Ogden FEIS Appendices

APPENDIX A

Units and Prescriptions
Appendix A Page 2 of 21

APPENDIX A: UNITS AND PRESCRIPTIONS

Prescription Codes (applicable to Table A-1 and Table A-2):

LP_1 Lodgepole pine seed tree removal (previous clearcut where understory is 

fully regenerated, seed trees are removed)

LP_3 Lodgepole pine seed tree harvest (clearcut with lodgepole pine seed trees 

reserved)

MC_3 Mixed conifer regeneration with reserve trees (two-aged method with 

desirable ponderosa pine and white fir reserved)

MC_1, PP_1, PP_LP_1 Thin, favoring ponderosa pine for retention. Lodgepole pine and true fir 

retained as needed to meet minimum stocking levels

MC_2, LP_2, LP_4 Thin, favoring ponderosa pine for retention. Lodgepole pine and true fir 

retained as needed to meet lower management stocking levels

LP_SPC, MC_SPC, 

PP_LP_SPC, PP_SPC

Thin, within plantations and other areas where excess stocking is primarily 

small diameter trees

RHCA Thin within Riparian Habitat Conservation Area

MOW Mechanical shrub treatment or Mowing

WTY Whole tree yarding

UB Underburning

Mow_UB Combination mow and underburn 

Mow_UB_2 Combination mow and underburn where thinning retains lodgepole or 

white fir to meet lower management zone tree density

Table A-1: Ogden - Alternative 2 (Proposed Action) - Units and Prescriptions

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

1 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 42

2 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 19

3 PP_LP_sustain_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 13

4 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY None 3

5 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 22

6 PP_LP_sustain_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 138

7 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 15

8 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 63

9 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 38

10 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 28

11 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 44

13 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY None 12
Appendix A Page 3 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

14 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 147

15 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY None 31

16 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 10

17 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 53

18 PP_LP_sustain_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 36

19 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 56

20 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 20

21 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 60

22 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 114

23 PP_LP_sustain_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 17

24 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 55

25 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 143

26 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 36

27 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 11

28 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 96

29 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 45

30 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 41

31 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 84

32 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 39

33 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 82

34 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 11

35 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 128

36 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 252

37 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 138

38 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 26

39 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 96

40 PP_LP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 138

41 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 93

42 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 44

43 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 20

44 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 19

45 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 22

46 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 65

47 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 85

48 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 17

49 PP_move_to_intermediate None None None MOW 117

50 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 60

51 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 10

52 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 25

54 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 12

55 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 41
Appendix A Page 4 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

56 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 4

57 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 60

59 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 5

60 MC_move_to_intermediate MC_SPC Hand_Grapple_Pile WTY MOW 20

61 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY MOW 10

62 PP_move_to_intermediate MC_SPC Hand_Grapple_Pile WTY MOW 1

63 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 34

64 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 43

65 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 34

66 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 25

67 LP_move_to_intermediate LP_1 Hand_Pile WTY None 19

68 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 39

69 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 23

70 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 37

71 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 31

72 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5

73 LP_move_to_intermediate LP_1 Hand_Pile WTY None 44

74 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5

75 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 9

76 LP_move_to_intermediate LP_1 Hand_Pile WTY None 39

77 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5

78 WLHab_LP_StructDiversity LP_SPC Hand_Grapple_Pile WTY None 63

79 LP_move_to_intermediate LP_1 Hand_Pile WTY None 68

80 LP_move_to_intermediate LP_1 Hand_Pile WTY None 8

81 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 15

82 LP_move_to_intermediate LP_1 Hand_Pile WTY None 23

83 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 24

84 LP_move_to_intermediate LP_1 Hand_Pile WTY None 41

85 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 8

86 LP_move_to_intermediate LP_1 Hand_Pile WTY None 37

87 LP_move_to_intermediate LP_1 Hand_Pile WTY None 34

88 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5

89 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 28

90 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

91 LP_move_to_intermediate LP_1 Hand_Pile WTY None 88

92 LP_move_to_intermediate LP_1 Hand_Pile WTY None 3

93 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

94 WLHab_LP_StructDiversity LP_SPC Hand_Grapple_Pile WTY None 170

95 LP_move_to_intermediate LP_1 Hand_Pile WTY None 67

96 LP_move_to_intermediate LP_1 Hand_Pile WTY None 19

97 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 36
Appendix A Page 5 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

