude that the 

agency could not harvest "dying" trees because they were not dead. The Appeals Court recognized that 

the Forest Service could correct this situation by amending the Forest Plan to include a definition of the 

term "live trees." 

On February 15, 2007 the Eastern District Court of Washington (District Court) issued an injunction 

requiring that "the Forest Service shall not harvest from the three timber sales any "live tree" > 21 inches 

dbh. This includes any tree of requisite size with green needles or that is not yet dead." The proposed 

action addressed in this FSEIS clarifies the agency definitions of live and dead trees. 

PURPOSE AND NEED FOR ACTION 

As stated in the Project FEIS on page 1-4 of the Purpose and Need, “there is a need to salvage harvest 

[burned timber] as rapidly as practicable before decay and other wood deterioration occurs to maximize

potential economic benefits.” The Appeals Court opinion and District Court injunction described in the 

Introduction above, prohibits salvage harvest of any "live tree" greater than or equal to 21 inches dbh for 

the Project. The Appeals Court definition of a "live tree," which does not reflect Forest Service 

silvicultural practice and interpretation, frustrates the ability of the Forest Service to achieve the purpose 

and need of the Project stated above. 

PROPOSED ACTION 

The Forest Service proposes to amend the Umatilla National Forest Land and Resource Management Plan 

to modify Eastside Screens wildlife standard at 6d. (2) (a) to define both live and dead trees. The 

amendment narrative is based on information disclosed in the FEIS, Appendix B1

, (Implementation and 

Marking Guides) and Appendix K (Response to Beschta and Others). Appendix B and K are appended to 

this DSEIS. This amendment applies to, and only for the duration of, the School Fire Salvage Recovery

Project. 

 1

 Appendix B, predicting tree survival scoring guide was modified to be consistent with the August 30, 2006

amendment to the Scott Guidelines. 

S-1 
Summary 

Existing Eastside Screen wildlife standard at 6d. (2) (a) reads: Maintain all remnant late and old seral 

and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest activities.

Amended Eastside Screen wildlife standard at 6d. (2) (a) would read: Maintain all remnant late and old 

seral and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest 

activities. Live trees are defined as trees rated to have a high probability of surviving the effects of fire, 

and trees rated to have a moderate probability of survival where sampling indicates that at least 50 

percent of their basal cambium is alive. Dead trees are defined as trees rated to have a low probability of 

surviving the effects of fire, and trees rated to have a moderate probability of survival where sampling 

indicates that more than 50 percent of their basal cambium is dead. Survival probability is determined 

using “Factors Affecting Survival of Fire Injured Trees: A Rating System for Determining Relative 

Probability of Survival of Conifers in the Blue and Wallowa Mountains” (Scott et al. 2002, as amended) 

(commonly referred to as the Scott Guidelines). 

ALTERNATIVES 

The FSEIS considered eleven alternatives, two were analyzed in detail (the no action and proposed 

action), and nine were considered but eliminated from detailed study for reasons stated in Chapter 2 of 

this document. 

Alternative A – No Action 

In this document the no action alternative means the August 14, 2006 decision (Alternative B as described 

in the Project FEIS) would be implemented with actual harvest limited to those trees not enjoined by the 

District Court of the Eastern District of Washington. Specifically "no harvest of "live trees " ≥ 21 inches 

dbh including any tree of requisite size with green needles or that is not yet dead." All other activities 

could proceed as disclosed previously. 

Alternative B – Proposed Action (Preferred Alternative) 

The Forest Service proposes to amend the Forest Plan to modify the Eastside Screens wildlife standard at 

6d. (2) (a) as stated above in the Proposed Action.

The following table is a comparison of alternatives. 

Table 1 - Summary Comparison of Alternatives 

Activity Unit of Measure Alternative A 

 (No Action) 

Alternative B 

(Proposed Action) 

Amendment to Forest Plan to 

modify Eastside Screens 

Wildlife Standard 6d. (2) (a) to

include definition of "live" and

"dead" trees 

Yes/No No Yes

Milly Oli and Sun sales MMBF 11* 13*

(Round-One)

Remaining to be Harvested Acres 1,800 1,800

Round-Two MMBF 12* 15*

Remaining to be harvested Acres 5,200 5,200

*Volume figures express actual volumes realized and experienced deterioration, and therefore, differ from the FEIS

S-2 
Chapter 1- Purpose and Need

Chapter 1 

Purpose and Need 

CHANGES BETWEEN DRAFT SEIS AND FINAL SEIS

• This FSEIS only contains discussion of information that is new or different. 

• Other sections of the July 2006 FEIS are unchanged 

• Minor editorial changes to text in all sections of the chapter. 

INTRODUCTION 

The Forest Service has prepared this Final Supplemental Environmental Impact Statement (FSEIS) in 

response to a recent opinion of the 9th Circuit Court of Appeals (Appeals Court) concerning the School 

Fire Salvage Recovery Project (the Project). The Final Environmental Impact Statement (FEIS) for the 

Project was issued July 2006 and a ROD signed August 14, 2006, which authorized about 9,430 acres of 

salvage harvest. Also in August, three timber sales (Millly, Oli and Sun) were awarded covering about 

3,670 acres with an estimated volume of 28 million board feet (MMBF). 

On August 15, 2006, the Lands Council, Oregon Natural Resources Council, Hells Canyon Preservation 

Council, and Sierra Club (plaintiffs) filed suit against Forest Supervisor Kevin Martin and the Forest 

Service in The Lands Council et al. v. Martin et al., Civ. No. 06-229, District Court of the Eastern District 

of Washington, challenging the Project. Plaintiffs alleged the Forest Service failed to adequately analyze 

impacts to certain undeveloped areas, failed to consider a reasonable range of alternatives, failed to 

comply with the Eastside Screens to protect old-growth trees, failed to adequately consider the scientific 

controversy regarding “Factors Affecting Survival of Fire-Injured Trees” (Scott et al. 2002, 2006), and 

failed to adequately analyze cumulative environmental impacts. Timber sale purchasers, Boise Building 

Solutions Manufacturing, LLC and Dodge Logging, Inc., along with American Forest Resource Council 

joined the lawsuit as Defendant-Interveners. 

On September 11, 2006, the District Court denied plaintiffs’ request for a temporary restraining order and 

preliminary injunction, finding that the Forest Service had not failed in its duty to take the requisite "hard 

look" at the environmental consequences. Thereafter, the three awarded salvage timber sales began 

operations. On September 15, the District Court denied plaintiffs’ request for stay and on September 18, 

the Appeals Court denied plaintiffs’ request for an injunction pending appeal. 

On February 5, 2007, the Appeals Court heard oral argument on the District Court’s denial of the 

preliminary injunction. The Appeals Court issued an opinion on February 12, 2007, that the Forest 

Service had adequately disclosed the impacts to the unroaded areas, but that the Forest Service violated 

the Forest Plan (Eastside Screens) prohibition of cutting "live trees" > 21 inches dbh when it designated 

dying trees for harvest. The intent of the Eastside Screens interim management direction was to restrict 

timber harvest in those areas that scientific analysis indicated were important to certain fish, wildlife, and 

ecosystem structure. 

1-1 
Chapter 1- Purpose and Need

The Appeals Court reasoned that in the absence of an adopted technical definition of "live trees," the 

common understanding of the word "live" from the Merriam Webster’s Collegiate Dictionary (10th ed. 

1993) meant "to be alive," which meant "not dead," and concluded "the common meaning of the term ‘all 

. . . live trees’ is all trees that have not yet died." Opinion at 12. Thus, according to the Appeals Court, 

dying trees designated for harvest were not yet dead, and remained "live" for the purposes of the Eastside 

Screens. The Appeals Court further opined that "[t]he Forest Service is free, of course, to amend the 

Eastside Screens to allow logging of old-growth dying trees, either by adding a definition of the term

"live trees" or by changing the requirement to maintain all live trees of a certain size." Opinion at 14. 

The Appeals Court remanded the case to the District Court to issue an injunction consistent with its 

findings. The District Court issued an injunction on February 15, 2007, requiring that "The Forest 

Service shall not harvest from the three timber sales areas any "live tree" > 21 inches dbh." This includes 

any tree of requisite size with green needles or that is not yet dead.” District Court Order at 2. The 

Appeals Court definition of a "live tree" does not reflect Forest Service silvicultural practice and 

interpretation, and it frustrates the ability of the Forest Service from achieving the purpose and need of the 

Project. 

This plan amendment is being proposed under the National Forest Management Act (NFMA) 

implementing regulations in effect prior to November 9, 2000. The 2000 NFMA implementing 

regulations (36 CFR 219.14 (d) (2)) as amended by the September 29, 2004 Interpretative Rule (Federal 

Register Vol. 69, No. 188) allow use of these procedures. Specific procedures for amending plans under 

the regulations in effect prior to November 9, 2000 are found in Forest Service Manual (FSM) 1926.5. 

Non-significant plan amendments may be made as a part of a project proposal, as is the case here. A plan 

amendment can be found to be non-significant if the amendment involves: 

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term land and 

resource management. 

2. Adjustments of management area boundaries or management prescriptions resulting from further 

on-site analysis when the adjustments do not cause significant changes in the multiple-use goals 

and objectives for long-term land and resource management. 

3. Minor changes in standards and guidelines. 

BACKGROUND 

Tree mortality is a complex biological process. Common measures of animal mortality are not useful for 

trees; tree death is not signified by cessation of a heartbeat, for example. In fact, a tree’s “heart” can rot 

and yet the tree might remain alive for decades or even centuries (Schmitt and Filip 2005). 

Trees die when they cannot acquire or transport sufficient resources (water, mineral nutrients, etc.) to 

recover from attack by insects and pathogens, or from injuries caused by environmental stress, wildfire, 

and other disturbance agents (Waring 1987). 

A wildfire typically creates a relatively broad spectrum of tree injuries. When fire injuries are acute, trees 

die almost immediately; when injuries are moderate, delayed mortality may occur over a period of several 

years; and when injuries are minor, trees may appear to be unaffected or uninjured by the fire.

Acute fire injuries cause obviously dead trees with blackened stems and a complete absence of needles, or 

trees with crowns having all brown needles, or trees with crowns having "fading" or "dry-appearing" (offcolor) needles throughout the crown. 

1-2 
Chapter 1- Purpose and Need

Moderate fire injuries result in a relatively broad array of tree response. Experience indicates that about 

half of the trees with moderate injuries will survive, and about half of them will die (Scott et al. 2002). 

Unlike monitoring human physiology with measures such as pulse rate and blood pressure, there is no 

definitive measure for determining near-term mortality (up to five years) for moderately injured trees. 

Because a definitive measure of delayed tree mortality does not exist, the traditional approach to post-fire 

assessment is to evaluate direct (first-order) fire effects to predict a tree’s survival probability. This 

traditional approach has a long historical precedence in the western United States dating back to the 1920s 

and 1930s (Flint 1925, Miller and Patterson 1927, Salman 1934, Starker 1934, Connaughton 1936, 

Herman 1954, Lynch 1959, Mann and Gunter 1960, Wagener 1961, Martin 1963, and Dieterich 1979). 

PURPOSE AND NEED FOR ACTION 

As stated in the Project FEIS on page 1-4 of the Purpose and Need, "there is a need to salvage harvest 

[burned timber] as rapidly as practicable before decay and other wood deterioration occurs to maximize

potential economic benefits." The Appeals Court opinion and District Court injunction described in the 

Introduction above "prohibits salvage harvest from the three timber sales areas of any "live tree" greater 

than or equal to 21 inches dbh. This includes any tree of requisite size with green needles or that is not 

yet dead." The Appeals Court definition of a "live tree," which does not reflect Forest Service 

silvicultural practice and interpretation, frustrates the ability of the Forest Service to achieve the purpose 

and need of the Project as stated above. 

PROPOSED ACTION 

The Forest Service proposes to amend the Forest Plan to modify Eastside Screens wildlife standard at 6d. 

(2) (a) to define both live and dead trees. The amendment narrative is based on information disclosed in 

the Project FEIS, Appendix B2

 (Implementation and Marking Guides), and Appendix K (Response to 

Beschta and Others). Appendix N (Appendix B, revised, of the environmental assessment for Interim

Management Direction Establishing Riparian, Ecosystem, and Wildlife Standards for Timber Sales, 

commonly referred to as the Eastside Screens), and Appendix B and K of the Project FEIS are appended 

to this FSEIS. This amendment applies to, and only for the duration of, the Project. 

Existing Eastside Screen wildlife standard at 6d. (2) (a) reads: Maintain all remnant late and old seral 

and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest activities. 

Amended Eastside Screen wildlife standard at 6d. (2) (a) would read: Maintain all remnant late and old 

seral and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest 

activities. Live trees are defined as trees rated to have a high probability of surviving the effects of fire, 

and trees rated to have a moderate probability of survival where sampling indicates that at least 50 

percent of their basal cambium is alive. Dead trees are defined as trees rated to have a low probability of 

surviving the effects of fire, and trees rated to have a moderate probability of survival where sampling 

indicates that more than 50 percent of their basal cambium is dead. Survival probability is determined 

using “Factors Affecting Survival of Fire Injured Trees: A Rating System for Determining Relative 

 2

 Appendix B, predicting tree survival scoring guide was modified to be consistent with the August 30, 2006

amendment to the Scott Guidelines. 

1-3 
Chapter 1- Purpose and Need

Probability of Survival of Conifers in the Blue and Wallowa Mountains” (Scott et al. 2002, as amended) 

(commonly referred to as the Scott Guidelines). 

DECISION FRAMEWORK 

The scope of the decision to be made is limited to the Forest Plan amendment to the Eastside Screens 

wildlife standard 6d. (2) (a) within the Project area. The Responsible Official for this proposal is the 

Forest Supervisor of Umatilla National Forest. The decision will be based on a consideration of public 

comments, responsiveness to the purpose and need, and a comparison of impacts disclosed by alternative. 

1-4 
Chapter 2 - Alternatives 

Chapter 2 

Alternatives 

CHANGES BETWEEN DRAFT SEIS AND FINAL SEIS

• This FSEIS only contains discussion of information that is new or different. 

• Other sections of the July 2006 FEIS are unchanged 

• Minor editorial changes to text in all sections of the chapter. 

• In response to comments made on the DSEIS additional alternatives were considered, but eliminated 

from detailed study.

ALTERNATIVES CONSIDERED IN DETAIL 

Alternative A – No Action 

In this document the no action alternative means the August 14, 2006 ROD (Alternative B selected as 

described in the Project FEIS) would be implemented as enjoined by the District Court of the Eastern 

District of Washington (District Court). Specifically, the no action alternative excludes further harvest of 

any "live trees" ≥ 21 inches dbh, including any tree of requisite size with green needles or that is not yet 

dead. All other activities would proceed as disclosed previously. 

Alternative B – Proposed Action (Preferred Alternative) 

The Forest Service proposes to amend the Forest Plan to modify Eastside Screens wildlife standard at 6d. 

(2) (a) to define both live and dead trees. The amendment narrative is based on information disclosed in 

the Project FEIS, Appendix B3

 (Implementation and Marking Guides) and Appendix K (Response to 

Beschta and Others). Appendix N (Appendix B, revised, of the environmental assessment for Interim

Management Direction Establishing Riparian, Ecosystem, and Wildlife Standards for Timber Sales, 

commonly referred to as the Eastside Screens), and Appendix B and K of the Project FEIS are appended 

to this FSEIS. This amendment applies to, and only for the duration of, the Project. 

Existing Eastside Screens wildlife standard at 6d. (2) (a) reads: Maintain all remnant late and old seral 

and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest activities. 

Amended Eastside Screens wildlife standard at 6d. (2) (a) would read: Maintain all remnant late and old 

seral and/or structural live trees ≥ 21′′ dbh that currently exist within stands proposed for harvest 

activities. Live trees are defined as trees rated to have a high probability of surviving the effects of fire, 

and trees rated to have a moderate probability of survival where sampling indicates that at least 50 

percent of their basal cambium is alive. Dead trees are defined as trees rated to have a low probability of 

surviving the effects of fire, and trees rated to have a moderate probability of survival where sampling 

 3

 Appendix B, predicting tree survival scoring guide was modified to be consistent with the August 30, 2006

amendment to the Scott Guidelines. 

2-1 
Chapter 2 - Alternatives 

indicates that more than 50 percent of their basal cambium is dead. Survival probability is determined 

using “Factors Affecting Survival of Fire Injured Trees: A Rating System for Determining Relative 

Probability of Survival of Conifers in the Blue and Wallowa Mountains” (Scott et al. 2002, as amended) 

(commonly referred to as the Scott Guidelines). 

ALTERNATIVES CONSIDERED, BUT ELIMINATED FROM 

DETAILED STUDY 

Assess Probability of Tree Mortality Using Methods Other Than Scott Guidelines 

Several respondents to the Project commented that our basis for differentiating between dying and living 

trees is either questionable or untenable for scientific and other reasons. Often, these comments 

specifically addressed use of the Scott Guidelines (Scott et al. 2002, 2003) and assert there are other and 

more appropriate methods that would better predict tree mortality for the Project. 

The Scott Guidelines provide a methodology for predicting the relative probability of survival for fireinjured trees growing on a wide variety of site conditions, exposed to varying levels of pre-fire factors 

that can predispose a tree to fire-induced mortality depending upon their severity or magnitude 

(occurrence of dwarf mistletoe, root disease, and bark beetles), and experiencing widely varying levels of 

first-order fire effects to their crowns, stems and roots. The possible combinations of these factors are 

almost limitless, leading inevitably to a decision to develop a prediction system relating site and tree 

factors (explanatory variables) to a probabilistic estimate of tree mortality. 