98 LP_move_to_intermediate LP_1 Hand_Pile WTY None 31

99 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

100 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 27

101 PP_LP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 21

102 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 16

103 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 30

104 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 37

105 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 58

106 LP_move_to_intermediate LP_1 Hand_Pile WTY None 77

107 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 13

108 PP_LP_sustain_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 13

109 LP_move_to_intermediate LP_1 Hand_Pile WTY None 11

110 PP_LP_sustain_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 1

111 PP_LP_sustain_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 9

112 MC_move_to_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 5

113 MC_sustain_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 8

114 PP_LP_move_to_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 14

115 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 33

116 MC_sustain_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 7

117 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 6

118 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 19

119 PP_LP_move_to_intermediate None None None MOW 42

120 PP_move_to_Lg_tree_str PP_SPC Hand_Grapple_Pile WTY MOW 11

121 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 11

122 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 8

123 PP_move_to_Lg_tree_str PP_SPC Hand_Grapple_Pile WTY MOW 20

124 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 76

125 PP_move_to_intermediate None None None MOW 48

126 PP_move_to_Lg_tree_str None None None MOW 16

127 PP_move_to_intermediate None None None MOW 9

128 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 11

129 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 4

130 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 34

131 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 106

132 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 29

133 PP_move_to_intermediate None None None MOW 43

134 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 66

135 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 8

136 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 61

137 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 21

138 PP_LP_move_to_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 27
Appendix A Page 6 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

139 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 21

140 PP_LP_move_to_Lg_tree_str RHCA_PP_

LP RHCA_Pile RHCA_WTY RHCA_UB 9

141 PP_LP_move_to_Lg_tree_str RHCA_PP_

LP RHCA_Pile RHCA_WTY RHCA_UB 85

142 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 25

143 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 37

144 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 82

145 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 87

146 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 91

147 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 32

148 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 99

149 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 20

150 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 20

151 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 135

152 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 5

153 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 59

154 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 20

155 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 16

156 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 103

157 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 38

158 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 204

159 PP_LP_move_to_Lg_tree_str RHCA_PP_

LP RHCA_Pile RHCA_WTY RHCA_UB 80

160 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 44

161 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 54

162 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 173

163 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 23

164 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 4

165 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 3

166 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 12

167 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 225

168 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 6

169 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 10

170 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 135

171 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 55

172 PP_LP_move_to_Lg_tree_str RHCA_PP_

LP RHCA_Pile RHCA_WTY RHCA_UB 11

173 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 29

174 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 121

175 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 41

176 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 8

177 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 41
Appendix A Page 7 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

178 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 136

179 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 15

180 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 66

181 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 3

182 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 21

183 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 55

184 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 9

185 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 17

186 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 20

187 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 141

188 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 21

189 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 7

190 PP_sustain_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 18

191 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 13

192 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 23

193 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 31

194 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 36

195 PP_move_to_intermediate PP_SPC Hand_Pile None MOW 7

196 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 11

197 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 28

198 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 2

199 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 23

200 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 3

201 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 25

202 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 6

203 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 4

204 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 22

205 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 4

206 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 14

207 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 30

208 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 78

209 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 91

210 PP_LP_move_to_Lg_tree_str PP_LP_SP

C

None_Lop_Scatter WTY Mow_UB_2 7

211 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 56

212 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 13

213 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 7

214 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 170

215 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 32

216 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 61

217 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 4

218 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 21
Appendix A Page 8 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

219 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 12

220 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 62

221 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 6

222 PP_move_to_intermediate PP_SPC Lop_Scatter None None 6

223 PP_move_to_intermediate PP_SPC Hand_Pile None None 48

224 PP_move_to_intermediate PP_SPC Lop_Scatter None None 181

225 PP_move_to_intermediate PP_SPC Lop_Scatter None None 30

226 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 19

227 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 9

228 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 38

229 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 34

230 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 98

231 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 30

232 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 31

233 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 43

234 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 20

235 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 35

236 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 31

237 PP_LP_move_to_intermediate LP_1 Lop_Scatter WTY None 20

238 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 64

239 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 5

240 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 5

241 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 36

242 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 44

243 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 34

244 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 25

245 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 5

246 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 14

247 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 70

248 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 14

249 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 31

250 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 43

251 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 126

252 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 15

253 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 45

254 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 94

255 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 22

256 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 36

257 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 51

258 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 84

259 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 31
Appendix A Page 9 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

260 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 29

261 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 16

262 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 10

263 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 62

264 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 11

265 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 151

266 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 29

267 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 86

268 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 106

269 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 115

270 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 16

271 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 10

272 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 45

273 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 150

274 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 45

275 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 27

277 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 24

278 PP_LP_move_to_Lg_tree_str PP_LP_1 None_Lop_Scatter WTY Mow_UB 86

279 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 59

280 PP_LP_move_to_intermediate PP_LP_SP

C

Hand_Grapple_Pile WTY Mow_UB_2 4

281 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 91

283 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 86

284 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 19

285 MC_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 25

286 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 12

287 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 25

288 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 13

289 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

290 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 45

291 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 9

292 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 2

293 LP_move_to_intermediate LP_1 Hand_Pile WTY None 20

294 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 3

295 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 10

296 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 27

297 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 13

298 LP_move_to_intermediate LP_1 Hand_Pile WTY None 25

299 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 15

300 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 9

301 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 7

302 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5
Appendix A Page 10 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

303 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 17

304 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 15

305 LP_move_to_intermediate LP_1 Hand_Pile WTY None 24

306 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 8

307 LP_move_to_intermediate LP_1 Hand_Pile WTY None 13

308 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 7

309 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 37

310 LP_move_to_intermediate LP_1 Hand_Pile WTY None 27

311 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 14

312 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 15

313 LP_move_to_intermediate LP_1 Hand_Pile WTY None 13

314 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

315 LP_move_to_intermediate LP_1 Hand_Pile WTY None 1

316 LP_move_to_intermediate LP_1 Hand_Pile WTY None 1

317 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 6

318 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 9

319 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 1

320 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 9

321 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 17

322 LP_move_to_intermediate LP_1 Hand_Pile WTY None 12

324 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 6

325 LP_move_to_intermediate LP_1 Hand_Pile WTY None 26

326 LP_move_to_intermediate LP_1 Hand_Pile WTY None 1

327 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 12

328 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 5

330 LP_move_to_intermediate LP_1 Hand_Pile WTY None 10

331 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 23

332 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

333 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 39

334 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

335 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 10

337 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY MOW 3

338 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY MOW 13

339 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 19

340 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY Mow_UB_2 67

341 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 23

342 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 48

343 MC_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 19

345 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 11

346 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY Mow_UB_2 67

347 LP_move_to_intermediate LP_1 Hand_Pile WTY None 12
Appendix A Page 11 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