The Forest Service agrees there are other methods available to predict tree mortality and differentiate 

between dying and living trees. The Project FEIS, Appendix K, compared and evaluated alternative 

methods to the Scott Guidelines that were suggested during public involvement. Additional information 

on these alternative methodologies can be found in Chapter 3 of this document. The Forest Service 

recognizes there will always be uncertainty associated with any probabilistic rating system, because 

accounting for every combination of variables that could potentially result in tree death is not currently

possible. Based on the analysis here and in Chapter 3 the Forest Service believes that the Scott 

Guidelines, which are based on peer-reviewed science, represent the best available science for assessing 

tree mortality in the Project. 

In order for a methodology to be appropriate for this project, it must: 

• Address all of the principal commercial species within the project area (ponderosa pine, Douglasfir, grand fir/white fir, lodgepole pine, Engelmann spruce, and western larch); 

• Be valid for the geographic area of the School Fire Salvage Recovery Project; and 

• Be operationally practical to potentially evaluate hundreds of trees per acre, over thousands of

acres. 

The following alternatives were considered but were not analyzed in detail for the reasons stated below. 

Waring Report One respondent provided a report (prepared by Richard Waring) describing an 

evaluation of the Scott Guidelines for the Easy and High Roberts salvage sales on the Malheur National 

Forest. In this report, Waring concluded that using indirect indicators (such as the “crown and bole 

scorch” factors from the Scott Guidelines) to assess a tree’s predisposition to fire-caused mortality is 

inappropriate, and that direct measurement of a tree’s physiological processes (photosynthesis or 

transpiration) provides a better estimate of survival potential. 

2-2 
Chapter 2 - Alternatives 

Waring’s report contends that measurements of water stress, using either a pressure chamber (Waring and 

Cleary 1967) or by collecting increment cores and then analyzing the sapwood’s relative water content 

(Waring and Running 1978), provides definitive estimates of tree health and survival potential. 

A plant moisture stress measurement can be obtained by using a portable pressurized chamber, as 

described by Waring and Cleary (1967), but this procedure is feasible primarily in a laboratory setting and 

not during the designation (marking) phase of a timber sale. The sapwood water storage article (Waring 

and Running 1978) describes how transpiration and photosynthesis relationships were examined over a 

multi-year period in the laboratory, but it does not provide a procedure or methodology for determining 

tree survivability. 

The Waring Report was not evaluated using the six evaluation criteria (Project FEIS, Appendix K) 

because Waring’s Report is not a tree mortality prediction system, and the criteria were selected for their 

relevance to mortality prediction systems. 

Ryan (2000) studied the effect of varying levels of fire-caused cambium injury on the water relations of 

ponderosa pine. He found that trees in the 100 percent basal-heating class, which experienced cambium

kill over an average of 95 percent of the circumference at their base, had higher midday xylem pressure 

potentials (i.e., less water stress) than non-girdled trees (Ryan 2000). This result was apparently due to 

phloem unloading that created a net water flow to the xylem tissue (Kozlowski 1992). 

It is our judgment that the Waring Report (Waring, No Date) is inappropriate for use with the Project for 

two reasons: 

• Since the Ryan (2000) study shows that mortality of basal-girdled trees can be delayed for more

than two growing seasons after a fire, and because it shows that fire-girdled trees can have a 

positive ("healthy") water status soon after a fire, it refutes Waring’s contention that a one-pointin-time measurement of water stress provides a suitable methodology for differentiating between 

living and dying trees: and 

• As described above, evaluating trees based on water stress or sapwood water content is not a 

practical approach, because of operational considerations and feasibility, for large burned areas 

such as School Fire area. 

The McHugh and Kolb (2003) model was developed using data from three wildfires in northern 

Arizona. It includes one conifer species (ponderosa pine) and it relates predicted tree mortality to two fire 

effects: total crown damage (scorch plus consumption), and bole char severity. It is our judgment that the 

McHugh and Kolb (2003) model is inappropriate for use with the Project for the following reasons: 

• Its geographical scope is limited (northern Arizona), and it pertains to an area far removed from

the School Fire analysis area; 

• It assesses the crown and stem systems only; no direct consideration of fine-root damage or basal 

stem girdling at the root crown (Ryan and Frandsen 1991) is included; 

• Its tree species coverage is limited (ponderosa pine only).

The Peterson and Arbaugh (1986) model was based on tree survival patterns after late-summer 

wildfires in the northern Rocky Mountains. It includes two conifer species (Douglas-fir and lodgepole 

pine) and it relates predicted tree mortality to a wide variety of tree characteristics and fire effects: tree 

diameter, tree height, crown diameter and ratio, bark thickness, scorch height, crown scorch volume, basal 

scorch, bark char, and insect damage. Although the variety of predictive factors included with this model 

2-3 
Chapter 2 - Alternatives 

is impressive, it is our judgment that the Peterson and Arbaugh (1986) model is inappropriate for use with 

the Project for the following reasons: 

• Its geographical scope is limited (northern Rocky Mountains of Montana, northwestern 

Wyoming, and Idaho); 

• It assesses the crown and stem systems only (no direct consideration of the root system); and

• Its tree species coverage is limited (Douglas-fir and lodgepole pine only). 

The Ryan and Reinhardt (1988) model was developed to predict tree mortality following prescribed 

fires in Idaho, Montana, Oregon, and Washington. It includes seven conifer species and it relates 

predicted tree mortality to two factors: bark thickness, and crown volume killed by fire. The authors of 

the Scott Guidelines used the Ryan and Reinhardt (1988) model when developing their rating procedure, 

in addition to other models and criteria that better account for the totality of fire effects (including root 

damage). It is our judgment that the Ryan and Reinhardt (1988) model is inappropriate for use with the 

Project for the following reasons: 

• Its geographical scope is limited because the Oregon data came from the western or northern 

Cascade Mountains, or from the southwestern portion of the state near Medford; 

• It assesses the crown and stem systems only, with no factors relating to root damage; 

• Its tree species coverage is somewhat limited because it does not include grand fir or ponderosa 

pine, two abundant tree species in the School Fire area; and 

• It was developed using prescribed fire data only, and this is believed to limit its potential 

applicability for wildfire situations such as the School Fire. 

The Stephens and Finney (2002) model was developed to predict tree mortality following prescribed 

fire in the southern Sierra Nevada Mountains of California. It includes five conifer species and it relates 

predicted tree mortality to four factors: tree diameter, percent crown volume scorched, forest floor (duff)

consumption, and crown scorch height. It is our judgment that the Stephens and Finney (2002) model is 

inappropriate for use with the Project for the following reasons: 

• Its geographical scope is limited (southern Sierra Nevada Mountains); 

• Its tree species coverage is limited (of the five conifers included in this model, only ponderosa

pine occurs in the School Fire area); and 

• It was developed using prescribed fire data only, and this is believed to limits its potential 

applicability for wildfire situations such as the School Fire. 

The Thies et al. (2006) model was developed to predict tree mortality following prescribed fire in the 

southern Blue Mountains of northeastern Oregon. It includes one tree species (ponderosa pine) and it 

relates predicted tree mortality to five factors: live crown proportion, needle scorch proportion, bud kill 

proportion, basal char severe, and bole scorch proportion. The size class variation for trees included in 

this study is quite limited due to similar stand replicates. Pre-treatment tree diameter at breast-height 

(dbh) for control units averaged 28.4 cm (11.2 inches), and the diameters for trees in the fall and spring 

burning treatments averaged 26.6 cm (10.5 inches) and 27.4 cm (10.8 inches), respectively. This is a very

different range of tree diameters from that found in the Project. The authors of this study also caution 

about extrapolating its results, and using its mathematical models, beyond the geographical area of the 

sampled stands or with tree species other than ponderosa pine, until datasets are produced to validate the 

models for other geographical areas or tree species. It is our judgment that the Thies et al. (2006) model 

is inappropriate for use with the Project for the following reasons: 

2-4 
Chapter 2 - Alternatives 

• Its geographical scope is limited (a specific set of sampled stands in the southern Blue 

Mountains); 

• Its ecological scope is limited (sampled stands are in the ponderosa pine potential vegetation 

series, and only 1.6 percent of the School Fire area is included in this series; see table E-3 in 

the Project FEIS); 

• Its tree species coverage is limited (ponderosa pine only); 

• The tree-size variation included in the model-development dataset (a range of 10.5 to 11.2 

inches average stand diameter across all replicates) is limited when compared with tree-size 

variation encountered in the School Fire area; 

• It assesses the crown and stem systems only (no direct consideration of the root system); and

• It was developed using prescribed fire data only, and this is believed to limits its potential 

applicability for wildfire situations such as the School Fire. 

Treat small-diameter fuels - This alternative was proposed by the public and would treat small-diameter 

fuel now and while delaying treatment of other fuels until they exceed desired levels. It is suggested that 

this approach would provide an interim recovery period and decrease the impacts of the proposed project. 

This alternative is outside the scope of the purpose and need to salvage harvest (burned timber) as rapidly 

as practicable before decay and other wood deterioration occurs to maximize potential economic benefits. 

Nor does it clarify the Appeals Court definition of live trees which frustrates the ability of the Forest 

Service to achieve the stated purpose and need. An alternative similar to this was considered in the 

Project FEIS (Chapter 2, p. 2-28). 

Non-Commercial Restoration Only - This alternative was proposed by the public and would focus on 

the removal of small-diameter flash fuels, the restoration of area soil, and the removal of unneeded roads 

and old logging roads. It is suggested that it would provide local jobs and reduce fuel loads by removing 

the small-diameter flash fuels. This alternative is outside the scope of the purpose and need to salvage 

harvest (burned timber) as rapidly as practicable before decay and other wood deterioration occurs to 

maximize potential economic benefits. Nor does it clarify the Appeals Court definition of live trees 

which frustrates the ability of the Forest Service to achieve the stated purpose and need. An alternative 

similar to this one was considered in the Project FEIS (Chapter 2, p. 2-27). 

Protect Old Growth - The public proposed several variations on ways to modify the Eastside Screens to 

protect old growth. One suggestion was to protect trees 21 inches or greater. This suggestion is

essentially the no action alternative (Alternative A) as analyzed in this document. 

Other suggestions were to modify the Eastside Screens and reduce the diameter limit from 21 to 19 or 20 

inches. The Eastside Screens (see Appendix N) define old growth (LOS) to be dominated by trees of 21 

inches diameter or greater. The Appeals Court did not dispute this tree-size criteria, so alternate tree-size 

limits are not consistent with the purpose and need to salvage harvest (burned timber) as rapidly as 

practicable before decay and other wood deterioration occurs to maximize potential economic benefits. 

Nor does it clarify the Appeals Court definition of live trees which frustrates the ability of the Forest 

Service to achieve the stated purpose and need. 

Another suggestion was to protect old growth, except for particular circumstances where a tree has a very

high likelihood of dying in the near future (1 or 2 years after fire) based on a commonly accepted 

scientific method. This alternative would be similar to the alternatives using methods other than Scott 

Guidelines. 

2-5 
Chapter 2 - Alternatives 

COMPARISON OF ALTERNATIVES 

The following table shows a comparison of alternatives. 

Table 1 - Summary Comparison of Alternatives 

Activity Unit of Measure Alternative A 

 (No Action) 

Alternative B 

(Proposed Action) 

Amendment to Forest Plan to 

modify Eastside Screens 

Wildlife Standard 6d. (2) (a) to

include definition of "live" and

"dead" trees 

Yes/No No Yes

Milly Oli and Sun sales MMBF 11* 13*

(Round-One)

Remaining to be Harvested Acres 1,800 1,800

Round-Two MMBF 12* 15*

Remaining to be harvested Acres 5,200 5,200

*Volume figures express actual volumes realized and experienced deterioration, and therefore, differ from the FEIS

2-6 
Chapter 3 – Affected Environment and Environmental Consequences 

Chapter 3 

Affected Environment 

and 

Environmental Consequences 

CHANGES BETWEEN DRAFT SEIS AND FINAL SEIS

• This FSEIS only contains discussion of information that is new or different. 

• Other sections of the July 2006 FEIS are unchanged 

• Minor editorial changes to text in all sections of the chapter. 

• Appendix K of the DSEIS and additional information has been incorporated into the Environmental 

Consequences section. 

INTRODUCTION 

The Forest Service has prepared this Final Supplemental Environmental Impact Statement (FSEIS) in 

response to a recent opinion of the 9th Circuit Court of Appeals (Appeals Court) concerning the School 

Fire Salvage Recovery Project (the Project). The physical, biological, social, and economic effects of the 

Project were fully disclosed in the July 2006 Final Environmental Impact Statement (FEIS) and are not 

repeated here except as they are affected by the Appeals Court opinion. 

AFFECTED ENVIRONMENT 

School Fire burned approximately 51,000 acres in August 2005, about 28,000 acres of which were on 

National Forest System land administered by the Umatilla National Forest. Tree mortality varied from

completely dead (total needle consumption) to underburned areas where delayed individual tree mortality

is expected. The FEIS for the Project was issued July 2006 and a ROD signed August 14, 2006, which 

authorized about 9,400 acres of salvage harvest. Based on initial field reconnaissance, timber industry

capability, and expected deterioration rates, the Umatilla National Forest decided to implement salvage 

operations in two steps. 

Shortly after the August 14, 2006 decision, three timber sales were awarded covering about 4,200 acres 

with an estimated volume of 28 million board feet (MMBF). This first round of salvage harvest consisted 

of three sales (Milly, Oli, and Sun) of the most severely burned areas (the majority of trees were dead or 

expected to die). When the three sales were enjoined on February 15, 2007 approximately 16 MMBF 

from 2,400 acres had been salvage harvested. There is an estimated 13 MMBF of volume within the 

remaining 1,800 acres left to be harvested. Of that volume, approximately 2 MMBF consists of trees that 

meet the definition of "live" as defined in the opinion of the Appeals Court. 

3-1 
Chapter 3 – Affected Environment and Environmental Consequences 

The second round of salvage harvest under the August 14, 2006 decision has not been sold, however, 

salvage harvest was intended to occur on these remaining 5,200 acres for an estimated 15 MMBF 

beginning in the 2007 field season. As of February 15, 2007, an estimated 3 MMBF of volume across 

round-two acres would be potentially affected by the Appeals Court ruling. The second round of sales 

consists of areas with mixed and/or delayed mortality, and may include areas of high mortality. Given 

these conditions, the Forest Service anticipated extensive use of the Scott Guidelines to predict the 

relative probability of tree survival for the round-two salvage timber sales. 

ENVIRONMENTAL CONSEQUENCES

No Action Alternative 

Direct, indirect, and cumulative effects were disclosed for Alternative B in the Project July 2006 FEIS. 

Timber harvest would still occur in the same areas and along the same roads as originally described for 

Alternative Bin the FEIS. Logging systems would remain the same and no new trees would be 

designated for harvest. The size and location of Riparian Habitat Conservations Areas would remain the 

same as would the measures to protect those areas. Seasonal restrictions on operations to minimize 

impacts on big game winter range, soils, and snowmobile uses would remain the same. The only change 

would be the retention of scattered "live" trees > 21 inches dbh including any tree of requisite size with 

green needles or that is not yet dead. 

The addition of > 21 inch dbh fire injured trees retained in these units could have a beneficial effect to 

wildlife. The majority of these > 21 inch dbh fire injured trees are expected to be dead within the next 

five years, contributing additional snags. Although unlikely, some trees may survive and could provide 

green component habitat in the burned forest ecosystem. Snags > 21 inches dbh remain standing longer 

than smaller dbh snags and therefore provide habitat for a variety of species for a longer period of time. 

Where retention of scattered trees > 21 inches dbh occurs, additional dead wood (snag) habitat would be 

created. Effects to woodpeckers from scattered increases in greater than 21 inch dbh dead wood habitat 

may change slightly compared to effects disclosed in the Project FEIS. However, these changes are not 

expected to be measurable across the project area because the harvest prescriptions leave substantial 

numbers of large snags, and it is unknown whether the scattered additional snags would result in any

additional habitat value. Therefore, effects disclosures in the Project FEIS would remain essentially

unchanged. Leaving additional scattered large diameter trees would not contribute significantly to the fire 

hazard. In fact, leaving them would result in the generation of slightly less timber harvest activity fuels 

that would have to be treated to reduce post-harvest fire hazard. There would be no new measurable 

environmental effects for other resources beyond those already identified for Alternative B in the Project 

FEIS. 

For the first round of sales the net effect of not being able to remove the enjoined trees > 21 inches dbh 

would vary among the three sales. Milly sale is 90 percent complete and relies extensively on helicopter 

yarding. The economic effect would be an undetermined reduction in volume and value across the 

remaining acres within the Milly sale area. The Oli and Sun timber sales would be affected by the 

Appeals Court opinion to a greater extent than the Milly timber sale. They are 35 percent and 60 percent 

completed, respectively. Both have a significant portion of unlogged units that were designed to utilize 

skyline and helicopter yarding systems. Skyline yarding falls in the mid-range of yarding cost, while 

helicopter yarding is the most expensive system. Since a larger portion of the volume of these two sales 

remains unharvested, the inability to harvest enjoined trees from these sales would have a greater 

economic effect. The inclusion of larger diameter trees offsets the costs of yarding smaller less valuable 

trees. This is most apparent when higher cost yarding systems like helicopter and skyline are used. 

3-2 
Chapter 3 – Affected Environment and Environmental Consequences 

Inability to harvest enjoined trees could render the majority of the unlogged portions of the Oli and Sun 

sales economically unviable. 