348 MC_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 15

350 MC_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 13

351 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 6

352 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 55

353 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 25

354 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY MOW 10

355 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY MOW 1

356 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY MOW 1

357 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Pile WTY MOW 16

358 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY MOW 3

365 PP_LP_move_to_Lg_tree_str PP_LP_SP

C

Hand_Grapple_Pile WTY MOW 21

366 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 12

367 PP_LP_move_to_intermediate PP_LP_SP

C

Hand_Grapple_Pile WTY MOW 8

368 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 8

369 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 90

370 PP_LP_move_to_Lg_tree_str PP_LP_1 Hand_Grapple_Pile WTY Mow_UB 118

371 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 24

372 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 9

373 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 66

374 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 6

375 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 25

376 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 11

377 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 149

378 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 45

379 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 10

380 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 27

381 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 7

382 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 29

383 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 13

384 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 19

385 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 24

386 MC_sustain_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 25

387 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 18

388 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 3

926 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 3

944 PP_move_to_Lg_tree_str None None None Mow_UB 89

945 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 9

947 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 29

948 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 5

950 MC_move_to_Lg_tree_str MC_3 Hand_Grapple_Pile WTY Mow_UB 12
Appendix A Page 12 of 21

Unit 

Number Objective

Treatment

Acres

Tree Slash 1 Slash 2 Fuel

951 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 17

952 MC_move_to_Lg_tree_str MC_3 Hand_Grapple_Pile WTY Mow_UB 20

953 PP_LP_move_to_Lg_tree_str MC_3 Hand_Grapple_Pile WTY Mow_UB 3

954 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 8

955 PP_LP_move_to_Lg_tree_str PP_LP_SP

C

None_Lop_Scatter WTY Mow_UB_2 19

956 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY Mow_UB_2 8

957 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY Mow_UB_2 22

958 PP_LP_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY Mow_UB_2 6

961 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 4

962 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 6

963 LP_move_to_stnd_initiation LP_3 Hand_Grapple_Pile WTY None 9

967 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 36
Appendix A Page 13 of 21

Alternative 3 – Units and Prescriptions

Table A-2: Ogden - Alternative 3 - Units and Prescriptions

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

1 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 42

2 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 19

3 PP_LP_sustain_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 13

4 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 3

5 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 22

6 PP_LP_sustain_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 138

7 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 15

9 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 38

13 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 12

14 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 147

15 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 31

16 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 10

17 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 53

18 PP_LP_sustain_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 36

19 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 56

20 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 20

21 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 60

22 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 114

23 PP_LP_sustain_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 17

24 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 55

25 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 143

26 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 36

27 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 11

28 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 96

29 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 45

30 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 41

31 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 84

32 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 39

33 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 82

34 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 11

35 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 128

36 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 252

37 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 138

38 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 26

39 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 96

40 PP_LP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 138

41 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 93

42 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 44

43 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 20

44 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 19

45 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 22
Appendix A Page 14 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

46 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 65

47 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 85

48 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 17

49 PP_move_to_intermediate None None None MOW 117

50 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 60

51 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 10

52 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 25

53 PP_move_to_Lg_tree_str GSHK_PFAmc None_Lop_Scatter WTY None 17

54 PP_LP_move_to_Lg_tree_str MC_2 None_Lop_Scatter WTY None 12

55 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 41

56 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 4

60 MC_move_to_intermediate MC_SPC Hand_Grapple_Pile WTY None 20

61 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY None 10

62 PP_move_to_intermediate MC_SPC Hand_Grapple_Pile WTY None 1

63 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 34

64 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 43

65 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 34

66 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 25

67 LP_move_to_intermediate LP_1 Hand_Pile WTY None 19

68 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 39

70 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 37

71 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 31

73 LP_move_to_intermediate LP_1 Hand_Pile WTY None 44

76 LP_move_to_intermediate LP_1 Hand_Pile WTY None 39

78 WLHab_LP_StructDiversity LP_SPC Hand_Grapple_Pile WTY None 63

79 LP_move_to_intermediate LP_1 Hand_Pile WTY None 68

80 LP_move_to_intermediate LP_1 Hand_Pile WTY None 8

82 LP_move_to_intermediate LP_1 Hand_Pile WTY None 23

84 LP_move_to_intermediate LP_1 Hand_Pile WTY None 41

86 LP_move_to_intermediate LP_1 Hand_Pile WTY None 37

87 LP_move_to_intermediate LP_1 Hand_Pile WTY None 34

90 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

91 LP_move_to_intermediate LP_1 Hand_Pile WTY None 88

92 LP_move_to_intermediate LP_1 Hand_Pile WTY None 3

93 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

94 WLHab_LP_StructDiversity LP_SPC Hand_Grapple_Pile WTY None 170

95 LP_move_to_intermediate LP_1 Hand_Pile WTY None 67

96 LP_move_to_intermediate LP_1 Hand_Pile WTY None 19

97 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 36

98 LP_move_to_intermediate LP_1 Hand_Pile WTY None 31

99 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

100 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 27

101 PP_LP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 21

102 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 16
Appendix A Page 15 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

103 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 30

104 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 37

106 LP_move_to_intermediate LP_1 Hand_Pile WTY None 77

107 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 13

108 PP_LP_sustain_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 13

109 LP_move_to_intermediate LP_1 Hand_Pile WTY None 11

118 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 19

119 PP_LP_move_to_intermediate None None None MOW 42

120 PP_move_to_Lg_tree_str PP_SPC Hand_Grapple_Pile WTY MOW 11

121 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 11

122 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 8

123 PP_move_to_Lg_tree_str PP_SPC Hand_Grapple_Pile WTY MOW 20

124 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 76

125 PP_move_to_intermediate None None None MOW 48

126 PP_move_to_Lg_tree_str None None None MOW 16

127 PP_move_to_intermediate None None None MOW 9

128 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 11

129 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 4

130 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 34

131 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 106

132 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 29

133 PP_move_to_intermediate None None None MOW 43

134 PP_LP_move_to_Lg_tree_str MC_2 None_Lop_Scatter WTY None 66

135 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 8

136 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 61

137 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 21

138 PP_LP_move_to_Lg_tree_str RHCA_MC RHCA_Pile RHCA_WTY RHCA_UB 27

139 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 21

140 PP_LP_move_to_Lg_tree_str RHCA_PP_LP RHCA_Pile RHCA_WTY RHCA_UB 9

141 PP_LP_move_to_Lg_tree_str RHCA_PP_LP RHCA_Pile RHCA_WTY RHCA_UB 85

142 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 25

143 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 37

144 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 82

145 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 87

146 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 91

147 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 32

148 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 99

149 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 20

150 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 20

151 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 135

152 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 5

153 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 59

154 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 20

155 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 16
Appendix A Page 16 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

156 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 103

157 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 38

158 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 204

159 PP_LP_move_to_Lg_tree_str RHCA_PP_LP RHCA_Pile RHCA_WTY RHCA_UB 80

160 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 44

161 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 54

162 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 173

163 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 23

164 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 4

165 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 3

166 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 12

167 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 225

168 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 6

169 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 10

170 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 135

171 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 55

172 PP_LP_move_to_Lg_tree_str RHCA_PP_LP RHCA_Pile RHCA_WTY RHCA_UB 11

173 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 29

174 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 121

175 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 41

176 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 8

177 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 41

178 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 136

179 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 15

180 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 66

181 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 3

182 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 21

183 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 55

184 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 9

185 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 17

186 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 20

187 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 141

188 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 21

189 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 7

190 PP_sustain_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 18

191 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 13

192 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 23

193 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 31

194 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 36

195 PP_move_to_intermediate PP_SPC Hand_Pile None MOW 7

196 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 11

197 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 28

198 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 2

199 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 23
Appendix A Page 17 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

200 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 3

201 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 25

202 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 6

203 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 4

204 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 22

205 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 4

206 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 14

207 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 30

208 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 78

209 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 91

210 PP_LP_move_to_Lg_tree_str PP_LP_SPC None_Lop_Scatter WTY Mow_UB_2 7

211 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 56

212 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 13

214 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 170

215 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 32

216 PP_LP_move_to_Lg_tree_str None None None Mow_UB_2 61

217 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 4

218 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 21

219 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 12

220 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 62

221 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 6

222 PP_move_to_intermediate PP_SPC Lop_Scatter None None 6

223 PP_move_to_intermediate PP_SPC Hand_Pile None None 48

224 PP_move_to_intermediate PP_SPC Lop_Scatter None None 181

225 PP_move_to_intermediate PP_SPC Lop_Scatter None None 30

226 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 19

227 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 9

228 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 38

229 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 34

230 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 98

231 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 30

232 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 31

233 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 43

234 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 20

235 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 35

236 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 31

237 PP_LP_move_to_intermediate LP_1 Lop_Scatter WTY None 20

238 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 64

239 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 5

240 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 5

241 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 36

242 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 44

243 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 34

244 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 25
Appendix A Page 18 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