Within the second round of sales about 5,200 acres trees >21 inches dbh that meet the Appeals Court 

definition of live are expected to result in an estimated 3 MMBF. While they only denote 20 percent of 

the anticipated volume, they represent the predominance of the remaining value. Wood deterioration has 

progressed at a faster rate than was initially anticipated in the Project FEIS due to weather conditions, 

higher than predicted activity of bark beetles, and other factors. This has rendered much of the small 

diameter volume unmerchantable for traditional lumber products. Larger diameter trees deteriorate at a 

slower rate and have a higher initial value. Inclusion of these trees is an essential component of the 

economic viability of these sales. Loss of volume and value associated primarily with the larger diameter 

trees and coupled with fluctuating lumber markets, could render the majority of helicopter and skyline 

portions of round-two sales as economically unviable. 

There would be no effect on multiple-use goals and objectives for long-term land and resource 

management from the no action alternative because there is no plan amendment proposed under this 

alternative. No adjustments to management area boundaries are proposed, therefore, there would be no

change in land allocation. There would be no effect on standards and guidelines from the no action 

alternative because there is no plan amendment proposed under this alternative. 

Proposed Action Alternative 

Direct, Indirect, and Cumulative Effects

Effects to resources would be as described for all resources under Alternative B in the Project FEIS. 

Timber harvest would still occur in the same areas and along the same roads as originally described in the 

Project FEIS. Logging systems would remain the same and no new trees would be designated for harvest. 

The size and location of Riparian Habitat Conservation Areas would remain the same as would the 

measures to protect those areas. Seasonal restrictions on operations to minimize effects on big game

winter range, soils, and snowmobile uses would remain the same. Therefore, as a result of this 

amendment, there would be no changes on the ground, or to environmental effects beyond those already

described in the Project FEIS. 

The Forest Plan allows for salvage from all of the lands included in the Project. A summary of the related 

Forest Plan management direction is found in the Project FEIS, pp. 1-10 through 1-14. The Forest Plan 

(p. 4-67) includes the following goal: “Provide for production of wood fiber consistent with various 

resource objectives, environmental constraints, and considering cost efficiency.” Management direction 

for the various land allocations in the Forest Plan recognizes the need or desire to salvage wood fiber 

following natural disturbance (Forest Plan pp. 4-94 through 4-105). The proposed action helps meet the 

goal of wood fiber production by allowing salvage of dead and dying timber that would not otherwise be 

salvaged. The Project FEIS (Chapter 3) addresses the environmental effects of the project in light of the 

full suite of Forest Plan management direction. In the Project's ROD these effects are evaluated and a 

finding is made that the selected alternative from that EIS is consistent with the Forest Plan, as amended 

(ROD p. 12).

The amendment proposed in this FSEIS is short-term (the life of this project) and of limited scope 

(28,000 acres of the 1.5 million acre Umatilla National Forest) and it amends the Forest Plan in a way that 

contributes to achieving plan goals. The proposed action includes modification of one Forest Plan 

standard, limited to the duration and geographic scope of the Project. The amendment would not change 

management intent of the Eastside Screens wildlife standard nor would there be changes in how the 

standard would be applied to the Project compared to the effects disclosed in the July 2006 Project FEIS. 

3-3 
Chapter 3 – Affected Environment and Environmental Consequences 

This amendment clarifies the definitions of live and dead trees to be consistent with normal agency

practice and current science. There would be no effect on any other standards and guidelines except the 

Eastside Screens wildlife standard. No adjustments to management area boundaries are proposed, 

therefore, there would be no change in land allocation. This amendment would not preclude or require 

other actions across the forest. Therefore, this amendment would not meaningfully affect multiple-use 

goals and objectives for long-term land and resource management for the remainder of the planning 

period. 

EFFECTS COMMON TO ALL ALTERNATIVES 

Columbia Complex Fire

Columbia Complex Fire burned in Garfield and Columbia Counties during August and September of 

2006. A portion of the Columbia Fire footprint is immediately adjacent to the School Fire area and a 

small portion (approximately 100 acres) overlapped the School Fire perimeter. 

Columbia Complex Fire was primarily wind and terrain dominated which resulted in the fire spreading 

from ridge top to ridge top and it subsequently backing into drainages. This resulted in less intense fire 

effects along lower slopes and in drainage bottoms. School Fire was plume dominated which resulted in a 

large smoke columns developing and then collapsing. This spread fire across the entire landscape and 

higher intensities burning from the bottoms of drainages to the top. 

On September 8, 2006, the Pomeroy District Ranger documented to the Forest Supervisor qualitative 

observations and information from a field assessment by the District Fish Biologist. The Fish Biologist 

concluded that there should be a low probability for sediment to enter the Tucannon River from Columbia 

Complex Fire. His conclusion was based on the following qualitative criteria: 

• Most riparian zones were still intact. The fire consumed predominately ground fuels, not 

crowns, and there were few examples of stand replacing fire. 

• Some dry draws showed signs of higher burn intensities, but wet riparian draws demonstrated

rare instances of higher burn intensities. 

• The three highest burn intensity drainages from School Fire (Tucannon River, Cummings and 

Tumalum Creek) had recovered significantly in one year. Since no evidence of scorched red 

soils were observed in Columbia Complex Fire drainage bottoms, it is very likely that these 

areas will recover even faster than School’s high intensity burn drainages. 

• Very little area between the two fires overlap (approximately 100 acres) there has been 

virtually no fire damage to BAER or district rehabilitated areas in School Fire perimeter. 

School Fire Salvage Recovery Project was designed to limit the effects of salvage harvest on sediment 

delivery. Examples of design criteria include, but are not limited to (See FEIS, Chapter 2 for complete

list): 

• Utilizing forwarder logging systems in place of rubber tire or track ground based yarding. 

• Emphasizing helicopter yarding to reduce ground disturbance. 

• Adding additional grass seeding requirements. 

• Adding 25-foot ephemeral buffers, in addition to standard PACFISH requirements. 

3-4 
Chapter 3 – Affected Environment and Environmental Consequences 

Several of these design criteria were more restrictive than current Forest Plan standards and guidelines. 

This resulted in only a modeled 1.5 percent increase in of sediment over baseline values, while harvesting 

9,432 acres across 27,000 acres (35 percent of all federal acres). 

Columbia Complex Fire may have slightly increased natural baseline sedimentation, but cumulative 

effects of salvage harvest from the School Project (which includes activities resulting from this proposed 

action) and Columbia Complex Fire would be negligible. Currently, only 500 acres are proposed for 

salvage harvest across 48,000 acres (1 percent of all federal acres) of the Columbia Complex. The 

combination of both fires results in the over-all percent of acres being salvage harvested across a burned 

landscape dropping from 35 percent to 13 percent 

A small portion of Columbia Complex Fire did burn into the School Fire perimeter and created a 100-acre 

overlap. This area is less than one-tenth of one percent (00.1 percent). No BAER or district rehabilitation 

efforts were located in that 100-acre overlap. Cumulative effects relative to sedimentation and fish 

habitat would be minimal. 

Cumulative effects for dead wood should be positive. The Columbia Complex burned and additional 

48,000 acres of which only 500 acres is proposed for salvage harvest. This results in an increase in 

percentage of acres available for wildlife needs from 65 percent to over 87 percent. 

Alternate or Conflicting Science

Several respondents to the School Fire Salvage Recovery Project and this supplement have commented on

alternate or conflicting science. Some have suggested that methods used by the Forest Service do not

represent the “best” science available. The methods and science used by the Forest Service to analyze 

effects of all alternatives does have an affect on the results documented here and in the FEIS. This 

section documents: (1) science the Forest Serve considered (2) applicability of the science to this project, 

(3) why the Forest Service chose to use one methodology over another, and (4) why the Forest Service 

did not use the methodology and why not. The Forest Service recognizes there will always be uncertainty

associated with some aspects of this project, however this section discloses what the Forest Service 

believes represents the “best” science available. 

VEGETATION

Science Criteria. The Eastside Screens are interim direction used to amend the Land and Resource 

Management Plans for every national forest located east of the Cascade Mountains in Oregon and 

Washington. The current version of the Eastside Screens is Regional Forester’s Forest Plan Amendment 

#2 (USDA Forest Service 1995). 

After the Eastside Screens were issued, the Pacific Northwest Regional Forester appointed an Eastside 

Screens Oversight Team (Norris 2005) and charged them with reviewing and monitoring Screens 

implementation. The team’s objective was to ensure that the Eastside Screens were being applied 

consistently across all of the Eastside national forests. 

The Oversight Team provided clarification and interpretation of the Eastside Screens by periodically 

reviewing sample projects on each national forest, producing a letter describing their findings, and then 

circulating the letter to other Eastside national forests as a “lessons learned” communication tool. These 

letters, which are signed by the Regional Forester or the Director of Natural Resources, are not considered 

advisory because they are used as administrative direction for Eastside Screens implementation. 

3-5 
Chapter 3 – Affected Environment and Environmental Consequences 

The Eastside Screens has a requirement to consider “best available science” (item 4 in scenario A of the 

wildlife screen) and during Screens implementation, questions arose about how to interpret this phrase. 

In response to the Colville National Forest’s request for clarification about the “best available science” 

requirement, the Oversight Team produced an administrative policy letter stating that (Devlin 1998a): 

“Science of course means peer reviewed and published by credible sources, and does not 

include articles, comments, or input that is simply opinion or editorials by scientists. 

‘Expert opinion’ can be helpful, but is not the same as ‘new science’.” 

Although the criteria provided by the Oversight Team (Devlin 1998a) are not the only ones that could be 

used to identify “best available science,” it is our judgment that: 

(1) They are suitable for this purpose; and 

(2) Using them for this purpose is consistent with administrative policy of the Pacific Northwest 

Region of the USDA Forest Service since at least 1998 (Devlin 1998a). 

For these two reasons, the Devlin (1998a) science criteria will be used in this appendix to identify if 

reports and articles mentioned in comments to the School Fire Salvage Recovery Project are peer 

reviewed and published by credible sources, and whether they are articles, comments, or input considered 

to be opinion or editorials by scientists. 

Note that the Devlin (1998a) letter did not provide explicit criteria for what constitutes “credible sources” 

of science information. We used accepted, government-agency standards of what qualifies as a credible 

source. Criteria supplied by the National Academy of Sciences was consulted, such as “publication in a 

peer-reviewed journal remains the standard means of disseminating scientific results” (Committee on 

Science, Engineering and Public Policy 1995), but research papers and notes, and general technical 

reports, particularly those published by the Forest Service’s research branch, were typically handled as 

credible sources because they are produced using a peer-review process similar to what is employed for 

scholarly journals. 

Beschta et al. Reports

The original Beschta Report (Beschta et al. 1995) was commissioned by Pacific Rivers Council. 

Apparently, it was neither peer-reviewed nor published in a credible source. 

A similar version (Beschta et al. 2004) was subsequently published in a peer-reviewed journal called 

Conservation Biology. Since this version was peer reviewed and is available from a credible source, it is 

considered to have more scientific credibility than the original report. 

Although the second Beschta report (Beschta et al. 2004) cited more literature than the first report to 

support the authors’ points of view, it is considered to be an editorial or opinion piece. 

One or both of the Beschta reports was mentioned by numerous respondents during public scoping or in 

response to the draft environmental impact statement. The Beschta report respondents generally 

advocated that natural recovery of burned landscapes, with little or no human intervention, is the optimal 

policy for public forests, and that this policy is supported by other literature such as American Lands 

Alliance (2005), DellaSala et al. (2006), Donato et al. (2006), Karr et al. (2004), Lindenmayer et al. 

(2004), and McIver and Starr (2000, 2001a). 

The non-intervention respondents often stated that recovering economic value from dead trees is an 

inappropriate objective, particularly for public lands such as national forests, or that other values 

associated with dead trees (wildlife habitat, etc.) provide more net public benefit than revenue and related 

socioeconomic benefits (employment, income) derived from recovering the salvaged timber. 

3-6 
Chapter 3 – Affected Environment and Environmental Consequences 

When US Forest Service research scientists reviewed the original Beschta report, they concluded that it 

was biased toward a custodial (hands off) approach (Everett 1995), and that it is generally accepted in the 

science community that limiting post-fire management to just a single approach (whether custodial or 

commodity) is inappropriate because forest sites encompass a wide range of variability, and this 

variability points to the need for site-specific plans addressing each salvage situation on a case-by-case 

basis (Everett 1995, McIver and Starr 2001b). 

The Everett response (Everett 1995) to the original Beschta report (Beschta et al. 1995) was apparently

not peer-reviewed or published in a credible source. 

Relevance to the Forest Vegetation portion of the School Fire Salvage Recovery Project. We 

reviewed the Beschta Report (Beschta et al. 1995) and the Beschta journal article (Beschta et al. 2004). 

In our judgment, the School Fire Salvage Recovery Project includes an alternative that would react to the 

burned forest in a manner similar to what is recommended by Beschta et al. (1995, 2004) – the No Action 

alternative. 

Specifically, the no action alternative would satisfy most or all of the Beschta et al. (1995, 2004) 

recommendations because it would not harvest trees in areas with steep slopes, sensitive soils, or severe 

fire intensity; it would not harvest trees in riparian areas; it would not build roads (whether temporary or 

permanent) to access harvest units; it would not harvest live trees (regardless of how tree mortality was 

determined); and it would not artificially regenerate (reforest) burned sites. 

With these Beschta et al. (1995, 2004) limitations in place, most of the salvage timber harvest units in the 

proposed action (alternative B) would not be available for harvest, which means that the purpose and need 

for economic recovery of dead and dying trees would not be achieved. 

A lack of agreement between the Beschta et al. (1995, 2004) recommendations and the School Fire 

Salvage Recovery Project proposed action is not surprising because the Beschta reports address 

ecosystem restoration goals, while the School Fire Salvage Recovery Project focuses on recovery of

economic value. 

American Lands Alliance “After the Fires” Report

The objective of the American Lands Alliance (ALA) report (American Lands Alliance 2005) is to “raise 

awareness among policy makers about the short- and long-term adverse ecological and economic impacts 

of post-fire logging.” It draws extensively from the recent Beschta et al. (2004) article in Conservation 

Biology.

The ALA report provides an extensive list of individuals and organizations that helped to produce it. 

However, the ALA report does not appear to be peer-reviewed (or credit for peer review was not claimed) 

and it was not published in a credible source. The American Lands Alliance “After the Fires” report is 

considered to be an editorial or opinion piece. 

The United States Forest Service prepared a response to the ALA report. It concluded that “ALA makes 

highly selective use of the scientific information that addresses this complex topic [logging after fires], 

ignores the legal mandates placed on the agency by Congress, and downplays the effects of inaction on 

public forests and local communities” (USDA Forest Service 2005). 

The US Forest Service response to the ALA report was apparently not peer-reviewed or published in a 

credible source. 

We reviewed the ALA “after the fires” report and the US Forest Service response to it. In our judgment, 

the School Fire Salvage Recovery Project includes an alternative that would react to the burned forest in a 

manner similar to what is recommended by the American Lands Alliance (2005) – the No Action 

alternative. 

3-7 
Chapter 3 – Affected Environment and Environmental Consequences 

Our discussion about the Beschta et al. (1995, 2004) reports and their relevance to the School Fire 

Salvage Recovery Project, specifically the No Action alternative, also pertains to the ALA report, and it is 

incorporated here by reference. 

McIver and Starr Salvage Logging Literature Synthesis and Review 

The McIver and Starr report is entitled “Environmental effects of post-fire logging: literature review and 

annotated bibliography” (McIver and Starr 2000). The acknowledgments section of this report indicates 

that it was peer reviewed before being published by the Pacific Northwest Research Station in Portland, 

Oregon. 

Results from the original General Technical Report (McIver and Starr 2000) were also reported in a peerreviewed journal called the Western Journal of Applied Forestry (McIver and Starr 2001a), and this 

journal is a credible source. 

The McIver and Starr report reviews the existing body of scientific literature about logging (timber 

harvest) following wildfire. Twenty-one post-fire logging studies were reviewed and interpreted. McIver 

and Starr concluded that while the practice of salvage logging after fires is controversial, the debate is 

conducted without the benefit of much scientific information (McIver and Starr 2000, 2001a). 

They also concluded that the immediate environmental effects of post-fire logging are extremely variable 

and dependent on a wide variety of factors such as fire severity, slope steepness, soil texture and 

composition, the presence of preexisting roads, construction of new roads, timber harvest systems, and 

post-fire weather conditions (McIver and Starr 2000, 2001a). 

Relevance to the Forest Vegetation portion of the School Fire Salvage Recovery Project. The 

McIver and Starr literature synthesis identified 21 studies worldwide that examined the environmental 

effects of post-fire salvage harvest (McIver and Starr 2000, 2001a).

Only 14 of the 21 studies included an unharvested control, which allows the effect of timber harvest to be 

isolated from unharvested areas with similar site conditions. Only 7 of the 14 studies with unharvested 

controls were replicated, which allows inferences from one study to be extrapolated or generalized to 

other areas with similar biophysical conditions (McIver and Starr 2000, 2001a). 

Although 14 controlled studies might seem like an acceptable number, it is actually not very many when 

considering the extensive variability of site and ecosystem conditions exposed to salvage logging, 

particularly since the McIver and Starr report considered literature from around the world. 

It is our judgment that any of the McIver and Starr salvage studies from areas outside the interior Pacific 

Northwest, the geographical region of the western United States containing the School Fire area, are 

likely to include site and ecosystem conditions differing from those found in the School Fire area. 

Of the 14 primary studies with unharvested controls, seven of them do not apply to the School Fire area 

because they were conducted in geographical areas outside the interior Pacific Northwest: two studies 

from Australia, one study from Israel, and United States studies from central California, northwestern 

Wyoming, northern Arizona, and northwestern (coastal) California. 

Because scientific information about salvage harvest was so sketchy, particularly for the geographic scope 

of their review (“the dry forested intermountain West”), McIver and Starr argued for the use of adaptive 

management techniques to monitor the effects of salvage logging, and to use monitoring results to adjust 

site-specific practices and prescriptions accordingly (McIver and Starr 2001a). 

We reviewed the McIver and Starr report (McIver and Starr 2000) and its associated journal article 

(McIver and Starr 2001a). In our judgment, the McIver and Starr literature synthesis findings do not 

3-8 
Chapter 3 – Affected Environment and Environmental Consequences 

adopt a definitive position with respect to the suitability (or unsuitability) of salvage timber harvest as an 

activity for recovering economic value from dead and dying trees, so it is difficult to judge their relevance 

to the purpose and need for the School Fire Salvage Recovery Project. 

Much of the salvage logging literature considered by McIver and Starr (2000, 2001a) is rather dated and 

was based on older techniques, equipment and silvicultural prescriptions. Of the 14 primary studies with 

unharvested controls, only seven of them are relevant to the School Fire area and the dates for these 

studies range from 1970 to 1997. Note that four of the seven relevant studies were replicated experiments 

and the other three were unreplicated experiments or modeling studies. 

We are aware of little or no research examining the effects of salvage timber harvest in the context of 

contemporary techniques, equipment and prescriptions. For this reason, it is likely that some aspects of 

the McIver and Starr literature synthesis are not relevant to the School Fire Salvage Recovery Project. 

McIver and Ottmar Postfire Logging Article

One respondent mentioned a recent article published in a journal called Forest Ecology and Management 

(McIver and Ottmar 2007). This article describes a modeling study based on preliminary information 

about postfire development following a 1996 wildfire in the central Blue Mountains (the Summit fire on 

the Malheur National Forest). This article was published in a peer-reviewed journal and is available from

a credible source. 

We reviewed the McIver and Ottmar (2007) article, and concluded that it has some relevance to the 

School Fire Salvage Recovery Project because it suggests (as based on computerized modeling) that 

reburn potential could be influenced more by postfire development of herbaceous vegetation and shrubs 

than by using salvage harvest to remove woody fuels from the burned sites. 

Although minimizing future reburn potential was not included in the School Fire Salvage Recovery

Project purpose and need, and therefore it had no influence on the selection of proposed actions for the 

School Fire area, the risk of reburn was discussed as a regeneration concern in Appendix F of the School 

Fire FEIS. 

The McIver and Ottmar (2007) article notes the importance of treating post-harvest slash as one option for 

protecting residual and developing tree stands, and the School Fire FEIS included such treatments for 

portions of the School Fire where slash loading was predicted to pose an unacceptable risk, but this article 

suggests that the time period when fuel loading differences between logged and unlogged areas might not 

be meaningful depending upon wildfire return intervals and other assumptions. 

The McIver and Ottmar (2007) article recognized the variability associated with wildland sites, and it 

concluded that “in general, how logging-generated slash fuels influence future stand development will 

tend to vary from site to site, in accordance with a wide variety of factors.” This conclusion reiterates that 

natural variation would be expected to influence how results from this study could be extrapolated to 

other areas. 

This modeling study suggests that future reburn potential might not be affected as much by large and 

small woody fuels as by non-woody fuels such as grasses and shrubs; regardless of what the fuel source 

was, this article suggests that a future reburn could result in a need to replant certain areas in order to 

bring stocking levels back up to Forest Plan minimums, particularly if reburning occurred within the first 

few decades after tree planting. 

3-9 
Chapter 3 – Affected Environment and Environmental Consequences 

ICBEMP Scientific Assessment for Ecosystem Management

At least one respondent to the School Fire Salvage Recovery Project scoping activity mentioned that 

salvage logging is not compatible with ecosystem management (specifically, the comment referred to a 

section on page 178 in Quigley et al. (1996) called “Can salvage timber sales be compatible with 

ecosystem-based management?”). 

The acknowledgments section of this Interior Columbia Basin Ecosystem Management Project 

(ICBEMP) report indicates that it was peer reviewed before being published by the Pacific Northwest 

Research Station in Portland, Oregon. 

The ICBEMP scientific assessment section referred to in this comment deals primarily with removal of 

large-diameter trees, and it is discussed in the context of the “Taylor Salvage Rider” bill passed by the US 

Congress in 1995 (PL 104-19). Note that the Taylor Salvage Rider legislation is no longer in effect. 

The section referenced above concludes that “ecosystem-based management would emphasize removing 

smaller green trees with greater attention to prevention of mortality rather than removal of large dead 

trees.” 

Relevance to the Forest Vegetation portion of the School Fire Salvage Recovery Project. We 

reviewed the ICBEMP salvage timber sales section (Quigley et al. 1996) referenced by the respondent. In

our judgment, this section is not relevant to the School Fire Salvage Recovery Project for four reasons: 

1. The purpose and need for the salvage timber harvest component of the School Fire Salvage 

Recovery Project does not include “ecosystem-based management” objectives; 

2. The proposed action for the School Fire Salvage Recovery Project does not include any removal 

of smaller green trees, as was recommended by the ICBEMP salvage section; 

3. The School Fire Salvage Recovery Project proposes to remove a range of tree diameters 

involving trees that are exclusively dead or dying, rather than emphasizing larger trees, “both 

green and recent dead,” of economically desirable species (as is mentioned in the ICBEMP 

section); 

4. The School Fire Salvage Recovery Project is not formulated or proposed in the context of the 

Taylor Salvage Law (PL 104-19), and most of the ICBEMP discussion deals with provisions or 

implementation characteristics associated with the Taylor salvage bill. 

Donato et al. Article

On January 5, 2006, a short article was published in Sciencexpress, an on-line affiliate of a print journal 

called Science, with this title: “Post-Wildfire Logging Hinders Regeneration and Increases Fire Risk.” 

The same or a slightly modified version was subsequently published as a single-page article in the full 

journal (Science) on January 20, 2006 (Donato et al. 2006a, 2006b). 

The Donato article (Donato et al. 2006a, 2006b) was published in a peer-reviewed journal and is available 

from a credible source. 

An analysis of the Donato methodology indicates that there might be serious flaws with the study and its 

design, including the statistical analysis of data (Baird 2006). The Baird (2006) analysis was apparently

not peer-reviewed or published in a credible source (although it was apparently submitted to Science to be 

considered as a peer-reviewed rebuttal to the original Donato et al. article). 

The Donato et al. article (2006a, 2006b) presents preliminary results from a post-fire study conducted in 

the 2002 Biscuit Fire area of southwestern Oregon. It concluded “that postfire logging, by removing 

naturally seeded conifers and increasing surface fuel loads, can be counterproductive to goals of forest 

regeneration and fuel reduction.” 

3-10
Chapter 3 – Affected Environment and Environmental Consequences 

This conclusion was based on an examination of early conifer regeneration and fuel loadings, and it used 

a spatially nested sampling design of both logged and unlogged plots replicated across a portion of the 

Biscuit Fire area. 

Relevance to the Forest Vegetation portion of the School Fire Salvage Recovery Project. We 

reviewed the Donato et al. (2006a, 2006b) article and believe it is relevant to the School Fire Salvage 

Recovery Project in at least two respects:

1. The School Fire action alternatives (alternatives B and C) include artificial regeneration (tree 

planting) for all areas that would be affected by the salvage timber harvest activity. The Donato 

study showed that postfire logging reduced natural regeneration by 71% (Donato et al. 2006a, 

2006b), so the tree planting portion of the School Fire proposed action would help mitigate for 

any salvage-caused loss of naturally regenerated seedlings. 

2. As described in the Regeneration Analysis for the School Fire (appendix D), many of the 

regeneration areas are considered to be at high risk of complete tree loss if another fire occurs in 

the next 10-30 years, primarily because of uncharacteristically high fuel loads created by the 

School Fire (Martin 2006). The risk of a future reburn is one reason for reducing large fuels in 

the School Fire area, and salvage timber harvest is a proposed activity for reducing large fuels. 

Because the Donato article lacks specifics about when the salvage harvest occurred, it is not definitively

known how many growing seasons occurred between the fire and the salvage harvest activity. If it is 

assumed that three growing seasons occurred between these events, then the finding about salvage 

logging causing a 71% reduction in natural regeneration is not unexpected because: 

1. If post-fire weather conditions were conducive to germination of tree seeds, and if tree seeds were 

actually present, then we would expect some amount of natural tree regeneration to be established 

by three growing seasons after the fire (and if tree seed sources were functional during the entire 

3-year period, the seedling amounts present in year 3 were probably greater than those in year 2, 

and the seedling amounts present in year 2 were probably greater than those in year 1); 

2. If post-fire weather conditions were conducive to establishment of natural tree regeneration, and 

if obvious amounts of natural regeneration became established by avoiding mortality from

competing vegetation or animal herbivory, then we would expect salvage harvest to have a 

negative effect on tree seedlings because they are too small to be avoided by harvest equipment, 

and they are too vulnerable to survive harvest-caused damage. 

As described earlier in this document, the proposed salvage timber harvest activity is expected to occur 

during the first growing season following the School Fire, although some of it is also expected to occur 

during the second and third growing seasons. 

Since the time interval between the School Fire and the majority of the proposed salvage harvest is 

shorter than the time interval associated with the Donato study, it is our judgment that the effect of 

salvage on natural regeneration would be less than what was reported by Donato because less natural 

regeneration is expected to be established by the first or second year after the fire than would be present if 

salvage occurred following the third growing season. 

If the salvage timber harvest activity is implemented as proposed, thereby removing a reasonable 

proportion of the large-fuel component from affected areas, and if the associated small-fuel treatments are 

completed as proposed (see Martin 2006), then it is our judgment that regenerated stands (both natural 

and planted) would survive a future reburn to an extent that replanting would not be necessary to meet 

Forest Plan minimum stocking levels (table 1-2) (USDA Forest Service 1990a).

This conclusion about reburn outcomes is based on an assumption that future reburn potential would be 

affected primarily by a combination of large and small woody fuels; if future fire intensity is largely

3-11
Chapter 3 – Affected Environment and Environmental Consequences 

related to non-woody fuels (such as grasses and shrubs), then a future reburn could still result in a need to 

replant certain areas in order to meet minimum stocking levels, particularly if reburning occurred within 

the first few decades after tree planting. 

Shatford et al. Conifer Regeneration Article

One respondent mentioned a recent article published in the Journal of Forestry (Shatford et al. 2007). 

This article was published in a peer-reviewed journal and is available from a credible source. 

We reviewed the Shatford et al. (2007) article, and concluded that some of its conclusions are similar to 

those from the Donato et al. (2006a, 2007b) article. The Donato article reported that conifer regeneration 

was variable but generally abundant for their study sites, and the Shatford et al. (2007) article reached 

similar conclusions, but with one important difference: the Shatford study sites have experienced a much 

longer period of postfire development (9-19 years) than the areas examined for the Donato study (3 

years). 

The Shatford et al. (2007) article does not examine the influence of salvage timber harvest on postfire 

conifer regeneration, or on post-treatment fuel loading. But with respect to the natural regeneration 

conclusions reached by both studies, they are similar, and since both studies occurred in the same

ecoregion, the Shatford et al. (2007) article might indicate that we could expect the near-term results 

reported in the Donato article to be maintained over a longer term as well. 

Note that both the Donato and Shatford articles pertain to an ecoregion (Klamath-Siskiyou) with 

substantial differences from the Blue Mountains section, particularly with respect to climate and geology, 

and these differences are perceived to have an important influence on whether results from either study

could be appropriately extrapolated to the Blue Mountains. 

Appendix F of the School Fire FEIS presents a regeneration analysis for the School Fire area. It describes 

how the potential for natural regeneration within the School Fire area was analyzed (see Map F-1): when 

an acceptable seed source was expected to result in natural regeneration, then it was emphasized as the 

regeneration method instead of tree planting. If regeneration results similar to what was reported in the 

Shatford et al. (2007) article also occur in the School Fire area, then it is likely that more natural 

regeneration will occur than was predicted in the School Fire FEIS.

However, an increase of natural regeneration in the School Fire area, as compared to what was predicted 

in the School Fire FEIS, is not expected to have an effect on the environmental consequences section of 

the FEIS because it is anticipated that the species composition of the natural regeneration would be 

similar to what would have been planted (the recommended planting mix is described in Chapter 2, table 

2-2 of the School Fire FEIS), resulting in little or no change to predicted development of future 

composition and structure in the School Fire analysis area. 

Lindenmayer et al. Salvage Harvest Article

The journal Science published a one-page article about salvage harvest on February 27, 2004

(Lindenmayer et al. 2004). Its position is that (1) salvage harvest undermines the ecosystem benefits of 

major disturbances; (2) removing biological legacies (large wood) can negatively affect many taxa; (3) 

salvage harvest can impair ecosystem recovery; and (4) some taxa might be maladapted to the interactive 

effects of two disturbance events in rapid succession (fire and salvage logging). 

The Lindenmayer article (Lindenmayer et al. 2004) was published in a peer-reviewed journal and is 

readily available from a credible source. It is considered to be an editorial or opinion piece. 

3-12
Chapter 3 – Affected Environment and Environmental Consequences 

We reviewed the Lindenmayer et al. (2004) article. In our judgment, the School Fire Salvage Recovery

Project includes an alternative that would respond to the burned forest in a manner similar to what is 

recommended by Lindenmayer et al. (2004) – the No Action alternative. 

Our discussion about the Beschta et al. (1995, 2004) reports and their relevance to the School Fire 

Salvage Recovery Project, specifically the No Action alternative, also pertains to the Lindenmayer et al. 

(2004) article, and it is incorporated here by reference. 

Society for Conservation Biology Scientific Panel Report

The Society for Conservation Biology published a white paper or report reviewing ecological science 

pertaining to fire management policies for western United States forests on February 24, 2006 (Noss et al. 

2006). 

The Society for Conservation Biology report (Noss et al. 2006) was apparently not peer reviewed (or 

credit for peer review was not claimed) and it was not published in a scientific journal or in another 

credible source. 

The Society for Conservation Biology report is considered to be an editorial or opinion piece. This 

conclusion is based partially on the fact that no literature citations are provided for any of the key findings 

(or for any other statement or conclusion in the report), and the report does not include a “literature cited” 

section. These omissions make it more difficult for the reader to determine whether key findings and 

other statements are based on scientific literature, and to judge the veracity of key findings. 

This report offers one or more “key findings” for each of the following primary topic or issue areas: (1) 

variable effects of fire exclusion, logging, livestock grazing, and plantations; (2) forests characterized by

high-severity fires; (3) forests characterized by mixed-severity fires; (4) forests characterized by lowseverity fires; (5) priorities and principles of ecologically-based forest restoration; (6) protected areas are 

essential for managing fire for ecological diversity; (7) management activities during wildfire; and (8) 

forest management after wildfire. 

We reviewed the Society for Conservation Biology report (Noss et al. 2006). In our judgment, this report 

includes one topic or issue area that obviously pertains to the School Fire Salvage Recovery Project: the 

“forest management after wildfire” topic. This topic includes 10 key findings, and each of them will be 

discussed individually.

1. Research by both ecologists and foresters provides evidence that areas affected by large-scale natural 

disturbances often recover naturally. 

Response: although this key finding provides no explicit definition or criteria for what constitutes 

natural recovery, it is our judgment that the School Fire Salvage Recovery Project includes an 

alternative that would respond to the burned forest in a manner similar to what is reported here: the 

No Action alternative. The No Action alternative adopts a passive management approach 

emphasizing natural recovery of burned landscapes and little or no human interaction with ecosystem

recovery processes. 

2. Post-fire logging does not contribute to ecological recovery; rather it negatively impacts recovery

processes, with the intensity of such impacts depending upon the nature of the logging activity. 

Response: although this key finding provides no explicit definition or criteria for what constitutes 

ecological recovery, it is our judgment that the School Fire Salvage Recovery Project includes an 

alternative that would respond to the burned forest in a manner similar to what is reported here: the 

No Action alternative. Since the No Action alternative adopts a passive management approach 

emphasizing natural recovery of burned landscapes, it responds to the philosophy that removal of 

3-13
Chapter 3 – Affected Environment and Environmental Consequences 

dead trees (using salvage timber harvest) makes an unfortunate situation even worse (Beschta et al. 

1995, 2004). 

3. Post-fire logging destroys much of whatever natural tree regeneration is occurring on a burned site. 

Response: this finding is similar to one of the two primary conclusions of the Donato et al. (2006) 

study, which is discussed earlier in this section. The School Fire action alternatives (alternatives B 

and C) include tree planting for all areas that would be affected by the salvage timber harvest activity. 

It is our judgment that this tree planting activity would help mitigate for any salvage-caused loss of 

natural tree regeneration. 

4. Evidence from empirical studies is that post-fire logging typically generates significant short- to midterm increases in fine and medium fuels.

Response: the School Fire Salvage Recovery Project fuels analysis shows that salvage timber harvest 

will contribute to fuel loads that warrant treatment after harvest, but this result is expected for some of 

the salvage harvest units but not for all of them. When post-salvage fuel loads are predicted to exceed 

Forest Plan thresholds, then fuel treatments are proposed to reduce the salvage activity fuels to 

acceptable levels. This issue is addressed in more detail in the fuels analysis. 

5. In forests subjected to severe fire and post-fire logging, streams and other aquatic ecosystems will 

take longer to return to historic conditions or may switch to a different (and often less desirable) state 

altogether. 

Response: this finding is beyond the scope of forest vegetation, so no response is offered. It is likely

that this issue is addressed in the fisheries analysis. 

6. Post-fire seeding of non-native plants generally damages natural ecological values, such as reducing 

the recovery of native plant cover and biodiversity, including tree regeneration. 