245 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 5

246 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 14

247 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 70

248 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 14

249 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 31

250 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 43

251 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 126

252 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 15

253 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 45

254 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 94

255 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 22

256 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 36

257 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 51

258 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 84

259 PP_move_to_Lg_tree_str None None None Mow_UB 31

260 PP_move_to_Lg_tree_str None None None Mow_UB 29

261 PP_move_to_Lg_tree_str None None None Mow_UB 16

262 PP_move_to_Lg_tree_str None None None Mow_UB 10

263 PP_move_to_Lg_tree_str None None None Mow_UB 62

264 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 11

265 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 151

266 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 29

267 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 86

268 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 106

269 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 115

273 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 150

274 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 45

275 PP_LP_move_to_Lg_tree_str None None None Mow_UB_2 27

277 PP_LP_move_to_Lg_tree_str None None None Mow_UB_2 24

278 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY Mow_UB_2 86

279 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 59

280 PP_LP_move_to_intermediate PP_LP_SPC Hand_Grapple_Pile WTY Mow_UB_2 4

281 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 91

283 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 86

285 MC_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 25

286 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 12

287 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 25

288 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 13

289 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

290 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 45

291 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 9

292 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 2

293 LP_move_to_intermediate LP_1 Hand_Pile WTY None 20

296 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 27
Appendix A Page 19 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

298 LP_move_to_intermediate LP_1 Hand_Pile WTY None 25

305 LP_move_to_intermediate LP_1 Hand_Pile WTY None 24

306 LP_move_to_stnd_initiation LP_4 Hand_Grapple_Pile WTY None 8

307 LP_move_to_intermediate LP_1 Hand_Pile WTY None 13

308 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 7

309 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 37

310 LP_move_to_intermediate LP_1 Hand_Pile WTY None 27

311 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 14

312 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY None 15

313 LP_move_to_intermediate LP_1 Hand_Pile WTY None 13

314 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

318 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 9

319 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 1

322 LP_move_to_intermediate LP_1 Hand_Pile WTY None 12

325 LP_move_to_intermediate LP_1 Hand_Pile WTY None 26

326 LP_move_to_intermediate LP_1 Hand_Pile WTY None 1

330 LP_move_to_intermediate LP_1 Hand_Pile WTY None 10

331 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 23

332 LP_move_to_intermediate LP_1 Hand_Pile WTY None 14

333 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 39

334 LP_move_to_intermediate LP_1 Hand_Pile WTY None 28

335 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 10

337 MC_move_to_Lg_tree_str MC_LFR Lop_Scatter None MOW 3

338 MC_move_to_Lg_tree_str MC_LFR Lop_Scatter None MOW 13

339 PP_move_to_intermediate PP_SPC Hand_Grapple_Pile WTY MOW 19

341 LP_move_to_intermediate LP_SPC Hand_Grapple_Pile WTY None 23

342 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 48

343 MC_move_to_Lg_tree_str MC_2 None_Lop_Scatter WTY Mow_UB_2 19

345 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 11

346 MC_move_to_Lg_tree_str MC_LFR Lop_Scatter None MOW 67

351 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 6

352 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 55

353 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY None 25

365 PP_LP_move_to_Lg_tree_str PP_LP_SPC Hand_Grapple_Pile WTY None 21

366 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 12

367 PP_LP_move_to_intermediate PP_LP_SPC Hand_Grapple_Pile WTY None 8

368 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 8

369 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 90

370 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 118

371 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 24

372 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 9

373 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 66

374 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 6

375 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 25
Appendix A Page 20 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