Response: this finding is beyond the scope of forest vegetation, so no response is offered. It is likely

that this issue is addressed in the noxious weeds analysis. 

7. Post-fire seeding of non-native plants is often ineffective at reducing soil erosion. 

Response: this finding is beyond the scope of forest vegetation, so no response is offered. It is likely

that this issue is addressed in the noxious weeds and soils analyses. 

8. There is no scientific or operational linkage between reforestation and post-fire logging; potential 

ecological impacts of reforestation are varied and may be either positive or negative depending upon 

the specifics of activity, site conditions, and management objectives. On the other hand, ecological 

impacts of post-fire logging appear to be consistently negative. 

Response: it is our judgment that the School Fire Salvage Recovery Project includes a direct linkage 

between reforestation and post-fire salvage harvest, and this linkage is mandatory because Forest 

Service policy is that the National Forest Management Act requires salvage harvest units to be 

reforested within 5 years of harvest (Goodman 2002). It is our judgment that the claim that 

“ecological impacts of post-fire logging appear to be consistently negative” is opinion, and that it is 

not supported by scientific literature or other evidence (and Noss et al. cite no scientific literature in 

support of this claim). 

9. Accelerated reestablishment of extensive closed forest conditions after fire is usually not an 

appropriate objective on sites managed with a major ecological focus. 

Response: although this key finding provides no explicit definition or criteria for what constitutes 

“sites managed with a major ecological focus,” it is our judgment that the School Fire Salvage 

Recovery Project includes ecologically appropriate regeneration recommendations (see table 1-3) 

because they vary by potential vegetation category (i.e., plant association group). Sites whose 

3-14
Chapter 3 – Affected Environment and Environmental Consequences 

ecological temperature-moisture regime is hot or warm, and dry, have dramatically lower seedling 

density levels (in table 1-3) than sites with a cool or moist temperature-moisture regime. It is our 

judgment that varying the regeneration recommendations by plant association group, as has been 

done in table 1-3, will reduce the potential for “extensive closed forest” getting reestablished on sites 

where it is an ecologically inappropriate condition (and closed forest is ecologically appropriate for 

some sites). 

10. Where timber production, other societal management goals, or special ecological needs are the focus, 

planting or seeding some native trees and other plants using local seed sources may be appropriate. 

Response: Forest Service policy is that the National Forest Management Act has established a legal 

requirement to reforest salvage harvest units within 5 years of harvest (Goodman 2002). If natural 

tree regeneration is predicted to be insufficient or ineffective at meeting this legal requirement, then 

tree planting (artificial tree regeneration) is proposed in the School Fire Salvage Recovery Project. 

The rationale for natural and artificial regeneration assumptions is provided in the Regeneration 

Analysis for the School Fire (appendix D of this document). Tree seedlings and other native plant 

materials are always produced from local seed sources. 

Lindenmayer and Noss Salvage Logging Article

One respondent mentioned a recent article published in a journal called Conservation Biology

(Lindenmayer and Noss 2006). 

This article was published in a peer-reviewed journal and is available from a credible source. 

We reviewed the Lindenmayer and Noss (2006) article, and concluded that its recommendations are 

similar to those offered by the Lindenmayer et al. (2004) salvage harvest article, and the Society for 

Conservation Biology scientific panel report (Noss et al. 2006). Our responses to those items are also 

applicable to the Lindenmayer and Noss (2006) salvage logging article. 

Note that the Lindenmayer and Noss (2006) article is a literature survey or synthesis; it does not report 

research results from a new or previously unpublished salvage logging study. As such, it can be 

considered to be an opinion piece offering commentary by two scientists, and one of its stated objectives 

is to build on the literature surveys conducted by McIver and Starr (see earlier section entitled “McIver 

and Starr Salvage Logging Literature Synthesis and Review”). 

Noss et al. (2006) Postfire Management Article

One respondent mentioned a recent article published in a journal called Frontiers in Ecology and the 

Environment, a journal published by the Ecological Society of America (Noss et al. 2006). 

This article was published in a peer-reviewed journal and is available from a credible source. 

We reviewed the Noss et al. (2006) article, and concluded that its recommendations are similar to those 

offered by the Society for Conservation Biology scientific panel report (Noss et al. 2006). Our response 

to that item is also applicable to the Noss et al. (2006) postfire management article. 

Note that the Noss et al. (2006) article is a literature survey or synthesis; it does not report research results 

from a new or previously unpublished salvage logging study. As such, it can be considered to be an 

opinion piece offering commentary by five scientists, as illustrated by this example: “Post-fire logging 

usually has no ecological benefits and many negative impacts; the same is often true for post-fire 

seeding.” 

3-15
Chapter 3 – Affected Environment and Environmental Consequences 

It is our judgment that the commentary expressed in the Noss et al. (2006) is similar to the commentary

discussed previously in this section (Beschta reports, American Lands Alliance report, McIver and Starr 

literature syntheses, ICBEMP scientific assessment, Lindenmayer et al. salvage article, and Society for 

Conservation Biology report). 

Logging and Forest Health (Insects and Diseases)

One respondent mentioned that salvage timber harvest (or any logging for that matter) should not be used 

as justification for reducing insect and disease effects in timber stands. This comment also asked that we 

consider the large body of research indicating that logging, roads and other human-caused disturbance 

promotes the spread of tree diseases and insect infestations. 

Although not mentioned specifically in the comment, this sentiment is similar to what was embodied in a 

recent report called “Logging to control insects: the science and myths behind managing forest insect 

‘pests’” (Black 2005). 

The Black report might have been peer-reviewed (as based on its acknowledgments section). It was not 

published in a scientific journal or similar source. 

The United States Forest Service prepared a response to the Black report (USDA Forest Service 2006). It 

concluded that: 

“the Black report contains many examples of erroneous statements that are not even 

supported by the report’s cited literature. Professional foresters and land managers will 

be able to see this deficit. Unfortunately, this report may be viewed by others as refuting 

hundreds of published papers on effectively managing forest insects and diseases, which 

it does not. It will be more unfortunate when a poorly written but popular document such 

as the Black report is used as supporting information during litigation. During any

project analysis, such a document should be considered in the context of its biased 

authorship, limited credibility, and dubious scientific value. It is recommended that 

analysis teams refer directly to the appropriate refereed or peer-reviewed literature and 

site-specific data, rather than popular review reports such as this.” 

The US Forest Service response to the Black report was peer reviewed by professional entomologists and 

pathologists of the Pacific Northwest Region of the U.S. Forest Service. The Forest Service response to 

the Black report is not available to the wider scientific community from a credible science source such as 

a journal. 

We reviewed the Black (2005) report. In our judgment, the School Fire Salvage Recovery Project 

appropriately considers “insect and disease damage” by using the Scott Guidelines to predict tree 

mortality (Scott et al. 2002, 2003), and the Scott Guidelines incorporate three insects or diseases as 

predisposing factors influencing post-fire tree mortality: dwarf mistletoe occurrence, root disease 

occurrence, and bark beetle pressure within or adjoining the fire area (Scott et al. 2002, 2003). 

Using the Scott Guidelines for tree mortality estimation means that bark beetle activity in close proximity

to the salvage harvest areas was considered as one criterion (in addition to outward indicators of firstorder fire effects such as bark scorch, scorched or consumed foliage, and duff consumption at the tree 

base) when predicting tree mortality. 

Filip et al. (2007) Conifer Mortality Article

The Regional Forester of the Pacific Northwest Region of the U.S. Forest Service issued a policy letter in 

2005 (Goodman 2005) in which she attempted to clarify how tree mortality should be determined, 

specifically in the context of Regional Forester’s Plan Amendment #2 (commonly referred to as the 

Eastside Screens). This letter included an enclosure called “Understanding and Defining Mortality in

Western Conifers” (commonly referred to as the “conifer mortality” paper) (Schmitt and Filip 2005). 

3-16
Chapter 3 – Affected Environment and Environmental Consequences 

The conifer mortality paper was subsequently submitted to a scientific journal for peer review and 

eventual publication. After several rounds of peer review, the conifer mortality paper was published in a 

peer-reviewed journal and is available from a credible source (Filip et al. 2007). 

As was the case for many other items reviewed in this section, the conifer mortality article (Filip et al. 

2007) is a literature survey or synthesis; it does not report research results from a new or previously 

unpublished conifer mortality study. As such, it can be considered to be an opinion piece offering 

commentary by four scientists. 

We reviewed this article, and concluded that it applies directly to the DSEIS because it examines many of 

the fire effects that ultimately cause mortality for fire-injured conifers, and it discusses the fire effects that 

have been found to be most useful for predicting whether tree mortality is imminent (imminent is defined 

by this article as mortality occurring within 5 years of a fire). 

The Filip et al. (2007) article proposes that a “dead tree” designation is justified for most tree species 

when at least three of the four quadrants around the base of the root collar have cambium, inner bark, or 

phloem that are discolored or dead. This definition of a dead tree was adopted for the School DSEIS, 

although the DSEIS also includes mortality criteria other than the Filip et al. (2007) basal cambium

standard. 

Comments About the Scott Guidelines

Several respondents to the School Fire Salvage Recovery Project commented that the project’s basis for 

differentiating between dying and living trees is either questionable or untenable for scientific and other 

reasons. Often, these comments specifically addressed use of the Scott Guidelines (Scott et al. 2002, 

2003), which is a protocol used to evaluate fire-injured trees and to predict their survival for up to one 

year after the fire (beyond one year after fire for mature or overmature ponderosa pine and grand fir or 

white fir). 

The Scott Guidelines were apparently not peer-reviewed or published in a credible source. 

Waring Report. One respondent provided a report (prepared by Richard Waring) describing an 

evaluation of the Scott Guidelines for the Easy and High Roberts salvage sales on the Malheur National 

Forest. 

In this report, Waring concluded that using indirect indicators (such as the “crown and bole scorch” 

factors from the Scott Guidelines) to assess a tree’s predisposition to fire-caused mortality is 

inappropriate, and that direct measurement of a tree’s physiological processes (photosynthesis or 

transpiration) provides a better estimate of survival potential. 

The Waring report was apparently not peer-reviewed or published in a credible source. 

Waring’s report contends that measurements of water stress, using either a pressure chamber (Waring and 

Cleary 1967) or by collecting increment cores and then analyzing the sapwood’s relative water content 

(Waring and Running 1978), provides definitive estimates of tree health and survival potential. 

We disagree with Waring’s contention. Assessing the moisture status of fire-injured trees, such as 

measuring moisture stress with a pressure chamber (Waring and Cleary 1967) or by analyzing sapwood 

water content (Waring and Running 1978), indicates only that the tree’s vascular system was functional 

when the measurement is taken. It provides no assurance that the tree’s vascular system will continue to 

function in the future. 

Ryan (2000) studied the effects of varying levels of fire-caused cambium injuries on the water relations of 

ponderosa pine, and he found that crown scorch and basal girdling had only minor effects on summer 

water relations. 

3-17
Chapter 3 – Affected Environment and Environmental Consequences 

He found that trees in the 100% basal-heating class, which experienced cambium kill over an average of 

95% of the circumference at their base, had higher midday xylem pressure potentials (i.e., less stress) than 

non-girdled trees (Ryan 2000). This result was apparently due to phloem unloading that created a net 

water flow to the xylem tissue (Kozlowski 1992). 

For the 100% basal-heating class, half of the trees died quickly and the other half were still alive at the 

end of the second growing season (two growing seasons was the length of the study period). The six 

surviving trees suffered no apparent decline in water relations despite the fact that three of them had basal 

girdling affecting 96% or more of their circumference. 

If we assume that an extreme amount of basal girdling (96% or more of the circumference) will

eventually result in tree death, then one possible conclusion from this study is that the ultimate effect of 

extreme basal girdling was not exhibited within two growing seasons of the injury (Ryan 2000). 

Because mortality of basal-girdled trees can be delayed for several years (Agee 2003; Herman 1954;

Kaufmann and Covington 2001; Kolb et al. 2001; McHugh and Kolb 2003; Ryan and Amman 1994, 

1996; Sackett and Haase 1998; Swezy and Agee 1991; Thies et al. 2005, 2006; and Thomas and Agee 

1986), and because the Scott Guidelines specifically address this basal-injury issue, it is our judgment that 

the Ryan (2000) study supports the Scott Guidelines as a physiologically appropriate protocol for 

predicting tree mortality. 

Since the Ryan (2000) study also suggests that mortality of basal-girdled trees can be delayed for more 

than two growing seasons, it also refutes Waring’s contention that a one-point-in-time measurement of 

water stress (i.e., Waring and Cleary 1967) provides a better methodology than the Scott Guidelines for 

differentiating between living and dying trees. 

Relevance to the Forest Vegetation portion of the School Fire Salvage Recovery Project. In our 

judgment, it is appropriate that the School Fire Salvage Recovery Project adopted the Scott Guidelines to 

help predict which of the fire-affected trees might succumb to their injuries over a specific period of time 

(one year for all species and size classes except for mature and overmature ponderosa pine or grand fir 

and white fir, for which the time period is beyond one year after fire). 

The decision to use the Scott Guidelines to predict tree mortality follows established administrative policy

for the Pacific Northwest Region of the USDA Forest Service. Two administrative policy letters issued in

1998 (Devlin 1998a, 1998b) allow injured (dying) trees to be identified as dead if there is a professional 

determination that the trees will die within five years: 

“...dying trees can be counted as snags if there is a professional determination that the 

tree will definitely be dead within 5 years. Careful documentation is important. Trees 

that are weakened or defoliated from stress or disease, but which do not meet 

documented, professional criteria that they will definitely be dead in 5 years can not be 

counted as snags” (2430/2600 memo of September 10, 1998) (Devlin 1998a). 

“Rigorous application of a Forest Pest Management-written standard for identifying the 

level of infestation expected to be fatal, is sufficient to identify trees as dead. The 

standard should be included or referenced in the project planning documents” (2430/2600

memo of August 27, 1998) (Devlin 1998b). 

It is our judgment that using the Scott Guidelines (Scott et al. 2002, 2003), which were prepared by 

professional entomologists and a pathologist in the field of Forest Health Protection (e.g., Forest Pest 

Management), to determine the probability of tree survival is a “professional determination” as defined by

the Pacific Northwest Region (Devlin 1998a, 1998b). 

3-18
Chapter 3 – Affected Environment and Environmental Consequences 

Our judgment is supported by an administrative policy letter issued by the Pacific Northwest Regional 

Forester (Goodman 2005) in which she specifically referred to the Eastside Screens Oversight Team

letters (Devlin 1998a, 1998b), and she further stated that: 

“These ‘Scott’ guidelines establish a scientific basis for determining the relative 

probability of post-fire tree survival. They describe conditions that result in tree death or 

will lead to delayed tree mortality and hence, implicitly define ‘tree mortality.’” 

It is our judgment that this administrative policy and direction means that: 

(1) Administrative policy states that a “professional determination,” defined as a Forest Pest 

Management-written standard, is sufficient to identify fire-injured trees as dead (Devlin 1998a, 

1998b); 

(2) The Regional Forester states that the Scott Guidelines are a scientific (professional) determination of 

tree survival (Goodman 2005); 

(3) The Scott Guidelines were prepared by entomologists and a pathologist assigned to the Forest Health 

Protection group (this organization was previously called Forest Pest Management), so they qualify as 

a Forest Pest Management-written standard; 

(4) In the context of the Eastside Screens amendment to the Forest Plan, delayed tree mortality identified 

using the Scott Guidelines is considered as dead trees (Devlin 1998a, 1998b; Goodman 2005);

(5) Although dead trees are used to meet the snag and down wood requirements, most of the Eastside 

Screens amendment applies to live trees only (Norris 2005, USDA Forest Service 1995); 

(6) The Eastside Screens requirement in scenario A to “maintain all remnant late and old seral and/or 

structural live trees ≥ 21" DBH” (emphasis added) does not apply to dead trees; and 

(7) The Eastside Screens do require that snags ≥ 21" DBH be maintained, but not necessarily all of them

because snag retention is based on 100% potential population levels for primary cavity excavators. 

It is our observation that using the Scott Guidelines for the School Fire Salvage Recovery Project is 

consistent with similar projects in the Pacific Northwest Region of the USDA Forest Service; the Scott 

Guidelines have recently been used with the Flagtail, Monument, High Roberts, and Easy fire salvage 

projects (Malheur National Forest); the B&B complex (Deschutes National Forest); and the Fischer fire 

(Okanogan-Wenatchee National Forests) (Scott 2005). 

Critics of the Scott Guidelines contend that they overestimate tree mortality when compared with 

alternative tree mortality prediction models. Alternative models frequently mentioned by respondents to 

the School Fire Salvage Recovery Project are McHugh and Kolb (2003), Peterson and Arbaugh (1986),

Ryan and Reinhardt (1988), Stephens and Finney (2002), and Thies et al. (2006). 

In the context of the School Fire Salvage Recovery Project, we believe that the Scott Guidelines are more 

appropriate for predicting tree mortality than any of the alternative models individually. Our basis for this 

belief is that a comprehensive assessment of tree injury, and any associated prediction of fire-caused tree 

mortality, must consider the effect of fire injuries on the whole tree rather than just one or more of its 

parts (Connaughton 1936, Dieterich 1979, Fowler and Sieg 2004, Johnson and Miyanishi 2001, Lynch 

1959, Regelbrugge and Conard 1993, Ryan 1990, Salman 1934, Wagener 1961, Weatherby et al. 2001). 

As Jiminez (2004) observed: “It is possible for a tree to survive if the cambial tissue is destroyed on only 

a portion of its circumference (Peterson and Arbaugh 1986, 1989, Peterson and Ryan 1986, Brown and 

DeByle 1987, Durcey et al. 1996, McHugh and Kolb 2003). But the combined effects of root, crown, and 

stem damage may kill a tree, even if the stem itself is not completely girdled (Ryan 2000, Dickinson and 

Johnson 2001, McHugh and Kolb 2003).” 

3-19
Chapter 3 – Affected Environment and Environmental Consequences 

It is well established in the scientific literature that a comprehensive model of post-fire tree mortality

should account for injuries to fine roots caused by smoldering combustion during duff consumption (e.g., 

Brown et al. 1991, Fowler and Sieg 2004, Hille and Stephens 2005, Johnson et al. 2001, Miller 2000, 

Miyanishi 2001, Miyanishi and Johnson 2002, Pyne et al. 1996, Ryan and Frandsen 1991, Stephens and 

Finney 2002, Swezy and Agee 1991, and others). 

Cambial damage accompanying surface fire does not account for fine-root injury because surface fires are 

rarely of sufficient duration to cause this type of tree injury in the absence of smoldering combustion 

(Peterson and Ryan 1986).

Prescribed Fire Versus Wildfire. Some tree mortality prediction models have been developed using 

data from prescribed fires only (Scott et al. 2002). Since the School Fire was a wildfire, it might not be 

appropriate to use a mortality-prediction model based exclusively on prescribed fire effects. 

A primary objective of prescribed fire is to modify the existing fuel loading of an area by igniting fire 

during weather conditions when fire behavior is expected to remain within designated parameters 

(Stratton 2004). The fire behavior parameters are designed to meet specific fire effects objectives such as 

minimizing unwanted tree mortality or unacceptable amounts of mineral soil exposure and associated 

erosion. 

Fire effects are managed by selecting favorable weather conditions for prescribed fire. Prescribed fire is 

generally conducted under relatively benign weather conditions (e.g., 70° F. temperature, high relative 

humidity, low wind speeds, etc.) varying dramatically from late-summer conditions when the School Fire 

occurred (e.g., temperatures in the high 90s, low relative humidity, moderate or high wind speeds, etc.). 

Unlike certain other regions of the country, prescribed fire in the Blue Mountains is typically

implemented during time periods outside of the normal wildfire season (prescribed fire is implemented in 

April-May or October, whereas wildfire occurs in July-September). These timing differences provide 

another indication that prescribed fire differs from wildfire. 

When comparing prescribed fire and wildfire, differing weather conditions produce differing fire 

behavior, which in turn produces differing fire effects. Since tree mortality prediction relies on some

combination of fire effects (to the crown, stem and roots), the comparatively narrow range of fire effects 

for prescribed fire could limit a model’s applicability for the broad range of fire effects associated with 

late-summer wildfires (Bevins 1980). 

Because the School Fire was a late-summer wildfire with fire effects exceeding those typically produced 

by prescribed fire, it is our judgment that a tree mortality prediction model developed exclusively from

prescribed fire data is not appropriate for use with the School Fire. 

Our rationale for selecting the Scott Guidelines for use with the School Fire Salvage Recovery Project, 

rather than one or more of the suggested alternatives (McHugh and Kolb 2003, Peterson and Arbaugh 

1986, Ryan and Reinhardt 1988, Stephens and Finney 2002, and Thies et al. 2006), is explained below. 

1. The McHugh and Kolb (2003) model was developed using data from three wildfires in northern 

Arizona. It includes one conifer species (ponderosa pine) and it relates predicted tree mortality to two 

fire effects: total crown damage (scorch plus consumption), and bole char severity. 

It is our judgment that the McHugh and Kolb (2003) model is inappropriate for use with the School 

Fire Salvage Recovery Project for four reasons (table F-1): 

a. Its geographical scope is limited (northern Arizona); 

b. It assesses the crown and stem systems only (no direct consideration of the root system); 

c. Its tree species coverage is limited (ponderosa pine only); and 

3-20
Chapter 3 – Affected Environment and Environmental Consequences 

d. It lacks a measure addressing fine-root damage or basal stem girdling at the root crown (Ryan and 

Frandsen 1991). 

2. The Peterson and Arbaugh (1986) model was based on tree survival patterns after late-summer 

wildfires in the northern Rocky Mountains. It includes two conifer species (Douglas-fir and 

lodgepole pine) and it relates predicted tree mortality to a wide variety of tree characteristics and fire 

effects: tree diameter, tree height, crown diameter and ratio, bark thickness, scorch height, crown 

scorch volume, basal scorch, bark char, and insect damage. 

Although the variety of predictive factors included with this model is impressive, it is our judgment 

that the Peterson and Arbaugh (1986) model is inappropriate for use with the School Fire Salvage 

Recovery Project for three reasons (table F-1): 

a. Its geographical scope is limited (northern Rocky Mountains of Montana, northwestern 

Wyoming, and Idaho); 

b. It assesses the crown and stem systems only (no direct consideration of the root system); and

c. Its tree species coverage is limited (Douglas-fir and lodgepole pine only). 

3. The Ryan and Reinhardt (1988) model was developed to predict tree mortality following prescribed 

fires in Idaho, Montana, Oregon and Washington. It includes seven conifer species and it relates 

predicted tree mortality to two factors: bark thickness, and crown volume killed by fire. 

Several fire effects and fire behavior computer software applications have adopted the Ryan and 

Reinhardt (1988) model to predict post-fire tree mortality, thus making it widely available to fire 

analysts. It has been used to predict tree mortality in applications such as the “First Order Fire Effects 

Model” (FOFEM) (Reinhardt et al. 1997) and “BehavePlus” (Andrews and Bevins 1999). 

The Ryan and Reinhardt (1988) equations are based on the assumption that differences in fire-caused 

tree mortality can be accounted for primarily by differences in bark thickness and the proportion of 

tree crown killed (Reinhardt et al. 1997). This model mainly addresses first-order fire effects – those 

occurring as a direct result of the fire combustion process (Reinhardt et al. 2001). 

The authors of the Scott Guidelines used the Ryan and Reinhardt (1988) model when developing their 

rating procedure, in addition to other models and criteria that better account for the totality of fire 

effects (including root damage). It is well established that accurate predictions of tree mortality

should account for injuries to all of the primary physiological systems of a tree: the crown, stem and 

roots (e.g., Fowler and Sieg 2004, Johnson and Miyanishi 2001, Ryan 1990, Wagener 1961). 

It is our judgment that the Ryan and Reinhardt (1988) model is inappropriate for use with the School 

Fire Salvage Recovery Project for three reasons (table F-1): 

(1) Its geographical scope is limited because the Oregon data came from the western or northern 

Cascade Mountains, or from the southwestern portion of the state near Medford; 

(2) It assesses the crown and stem systems only, whereas the Scott Guidelines account for injuries to 

all three physiological systems (crown, stem, and roots) (Ryan and Frandsen 1991); and 

(3) It was developed using prescribed fire data (see discussion above about the differences between 

prescribed fire and wildfire). 

4. The Stephens and Finney (2002) model was developed to predict tree mortality following prescribed 

fire in the southern Sierra Nevada Mountains of California. It includes five conifer species and it 

relates predicted tree mortality to four factors: tree diameter, percent crown volume scorched, forest 

floor (duff) consumption, and crown scorch height. 

3-21
Chapter 3 – Affected Environment and Environmental Consequences 

It is our judgment that the Stephens and Finney (2002) model is inappropriate for use with the School 

Fire Salvage Recovery Project for three reasons (table F-1): 

a. Its geographical scope is limited (southern Sierra Nevada Mountains); 

b. Its tree species coverage is limited (of the five conifers included in this model, only ponderosa

pine occurs in the School Fire area); and 

c. It was developed using prescribed fire data (see discussion above about the differences between 

prescribed fire and wildfire). 

5. The Thies et al. (2006) model was developed to predict tree mortality following prescribed fire in the 

southern Blue Mountains of northeastern Oregon. It includes one tree species (ponderosa pine) and it 

relates predicted tree mortality to five factors: live crown proportion, needle scorch proportion, bud

kill proportion, basal char severe, and bole scorch proportion. 

The size class variation for trees included in this study is quite limited due to similar stand replicates: 

pre-treatment tree diameter at breast-height (DBH) for control units averaged 28.4 cm (11.2 inches), 

and the diameters for trees in the fall and spring burning treatments averaged 26.6 cm (10.5 inches) 

and 27.4 cm (10.8 inches), respectively.

The authors of this study also caution about extrapolating its results, and using its mathematical 

models, beyond the geographical area of the sampled stands or with tree species other than ponderosa 

pine, until datasets are produced to validate the models for other geographical areas or tree species. 

It is our judgment that the Thies et al. (2006) model is inappropriate for use with the School Fire

Salvage Recovery Project for six reasons (table K-1): 

(1) Its geographical scope is limited (a specific set of sampled stands in the southern Blue 

Mountains); 

(2) Its ecological scope is limited (sampled stands are in the ponderosa pine potential vegetation 

series, and only 1.6% of the School Fire area is included in this series; see table B-1); 

(3) Its tree species coverage is limited (ponderosa pine only); 

(4) The tree-size variation included in the model-development dataset (a range of 10.5 to 11.2 inches 

average stand diameter across all replicates) is limited when compared with tree-size variation 

encountered in the School Fire area; 

(5) It assesses the crown and stem systems only (no direct consideration of the root system); and

(6) It was developed using prescribed fire data (see discussion above about the differences between 

prescribed fire and wildfire). 

Summary: The Scott Guidelines provide a methodology for predicting the relative probability of 

survival for fire-injured trees growing on a wide variety of site conditions, exposed to varying levels of 

pre-fire factors that can predispose a tree to fire-induced mortality depending upon their severity or 

magnitude (occurrence of dwarf mistletoe, root disease, and bark beetles), and experiencing widely

varying levels of first-order fire effects to their crowns, stems and roots. 

The possible combinations of these factors are almost limitless, leading inevitably to a decision to develop 

a prediction system relating site and tree factors (explanatory variables) to some type of probabilistic 

estimate of tree mortality. This regression or modeling approach is commonly used in science, 

particularly for complex situations such as wildland ecosystems (Rubinfeld 2000). 

3-22
Chapter 3 – Affected Environment and Environmental Consequences 

Since it is not possible to account for every combination of variables that could potentially result in tree 

death, there will always be some amount of uncertainty associated with a probabilistic rating system such 

as the Scott Guidelines. 

This same statement about uncertainty applies to the alternative modeling approaches suggested by Dr. 

Royce and other respondents to the School Fire Salvage Recovery Project (i.e., McHugh and Kolb 2003, 

Peterson and Arbaugh 1986, Ryan and Reinhardt 1988, Stephens and Finney 2002, and Thies et al. 2006) 

because they provide an estimate (prediction) of tree mortality or tree survival, not an absolute or 

definitive determination 

Table 3-1. Comparison of Post-Fire Tree Mortality Models. 

McHugh

and Kolb 

(2003) 

Peterson 

and 

Arbaugh 

(1986) 

Ryan and 

Reinhardt 

(1988) 

Scott et al. 

(2002, 2003)

Stephens 

and Finney 

(2002) 

Thies et al. 

(2006) 

Geographical 

area included 

Northern

Arizona 

Idaho, 

Montana, 

northwestern

Wyoming 

Idaho, 

Montana, 

western and

southwestern

Oregon, 

Washington

Northeastern

Oregon (Blue 

and Wallowa 

Mountains) 

Central 

California 

(Sequoia NP) 

Northeastern

Oregon

(southern 

Blue

Mountains) 

Tree species 

included 

Ponderosa 

pine 

Douglas-fir 

Lodgepole

pine 

Douglas-fir 

Western larch

Engelmann 

spruce 

Lodgepole

pine 

Subalpine fir 

Western red

cedar 

Western 

hemlock 

Ponderosa 

pine 

Douglas-fir 

Engelmann 

spruce 

Lodgepole

pine 

Western larch

Grand/white 

fir 

Subalpine fir 

Western 

white pine 

White fir 

Sugar pine 

Ponderosa 

pine 

Incense cedar 

Giant sequoia 

Ponderosa 

pine 

Fire type used 

for model 

development 

Wildfire

(spring,

early 

summer, 

late 

summer) 

Wildfire (late 

summer) 

Prescribed fire

(May through 

October)

Wildfire (mid 

to late 

summer) 

Prescribed

fire (fall) 

Prescribed

fire (spring 

and fall) 

Tree mortality 

prediction 

factors or 

variables used

Crown 

damage 

Bole char 

severity 

Crown scorch

Basal scorch

Bark char

ratio

Bark

thickness 

Insect damage 

Crown 

volume killed

Bark

thickness 

Season of fire

Pre-fire vigor, 

growth rate, 

site quality 

Down woody 

material 

Dwarf

mistletoe 

occurrence 

Root disease 

DBH 

Percent crown 

volume 

scorched

Duff

consumption 

Crown scorch

height

Live crown 

proportion 

Needle scorch 

proportion 

Bud kill 

proportion 

Basal char 

severe 

Bole scorch

proportion 

3-23
Chapter 3 – Affected Environment and Environmental Consequences 

McHugh

and Kolb 

(2003) 

Peterson 

and 

Arbaugh 

(1986) 

Ryan and 

Reinhardt 

(1988) 

Scott et al. 

(2002, 2003)

Stephens 

and Finney 

(2002) 

Thies et al. 

(2006) 

occurrence 

Bark beetle 

pressure 

Crown 

volume 

scorch

Bole 

scorch/char 

Total scorch

height

Duff

consumption 

Bole/root char 

at ground

surface 

Tree 

physiological

systems 

included 

Crown

Stem/bole 

Crown

Stem/bole 

Crown

Stem/bole 

Crown

Stem/bole 

Roots 

Crown

Stem/bole 

Roots 

Crown

Stem/bole 

Considers 

insect or 

disease agents

No Yes No Yes No No

Other

comments 

Widely used

for fire effects 

modeling 

(FOFEM, 

BehavePlus,

etc.) 

Tree-size

variation 

included in

study

replicates was 

very narrow 

Sources: McHugh and Kolb (2003), Peterson and Arbaugh (1986), Ryan and Reinhardt (1988), Scott et al. 

(2002, 2003), Stephens and Finney (2002), and Thies et al. (2006).

3-24
Chapter 3 – Affected Environment and Environmental Consequences 

HYDROLOGY/WATER QUALITY

Beschta et al. Reports 1995, 2004

Relevance to the Hydrologic Analysis. Both the 1995 and 2004 documents were reviewed. Concerns 

were expressed regarding the sensitivity of riparian areas and recovery rates of stream ecosystems from

fire effects, including providing for structural components for their recovery. Design features (Chapter 2, 

Table 2-3) for the proposed alternatives include designation of PACFISH RHCAs which provide 

protection to near channel areas by precluding harvest. Existing structural components would remain 

available to stream ecosystems and recovery rates would not be slowed. Other design features and BMPs 

have been identified to control and minimize effects of proposed actions, including temporary road 

construction and road use. 

Everett, R. 1995, Memorandum to John Lowe, Review of Beschta Document.

Relevance to the Hydrologic Analysis. Dr. Everett states that some studies have shown increased soil 

disturbance and erosion following post fire logging. He cites literature that was reviewed, and in one case 

cited (Klock, 1975) in the hydrologic effects analysis. Soil disturbance and erosion is expected to 

increase following salvage logging, based on the hydrologic analysis. The analysis shows that increased 

erosion due to salvage and related activities would be small relative to increases resulting from the School 

Fire and would be of relatively short duration. Design features (Chapter 2, Table 2-3) and best 

management practices have been identified which would control and limit the magnitude of ground 

disturbance and erosion in action alternatives. 

American Lands Alliance, After the Fires do No Harm 

Relevance to the Hydrologic Analysis. This publication was reviewed. Concerns regarding riparian 

areas, recovery of stream ecosystems, and providing for structural components for that recovery were 

similar to those expressed in the Beschta et al. reports. The discussion for Beschta et al. pertains to the 

ALA report. 

McIver, James D., Starr, Lynn, tech. eds. 2000 

Relevance to the Hydrologic Analysis. McIver and Starr found 9 studies that looked 

erosion/sedimentation or water yield, two without an unlogged wildfire control. Differing results for the 

study parameters appear to be due to variability between sites, treatments, and weather patterns and does 

not reflect scientific controversy. Summarized results are consistent with other literature reviewed 

during the preparation of the EIS and was used in the discussion of environmental effects. 

Other sources cited in comments

Relevance to the Hydrologic Analysis. Several sources were cited in comments which discussed 

elevated erosion from roads, effects of increased sediment loads and peakflows on channel morphology, 

and peakflow effects of green tree logging and road construction. These sources are within the body of 

scientific literature that informs hydrologic analysis. Other studies and especially the most recent 

literature available pertaining to post fire conditions and fire salvage logging were used in the analysis for 

this EIS. Erosion from roads post fire and from road use during proposed salvage logging was discussed 

and extensively analyzed in the hydrologic effects analysis. Peakflow and channel morphology changes 

were also discussed and analyzed.

3-25
Chapter 3 – Affected Environment and Environmental Consequences 

FISHERIES

As noted by Bisson et al. (2003), wildfire, fuels management and fire suppression activities can all alter 

aquatic ecosystems, and recent developments in disturbance ecology have led conservation biologists and 

ecologists to recognize that landscapes are dynamic and should be managed in that context to restore 

natural processes to aquatic and terrestrial where they are operating outside the natural range of variability

(Rieman et al.. 2003; Karr et al.; Everett et al. 1995). There is recognition by some supporters of passive 

recovery that active management following a fire could still be appropriate under certain circumstances. 

Beschta et al. 1995, for example, recommended removal of roads at hydrologic risk following fires to 

help to restore hydrologically appropriate drainage patterns at watershed-scale, as well as restore withinchannel connectivity. As Bisson et al. (2003) noted, each fuels treatment or response to wildland fire is 

unique in its ecological circumstances and in its social context. As Rieman et al. (2003) noted, there are 

no universal answers that would apply to fire and fuels conditions on every forest and watershed in the 

western United States, given the ecological variability across the landscape that shapes the debate at local 

scales. 

Beschta et al. Reports; Everett et al. 1995; McIver and Starr 2000, 2001

One or the other of the Beschta reports was mentioned by numerous respondents during the public 

scoping phase of the School Fire Salvage Recovery Project. The original Beschta Report (1995) was 

commissioned by Pacific Rivers Council. A similar version (Beschta et al. 2004) was subsequently

published in a peer-reviewed journal called Conservation Biology. Beschta et al. (2004) was published in 

the Forum section of the Journal of Conservation Biology, which is a section of the journal reserved for 

commentary, policy advocacy and related articles based on scientific research and professional 

observation. In their 2004 article, they cited McIver and Starr (2000) (discussed below) in support of 

their recommendations. McIver and Starr (2000, 2001) reviewed and discussed commentaries by Beschta 

et al. (1995) and Everett et al. (1995). They noted that Everett et al. (1995) were more oriented towards 

active management strategies and case-by-case evaluations of salvage logging, whereas, Beschta et al. 

(1995) focused on re-establishment of natural disturbance regimes and supported post-fire logging, 

reseeding and replanting only under limited circumstances. The fisheries analysis assessed the effects to 

aquatic habitats and fish species from both active management alternatives and from natural disturbance 

processes associated with the No Action alternative 

Both the 1995 and 2004 documents authored by Beschta and his associates were reviewed. Concerns 

were expressed regarding the sensitivity of riparian areas and recovery rates of stream ecosystems from

fire effects, including providing for structural components for their recovery. Design features (Chapter 2, 

Table 2-3) for the proposed alternatives include designation of PACFISH RHCAs which provide 

protection to near channel areas by precluding harvest. Existing structural components would remain 

available to stream ecosystems and recovery rates would not be slowed. Other design features (Chapter 2, 

Table 2-3) and BMPs have been identified to control and minimize effects of proposed actions on 

sediment delivery and large wood recruitment, including temporary road construction and temporary use 

of pre-existing unauthorized roads, road use and hazard tree management. 

When US Forest Service research scientists (Everett et al. 1995) reviewed the 1995 report by Beschta and 

his associates, they noted that forest ecosystems and fires as they have operated in recent decades 

encompass a wide range of variability and varying degrees to which disturbance processes and regimes 

have been altered, and that this variability points to the need for site-specific plans addressing each 

salvage situation on a case-by-case basis. This report, like Beschta et al. (1995), was categorized by

McIver and Starr (2000, 2001) as commentary by scientists. McIver and Starr (2000) was explicitly

instigated by the exchange of views in the two 1995 commentaries, and was published as a Forest Service 

3-26
Chapter 3 – Affected Environment and Environmental Consequences 

technical report following peer review. They compiled and evaluated available information published 

through August 1998 on the subject of post-fire salvage harvest on erosion, sediment production, and

sediment delivery. McIver and Starr (2001) was essentially the same report, peer-reviewed and published 

in a non-Forest Service scientific journal. 

McIver and Starr (2000, 2001) were able to find only seven scientific studies in the western United States 

which directly investigated effects of post-fire salvage harvest on erosion, sediment movement

(sedimentation) and sediment delivery (to stream channels), with controls for comparison of effects of 

salvage following fire. During their review and annotation of those seven studies, they found that four of 

the seven studies detected increased erosion and sediment movement following post-fire logging. Two 

studies, Helvey (1980) and Helvey et al. (1985) in the eastern Cascades of Washington, detected 

increased sediment yields with post-fire logging relative to sediment yields generated by the fire itself. 

Chou et al. (1994b) found increased sedimentation from post-fire salvage logging in steep basins. Klock 

(1975) evaluated the relative effects of five different logging systems on soil erosion during post-fire 

salvage operations. He found that erosion effects varied depending on the method, and that erosion was 

highest with tractor logging, with decreasing impacts respectively with cable and helicopter logging 

Maloney et al. (1995) monitored sediment transport following post-fire salvage on Boise National Forest. 

That study detected significant sediment delivery only where a skid trail crossed a class II (nonanadromous perennial stream). Other than at that one site, Maloney et al. (1995) found no managementrelated increases in erosion or sediment transport when best management practices (BMPs) were 

implemented. They found that, provided that appropriate BMPs were applied, ground-based logging and 

new temporary roads did not increase erosion or sediment transport. Potts et al. (1985) found that 

modeling results indicated that sediment yield from post-fire logging, though measurable, was still less 

than sediment yields from the fire alone. Potts et al. (1985) also noted that sediment yield increases were

only severe when associated with steep slopes and large fires. In the remaining study, Chou et al. (1994a) 

was unable to detect management-related differences in sediment movement due to high variance in 

logging intensity and timing of implementation among sites logged, despite ecological similarities among 

sites compared. 

McIver and Starr (2001a) were unable to find any studies that distinguished the effects of post-fire road 

building and use per se, but allowed that roads likely contribute as much to erosion in a post-fire setting 

as they do in an unburned environment, given findings by Helvey (1980) following the Entiat fire in the 

eastern Washington Cascades (McIver and Starr 2000, 2001a). 

Based on review of those seven studies, and a couple studies done without controls, McIver and Starr 

(2000, 2001) concluded that the immediate environmental effects of post-fire logging in terms of soil 

disturbance leading to erosion and excess sedimentation to streams are variable and depend on a wide 

variety of factors such as fire severity, slope steepness, soil texture and composition, the presence of preexisting roads, construction of new roads, timber harvest systems, and post-fire weather conditions. 

Because scientific information about salvage harvest following wildfire was so sketchy, they urged 

caution and encouraged the use of adaptive management by approaching post-fire activities as 

opportunities for learning which could add to the existing knowledge base on the effects of management 

in a post-fire environment (McIver and Starr 2000, 2001a). 

Relevance to the Fisheries portion of School Fire Salvage Recovery Project. Beschta et al. 1995) and 

Beschta et al. 2004, together with Everett et al. 1995 and McIver and Starr (2000, 2001) were reviewed. 

Concerns were expressed in both Beschta articles regarding the sensitivity of riparian areas and recovery

rates of stream ecosystems from fire effects, including providing for structural components for their 

recovery. The no action alternative (Alternative A) would satisfy most or all of the Beschta et al. (1995, 

2004) recommendations related to logging, erosion, and sedimentation impacts to aquatic habitats because 

it would not harvest trees in areas with steep slopes, sensitive soils, or severe fire intensity; it would not 

3-27
Chapter 3 – Affected Environment and Environmental Consequences 

harvest trees in riparian areas; it would not build roads (whether temporary or permanent) to access 

harvest units; it would not harvest live trees (regardless of how tree mortality was determined). 

Consistent with concerns expressed by Beschta et al. (1995) and Beschta et al. (2004), the sensitivity of 

riparian areas and recovery rates of stream ecosystems from fire effects, including providing for structural 

components for their recovery were also recognized in development of both action alternatives. Design 

features (Chapter 2, Table 2-3) for the proposed alternatives include protection of PACFISH RHCAs and 

stream-floodplain connectivity for PACFISH Category I, II and 4 streams by applying non-harvest 

buffers with additional operational restrictions, and go beyond PACFISH requirements by providing 

buffers and operational restrictions to protect ephemeral draws upslope of intermittent drainages, even 

though these were places the team did not feel met criteria for Category 4 RHCAs even in the post-fire 

environment. Structural components in these buffers would remain available to stream ecosystems and 

recovery rates would not be slowed. Road use will be restricted whenever risk of erosion and sediment 

delivery is high due to soil moisture, and dust control measures will help prevent dry ravel and sediment 

movement during dry conditions. Other design features (Chapter 2, Table 2-3) and BMPs have been 

identified to control and minimize effects of proposed actions including temporary road construction. 

Although Maloney et al. (1995) detected significant sediment delivery in Idaho where a skid trail crossed 

a class II (non-anadromous perennial stream), School Fire Salvage Recovery Project design features 

expressly prohibit placement of skid trails across any drainages, even ephemeral draws, and require full 

suspension across such sites. 

Some of the recommendations provided by Beschta et al. (1995 and 2004) are incompatible with the 

purpose and need of the School Fire Salvage Recovery Project, which is focused solely on recovery of 

economic value, consistent with laws relevant to fisheries resources on NFS lands in the Tucannon

subbasin, such as Section 7 of the Endangered Species Act and the National Forest Management Act. 

Accordingly, action alternatives that meet the specified purpose and need are unable to fully adopt 

recommendations offered by Beschta et al. (1995, 2004), and alternatives were analyzed to address those 

concerns site-specifically. 

Even so, both of the action alternatives (Alternatives B and C) would satisfy some but not all of the above 

recommendations: Regardless of whether the no action or one of the action alternatives is selected, no 

tree harvest would take place in riparian areas and post-suppression rehabilitation of firelines has already

taken place, as has curtailment of livestock grazing until soils and vegetative recovery are determined to 

be sufficient to support resumed grazing. No construction of near- or instream structures are 

contemplated as post-fire restoration actions, nor is the seeding of non-native species for erosion control, 

consistent with recommendations from Beschta and his associates. 

As Everett et al. (1995) acknowledged, some studies have shown increased soil disturbance and erosion 

following post-fire logging. They cite literature that was reviewed, and in one case cited (Klock, 1975). 

Soil disturbance and erosion are expected to increase following salvage logging, based on the hydrologic 

analysis for School Fire EIS. The hydrologic analysis also shows that increased erosion due to salvage 

and related activities would be small relative to increases resulting from the School Fire and would be of 

relatively short duration. Design features (Table 2-3) and best management practices have been identified 

which would control and limit the magnitude of ground disturbance and erosion, and minimize the risk of 

accelerated sediment delivery in action alternatives. 

Contrary to recommendations in the Beschta (1995, 2004) articles, the No Action alternative would not 

act to eliminate unauthorized roads present on the pre-fire landscape, however, such action would occur 

under both action alternatives and into the foreseeable future, consistent with recommendations provided 

by Beschta and his associates. Remedial action to eliminate unauthorized roads in the near future is most 

likely to be achieved through selection of an action alternative that meets the economic purpose and need 

for the project, and which could generate revenue to fund removal of some or most of the unauthorized 

roads within the next 5 years. McIver and Starr (2000; 2001) noted that even when the primary objective 

3-28
Chapter 3 – Affected Environment and Environmental Consequences 

of post-fire logging has been economic, often other objectives (e.g. erosion control) have also been 

achieved. In the case of School Fire Salvage Recovery Project, action alternatives were constructed with 

such “other” objectives in mind, allowing for natural rates of recruitment of large wood to deficient 

streams, reducing cumulative surface erosion from fire and salvage activities to near-natural levels 

through combinations of design features (Chapter 2, Table 2-3) and post-harvest decommissioning of 

some unauthorized roads in existence prior to the fire, facilitated by aspects of timber sale layout and 

contract specifications. McIver and Starr’s (2000, 2001) summarized results and relevant studies they

cited are consistent with other literature reviewed and used during the preparation of the Fisheries 

Analysis, and effects identified in the Fisheries Specialist Report are within the range of effects noted in 

literature reviewed by McIver and Starr. 

American Lands Alliance (ALA) Report(s) 2005-“After the Fires”), 2003-“Salvaging 

Timber, Scuttling Forests” 

The ALA “After the Fires” (2005) article was mentioned by numerous respondents during the public 

scoping phase of the School Fire Salvage Recovery Project. Concerns raised in the article relevant to 

aquatic ecosystems include loss of biological legacies (downed wood) and sediment runoff into streams. 

The article draws extensively from policy recommendations contained in the recent Beschta et al. (2004) 

article in Conservation Biology, and cites literature already considered, specifically McIver and Starr 

(2000), Beschta et al. (1995), Everett et al. (1995), as well as a variety of literature on general ecological 

processes related to landscape disturbance and recovery. An earlier more detailed article produced by 

Ingalsbee (2003) for the American Lands Alliance expressed similar concerns for additive effects of 

salvage logging on aquatic ecosystems with respect to sediment delivery, large wood recruitment and 

function. The Ingalsbee (2003) article was mentioned by one commenter. It cites relevant literature 

already discussed, specifically Helvey (1980), McIver and Starr (2000), Beschta et al. (1995), Everett et 

al. (1995) and Klock (1975). 

Relevance to the Fisheries portion of School Fire Salvage Recovery Project. The ALA “After the 

Fires” report was reviewed, and the 2003 article by Ingalsbee which contained notably more citations was 

reviewed. The articles have relevance to School Fire Salvage Recovery project. In the professional 

judgment of the fisheries biologist, the action alternatives include design features (Chapter 2, Table 2-3) 

and mitigations which address concerns for aquatic ecosystems as expressed by both of the ALAsponsored articles and the level of anticipated effects from active management are within the range of 

effects already noted in the literature. Relevant literature cited in the ALA (2003) report by Ingalsbee and 

Beschta et al. (2004) cited in the ALA (2005) article were previously assessed. Earlier comments on 

literature sources they cited are applicable to concerns raised in the two ALA articles. The earlier 

discussions above for Beschta et al. (1995, 2004), Everett et al. (1995), McIver and Starr (2000) and their 

review of relevant studies also pertain to the ALA reports. 

Other literature cited by Ingalsbee regarding post-fire structure, function and processes in the aquatic 

environment is consistent with effects of alternatives and literature cited in the Fisheries Effects Analysis. 

Lindenmayer Salvage Harvesting Policies Article

The journal Science published a short, one-page article on February 27, 2004 (Lindenmayer et al. 2004). 

Its position is that (1) salvage harvest undermines the ecosystem benefits of major disturbances; (2) 

removing biological legacies (large wood) can negatively affect many taxa; (3) salvage harvest can impair 

ecosystem recovery; and (4) some taxa might be maladapted to the interactive effects of two disturbance 

events in rapid succession (fire and salvage logging). 

The article was published in the Policy Forum section of Science, which is a section of the journal 

reserved for articles of commentary, policy advocacy and related articles based on scientific research and 

professional observation on subjects of scientific interest. The discussion for Beschta et al. (1995, 2004), 

3-29
Chapter 3 – Affected Environment and Environmental Consequences 

McIver and Starr (2000, 2001), Everett et al., and ALA (American Lands Alliance 2005) reports also 

pertains to Lindenmayer et al. (2004) and is hereby incorporated by reference. 

Relevance to the Fisheries portion of School Fire Salvage Recovery Project. The Lindenmayer et al. 

(2004) article was review. School Fire Salvage Recovery Project includes an alternative that would react 

to the burned watersheds in a manner similar to what is recommended by Lindenmayer et al. (2004) – the 

No Action alternative. Both action alternatives include design features (Chapter 2, Table 2-3) and 

mitigations which effectively address all four of the concerns listed by Lindenmayer and his associates as 

they pertain to listed, sensitive and management indicator fish species and their habitats. Most of the 

habitat indicators selected for analysis were based on primary and secondary habitat factors limiting 

recovery of bull trout, steelhead and Chinook salmon in the affected subwatersheds, which were 

previously identified in the Recovery Plan for listed species in southeast Washington (Snake River 

Salmon Recovery Board. 2005). Analysis of selected indicators discussed changes to indicators in terms 

of post-disturbance processes and ecosystem benefits, the degree to which biological legacies will be 

affected (Large Wood recruitment and retention), potential for impairment of aquatic ecosystem recovery, 

and resiliency of the respective sensitive, listed and management indicator fish species in the Upper 

Tucannon and Upper Pataha watersheds to two disturbance events, School Fire followed by either of the 

action alternatives. 

Karr et al. 2004

The scientific journal BioScience, published a five-page peer-reviewed article by Karr et al. (2004) in the 

Forum section of the journal, which is reserved for articles of commentary, policy advocacy and related 

articles based on scientific research and professional observation on subjects of scientific interest. The 

article identified concerns for salvage logging impacts on aquatic ecosystems similar to those noted in

commentary articles previously discussed, and cites several of those articles in support of their concerns 

and recommendations, including Beschta et al. 1995, 2004; Lindenmayer et al. 2004) and presented 

recommendations to curb ecological damage from post-fire salvage logging, which were very similar to 

recommendations offered by Beschta et al. (1995, 2004). 

Other literature cited by Karr et al. regarding post-fire structure, function and processes in the aquatic 

environment is consistent with effects of alternatives and literature cited in the Fisheries Effects Analysis. 

Other sources cited in comments

Relevance to the Fisheries portion of School Fire Salvage Recovery Project. Several sources were

cited in comments which discussed elevated erosion from roads, effects of increased sediment loads on 

aquatic biota, pool development, temperature and ineffectiveness of BMPs to protect salmonids from

cumulative degradation from roads and logging. These sources are within the range of scientific literature 

that informed the fisheries analysis. Other studies and especially the most recent literature available 

pertaining to post-fire conditions, erosion, sediment delivery and transport, and fire salvage logging were 

used in the analysis for this EIS. Erosion from roads post-fire and from road use during proposed salvage 

logging, including effectiveness of BMPs was discussed and extensively analyzed in the hydrologic 

effects analysis. Peakflow and channel morphology changes were also discussed and analyzed. Findings 

from the hydrology analysis informed the fisheries effects analysis. Effects to salmonids and other 

sensitive fish species, temperature and pool development from the fire itself and the additive effects of 

logging, road construction and road use were evaluated. 

FUELS - FIRE HAZARD

Beschta et al. Reports

One or the other of the Beschta reports was mentioned by numerous respondents during the public 

scoping phase of the School Fire Salvage Recovery Project. These respondents generally advocated that 

3-30
Chapter 3 – Affected Environment and Environmental Consequences 

natural recovery of burned landscapes, with little or no human intervention, is the optimal policy for 

public forests, and that this policy is supported by literature other than Beschta et al. (1995, 2004) such as 

American Lands Alliance (2005), DellaSala et al. 2006, Donato et al.. 2006, Lindenmayer et al. (2004), 

McIver and Starr (2000, 2001), and others. 

When US Forest Service research scientists reviewed the original Beschta report, they concluded that it 

was biased toward a custodial (hands off) approach, and that it is generally accepted in the science 

community that limiting post-fire management to just a single approach (whether custodial or 

commodity) is inappropriate because forest sites encompass a wide range of variability, and this 

variability points to the need for site-specific plans addressing each salvage situation on a case-by-case 

basis (Everett 1995). 

Relevance to the Fire Hazard portion of School Fire Salvage Recovery Project. The Beschta Report 

(Beschta et al. 1995) and the Beschta journal article (Beschta et al. 2004) was reviewed. The School Fire 

Salvage Recovery Project includes an alternative (the No Action alternative) that would react to the 

burned forest in a manner similar to what is recommended by Beschta et al. (1995, 2004). From a fire 

hazard risk and fuels management perspective, we concur that making fire prevention a high priority

management goal is a commitment to continuous fire suppression and fails to capitalize on the selfrepairing and self-perpetuating capabilities of ecosystems. It is not a matter of if another fire will occur in 

this fire prone ecosystem, but when it will occur and how it will burn. The large woody fuel created by

the dead trees falling will not increase the risk of wildfire in the short term, but it will influence fire 

behavior (intensity and rate of spread) in the future. The Federal Wildland Fire Management Policy 

mandates that wildland fire, as a critical natural process, must be reintroduced into the ecosystem and 

allowed to function as nearly as possible in its natural role to achieve the long-term goals of ecosystem

health. School Fire Salvage Recovery project will allow this by removing the excess fuels which have 

accumulated because of fire suppression over the last century. The removal of this excessive fuel loading 

will help enable fire to play its historical ecological role in the ecosystem without unnecessary risk to 

forest resources, firefighters, and public. Past actions have increased probabilities that various series of 

natural events will be viewed as catastrophic (Beschta et al. 1995). Without removal of excess fuels, this 

problem will be perpetuated. The School Fire was uncharacteristic with high intensity, stand replacement 

fire in a historically low intensity fire environment. Without the removal of excess fuels, the next fire will 

also likely be high intensity stand replacement fire. 

Fires in forested ecosystems normally burn in mosaic patterns that can range from a beneficial low 

intensity burn to very high intensity fires. Some forest types are not well adapted to extremely severe, 

uncharacteristic fire events. These forests will not recover quickly without management intervention. 

(USDA Forest Service 2005) 

Beschta (1995, 2004) recommendations describe ecosystem restoration goals, which in the case of the 

School Fire area may be harder to attain in the absence of post fire salvage logging. Even though the 

School Fire Salvage Recovery Project is focused on recovery of economic value only, one effect of 

salvage logging is the reduction of large woody fuels and alteration of the way wildfire and prescribed 

fire will burn through stands in the future, as discussed in the Fire Hazard section of this document. 

Large fuels (greater than 3” diameter) do not contribute greatly to fire spread. but they do contribute to 

fire severity. Due to large dead and down woody fuel contributions to fire behavior and resistance to 

control, reducing the amount of large, dead and down woody debris would increase the potential for using 

fire (prescribed or natural), which in turn will help keep the fine fuel load at a relatively low level. 

Torching, crowning, and spotting, which contribute to large fire growth, are greater where large woody

fuels have accumulated under a forest canopy and can contribute to surface fire heat release. If the large 

woody fuel is decayed and broken up (as it will be in 30 years), its contribution is considerably greater, 

similar to fire in heavy slash. Higher severity burning than would typically occur during earlier periods is 

possible depending on extent of soil coverage by large woody pieces (Brown 2003). If a conifer 

3-31
Chapter 3 – Affected Environment and Environmental Consequences 

overstory exists, crowning coupled with burnout of duff could amplify the burn severity. However, a fire 

involving optimum quantities of large woody debris should not lead to unusually severe fire effects. 

Historically, fires probably often occurred in the understory and mixed fire regime types when large 

downed woody fuels were in the optimum range (Brown 2003). 

American Lands Alliance “After the Fires” Report

The ALA “After the Fires” (2005) article was mentioned by numerous respondents during the public 

scoping phase of the School Fire Salvage Recovery Project. The article draws extensively from policy

recommendations contained in the recent Beschta et al. (2004) article in Conservation Biology, and cites 

literature already considered, specifically McIver and Starr (2000), Beschta et al. (1995), Everett et al. 

(1995), as well as a variety of literature on general ecological processes related to landscape disturbance 

and recovery. 

Relevance to the Fire Hazard portion of School Fire Salvage Recovery Project. The ALA “After the 

Fires” report and the US Forest Service response to it was reviewed. Concerns regarding effects of 

salvage logging on fire hazard and fires natural role in the ecosystem were similar to those expressed in 

the Beschta et al. reports. The fire hazard discussion above for Beschta et al. (1995, 2004) also pertains to 

the ALA report. 

McIver and Starr Salvage Logging Report 

The McIver and Starr report is entitled “Environmental effects of post-fire logging: literature review and 

annotated bibliography” (McIver and Starr 2000). The McIver and Starr report reviews the existing body

of scientific literature about logging (timber harvest) following wildfire. Twenty-one post-fire logging 

studies were reviewed and interpreted. McIver and Starr concluded that while the practice of salvage 

logging after fires is controversial, the debate is conducted without the benefit of much scientific 

information. 

They also concluded that the immediate environmental effects of post-fire logging are extremely variable 

and dependent on a wide variety of factors such as fire severity, slope steepness, soil texture and 

composition, the presence of preexisting roads, construction of new roads, timber harvest systems, and 

post-fire weather conditions. 

Relevance to the Fire Hazard portion of School Fire Salvage Recovery Project. The McIver and 

Starr report found only 14 studies that isolated the actual effect of logging burned timber as compared to 

an unlogged control. Because scientific information about salvage harvest was so sketchy, McIver and 

Starr argued for the use of adaptive management techniques to monitor the effects of salvage logging and

to use monitoring results to adjust site-specific practices and prescriptions accordingly (McIver and Starr 

2001). 

McIver and Starr found no studies that looked at reduction in fire severity in burned stands that had been 

logged. The following are their findings in reference to fire hazard: “Although fuel accumulations owing 

to spruce budworm (Choristoneura fumiferana)-caused tree death can result in unusually severe wildfires 

(Stocks 1987), there is no similar information on severity of subsequent fires in stands killed by wildfire.

In general, logging of large-diameter material in green tree stands will lead to decreases in total fuel 

accumulations over the intermediate term but increases in fine activity fuels (<3 in. in diameter) over the 

short term (Brown 1980). Logging in post-fire stands, however, would be expected to produce less fine 

activity fuel because the fine material burned, and one would expect removal of large diameter material to 

have an intermediate-term effect similar to green tree stands. Retrospective studies that look at twice 

burned stands in which different levels of fuel reduction were undertaken after the first fire would 

possibly shed light on the issue of postfire logging, fuel reduction, and reburn severity.” 

Donato et al. Article

On January 5, 2006, a short article was published in Sciencexpress, an on-line affiliate of a print journal 

called Science, with the title: “Post-Wildfire Logging Hinders Regeneration and Increases Fire Risk.” 

3-32
Chapter 3 – Affected Environment and Environmental Consequences 

The same or a slightly modified version was subsequently published as a one-page article in the full 

journal (Science) on January 20, 2006 (Donato et al. 2006a, 2006b). 

The Donato et al. article (2006a, 2006b) concluded “that postfire logging, by removing naturally seeded 

conifers and increasing surface fuel loads, can be counterproductive to goals of forest regeneration and 

fuel reduction.” This conclusion was based on a study of early conifer regeneration and fuel loads after 

the 2002 Biscuit Fire in southwestern Oregon 

Relevance to the Fire Hazard portion of School Fire Salvage Recovery Project. The Donato et al. 

article (2006a, 2006b) was reviewed and is relevant to the School Fire Salvage Recovery Project in that 

many areas are considered to be at high risk of complete tree loss if another fire should occur, primarily

because of uncharacteristically high fuel loads. This high severity fire potential is one reason for 

completing fuel reduction activities in the School Fire area, with salvage timber harvest proposed for 

reducing larger fuels and other activities for smaller fuels. 

We concur that after logging, the mitigation of short-term fire risk is not possible without subsequent fuel 

reduction treatments. Short-term fire risk will be mitigated by implementing fuel treatments such as 

yarding tops attached and jackpot burning in conjunction with salvage timber harvest. Appropriate fuel 

treatments are planned to ensure small woody fuel loads do not pose undue fire hazard risk to existing and 

future forest stands. 

The School Fire area is a fire dependent ecosystem. It is not a matter of if it will burn, but when and how. 

The proposed salvage timber harvest activity is expected to help manage fuels both in the short -erm and 

the long-term. If the salvage timber harvest activity is implemented as proposed, which would remove a 

reasonable proportion of the large-fuel component from these areas, and if the associated fine-fuel 

treatments are completed, then it is our judgment that salvage-related effects to reduce the potential 

intensity of future fires to ensure forest sustainability in treated stands would be both positive and 

efficacious. 

Lindenmayer Salvage Harvesting Policies Article

The journal Science published a short, one-page article on February 27, 2004 (Lindenmayer et al.. 2004). 

Its position is that (1) salvage harvest undermines the ecosystem benefits of major disturbances; (2) 

removing biological legacies (large wood) can negatively affect many taxa; (3) salvage harvest can impair 

ecosystem recovery; and (4) some taxa might be maladapted to the interactive effects of two disturbance 

events in rapid succession (fire and salvage logging). 

The Lindenmayer et al. (2004) article was reviewed. School Fire Salvage Recovery Project includes an 

alternative that would react to the burned watersheds in a manner similar to what is recommended by 

Lindenmayer et al. (2004) – the No Action alternative. 

Relevance to the Fire Hazard portion of School Fire Salvage Recovery Project. The article did not

raise specific issues in regard to fire hazard and fuels. 

SOILS

Beschta et al. Reports - With regards to soils the following are statements from the Beschta reports: 

“No management activity should be undertaken which does not protect soil integrity.” 

3-33
Chapter 3 – Affected Environment and Environmental Consequences 

(a). “Soil loss and compaction are associated with both substantial loss of site productivity and with offsite degradation (water quality).” 

(b). “Reduction of soil loss is associated with maintaining the litter layer.” 

(c).“Although post-burn soil conditions may very depending upon fire severity, steepness of slope, 

inherent erodibility, etc., soils are particularly vulnerable in burned landscapes.” 

(d). “Post-burn activities that accelerate erosion or create soil compaction must be prohibited.”

Relevance to the Soils portion of School Fire Salvage Recovery Project. The EIS includes analysis of 

soil conditions due to pre-fire management activity and those predicted as a result of proposed activities. 

Changes in surface conditions due to loss of down wood and litter (surface cover) from high and 

moderate burn severity are accounted for the in predicted effects. While the initial susceptibility of the 

soil to erosion is elevated due to loss of cover, the recovery of vegetation has and will continue to occur 

on these areas under uninhibited post-fire rates. Disturbance of recovering vegetation is limited to very

small percentages of the units in the proposed action. 

Logging in units within the fire area will produce soil disturbance, some exceeding criteria for detrimental 

levels in degree, primarily in the form of compaction, disturbance of vegetation by crushing and 

uprooting, especially in units using ground-based harvest and yarding systems. Harvest and yarding 

systems have been selected to minimize these impacts based on soil characteristics and slope. Helicopter 

and cable yarding systems are proposed for units averaging over 30 percent slopes. The ground-based 

system selected is the harvester/forwarder system which limits the area of compaction and exposes very

little mineral soil subject to erosion. Units within high and moderate burn severity would increase surface 

cover of fine and some coarse wood as salvage operations would leave unmerchantable tops and branches 

scattered on site. Subsoiling rehabilitation would be used to relieve compaction on highly compacted 

areas, such as landings, including areas of preexisting compaction reused in this project. 

“Recovery logging should be prohibited in sensitive areas.” 

(a). “Logging on sensitive areas is often associated with accelerated erosion and soil compaction.” 

(b). “Recovery logging by any method must be prohibited on sensitive sites, including: severely burned 

areas (no duff layer), on erosive soils, on fragile soils, in roadless areas, in riparian areas, on steep slopes, 

or any site where accelerated erosion is possible.”

Relevance to the Soils portion of School Fire Salvage Recovery Project. Selection of harvest and 

yarding systems, and erosion control and mitigation measures (Best Management Practices), were 

selected based on sensitivity (risk based on soil characteristics) of the soils in the project area, including 

burn severity from the fire. Hand-felling and helicopter and cable-yarding are to be used on units where 

slopes average over 30 percent. Unmerchantable tops and branches would be retained on site in high burn 

severity areas, lopped and scattered adding to ground cover in these units. No activities are proposed 

within inventoried roadless areas. Riparian buffers have been designed in with additional buffering of 

sensitive steep, ephemeral draws. 

3-34
Literature Citations

LITERATURE CITATIONS 

CHANGES BETWEEN DRAFT SEIS AND FINAL SEIS

• This FSEIS only contains discussion of information that is new or different. 

• Other sections of the July 2006 FEIS are unchanged 

• Additional citations in the FSEIS 

Committee on Science, Engineering and Public Policy. 1995. On being a scientist; responsible conduct 

in research. Washington, DC: National Academy Press. 27 p. 

Filip, Gregory M.; Schmitt, Craig L.; Scott, Donald W.; Fitzgerald, Stephen A. 2007. Understanding and 

defining mortality in western conifer forests. Western Journal of Applied Forestry. 22(2): 105-

 115. 

Joyce, Linda A.; Birdsey, Richard, technical editors. 2000. The impact of climate change on America's 

forests: a technical document supporting the 2000 USDA Forest Service RPA assessment. 

General Technical Report RMRS-GTR-59. Fort Collins, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station. 133 p. 

Lindenmayer, D. B.; Noss, R. F. 2006. Salvage logging, ecosystem processes, and biodiversity 

conservation. Conservation Biology. 20(4): 949-958. 

McIver, J. D.; Ottmar, R. 2007. Fuel mass and stand structure after post-fire logging of a severely

burned ponderosa pine forest in northeastern Oregon. Forest Ecology and Management. 238(1-

3): 268-279. 

Noss, Reed F.; Franklin, Jerry F.; Baker, William L.; Schoennagel, Tania; Moyle, Peter B. 2006. 

Managing fire-prone forests in the western United States. Frontiers in Ecology and the 

Environment. 4(9): 481-487. 

Shatford, J. P. A.; Hibbs, D. E.; Puettmann, K. J. 2007. Conifer regeneration after forest fire in the 

Klamath-Siskiyous: How much, how soon? Journal of Forestry. 105(3): 139-146. 

Waring, R. [N.D.] Evaluation of Don Scott’s marking of “dying ponderosa pine above 21"” on fire 

salvage sales: USFS Prairie City Ranger District. Unpublished Report. [Corvallis, OR]: Oregon 

State University, College of Forestry, Department of Forest Science. 5 p. 

Waring, R.H. 1987. Characteristics of trees predisposed to die. BioScience. 37(8): 569-574. 

Mann, W.F., Jr.; Gunter, E.R. 1960. Predicting the fate of fire-damaged pines. Forests and People. 

10(First Quarter): 26-27, 43. 

Martin, R.E. 1963. A basic approach to fire injury of tree stems. In: Proceedings of the second annual 

Tall Timbers fire ecology conference. Tallahassee, FL: Tall Timbers Research Station: 151-162. 

Miller, J.M.; Patterson, J.E. 1927. Preliminary studies on the relation of fire injury to bark beetle attack 

in western yellow pine. Journal of Agricultural Research. 34(7): 597-613. 

L-1 
Index 

Index 

This list of terms is intended to assist the reader in locating a broad scope of subject areas discussed in the 

FSEIS documentation. The reference to specific page numbers is not intended to be complete. 

A 

Amend/Amendment – Abstract, S-1, S-2, 1-2, 1-4, 2-1, 2-2, 2-4, 2-5, 3-2, 3-3 

D 

Dead – Abstract, S-1, S-2, 1-2, 1-4, 2-1, 2-4, 2-5, 3-1, 3-3 

Deterioration – S-1, 1-3, 2-4, 3-1, 3-2 

E 

Eastside Screens – Abstract, S-1, 1-4, 2-1, 2-4, 3-3, Appendix N 

Economic – Abstract, S-1, 1-3, 2-4, 2-5, 3-1, 3-2 

Emergency Situation Determination - Abstract 

F 

Forest Plan - Abstract, S-1, 1-4, 2-1, 2-5, 3-3 

H 

Harvest – Abstract, S-1, S-2, 1-1, 1-2, 1-3, 1-4, 2-1, 2-4, 2-5, 3-1, 3-2 

L 

Live - Abstract, S-1, S-2, 1-1, 1-2, 1-3, 1-4, 2-1, 2-4, 2-5, 3-1, 3-2, 3-3, Appendix B, and N 

M 

Mortality – 1-2, 1-3, 2-2, 2-3, 3-1 

N 

National Forest Management Act (NMFA) – 1-2 

O 

Old Growth – S-1, 1-1, 1-2 

P 

Prediction – 2-2 

Probability – S-2, 1-3, 1-4, 2-1, 2-2, 3-2 

V 

Volume – S-1, 1-1, 2-3, 2-4, 2-5, 3-1, 3-2 

Index-1