376 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 11

377 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 149

378 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 45

379 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 10

380 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 27

381 PP_move_to_intermediate PP_SPC Lop_Scatter None MOW 7

382 PP_LP_move_to_Lg_tree_str MC_2 None_Lop_Scatter WTY Mow_UB_2 29

383 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 13

384 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 19

385 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 24

386 MC_sustain_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 25

387 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 18

388 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 3

901 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 11

902 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 138

903 PP_LP_move_to_Lg_tree_str None None None Mow_UB_2 33

904 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 116

905 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 56

906 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 50

907 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY None 2

909 PP_move_to_Lg_tree_str GSHK_PFAmc None_Lop_Scatter WTY Mow_UB 33

912 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY None 23

913 PP_move_to_Lg_tree_str GSHK_PFAmc Hand_Grapple_Pile WTY Mow_UB_2 57

914 MC_move_to_Lg_tree_str MC_2 None_Lop_Scatter WTY Mow_UB_2 20

916 LP_move_to_stnd_initiation LP_4 Hand_Grapple_Pile WTY None 8

918 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 32

919 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 5

920 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 5

921 PP_LP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 6

922 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 7

923 PP_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 12

924 PP_LP_move_to_intermediate PP_LP_SPC Hand_Grapple_Pile WTY Mow_UB_2 43

925 PP_LP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB_2 19

926 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 3

927 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 4

928 PP_LP_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 13

929 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 22

930 PP_LP_move_to_Lg_tree_str PP_LP_LFR Lop_Scatter None Mow_UB_2 18

931 PP_move_to_Lg_tree_str PP_1 Hand_Grapple_Pile WTY Mow_UB 27

932 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY Mow_UB_2 58

933 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 17

934 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 10

935 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY Mow_UB 21

943 PP_LP_move_to_Lg_tree_str PP_LP_2 None_Lop_Scatter WTY None 18
Appendix A Page 21 of 21

Unit 

Number Objective Treatment Acres Tree Slash 1 Slash 2 Fuel

944 PP_move_to_Lg_tree_str None None None Mow_UB 89

945 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 9

946 PP_LP_move_to_Lg_tree_str GSHK_NST Hand_Grapple_Pile WTY Mow_UB_2 50

947 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY Mow_UB_2 29

948 PP_move_to_Lg_tree_str MC_1 None_Lop_Scatter WTY Mow_UB 5

949 PP_move_to_Lg_tree_str GSHK_PFA None_Lop_Scatter WTY None 129

951 MC_move_to_Lg_tree_str MC_2 Hand_Grapple_Pile WTY None 17

955 PP_LP_move_to_Lg_tree_str PP_LP_SPC None_Lop_Scatter WTY None 19

956 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY MOW 8

957 MC_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY MOW 22

958 PP_LP_move_to_Lg_tree_str MC_SPC Hand_Grapple_Pile WTY MOW 6

964 PP_move_to_Lg_tree_str PP_1 None_Lop_Scatter WTY None 4

965 PP_move_to_Lg_tree_str GSHK_PFA Hand_Grapple_Pile WTY Mow_UB 25

966 MC_move_to_Lg_tree_str GSHK_NSTmc Hand_Grapple_Pile WTY Mow_UB_2 32

967 MC_move_to_Lg_tree_str MC_1 Hand_Grapple_Pile WTY Mow_UB 36

969 PP_LP_move_to_Lg_tree_str PP_LP_2 Hand_Grapple_Pile WTY None 15
Appendix B Page 1 of 20

APPENDIX B

Wildlife Analysis Supporting Information:

-Dead Wood Analysis

-Paulina Creek Old Growth Management Plan

-Road Density Further Evaluation
Appendix B Page 2 of 20

Wildlife – Dead Wood Analysis

Rationale for Management of Snags and Green Tree Replacements

The Deschutes National Forest Tree and Log Implementation Strategy (DWTL 1994) prescribes snag 

numbers and characteristics, green tree replacements (GTR), and coarse woody (CWM) to be left in a 

harvest unit. The general prescription is on a unit by unit basis. It also describes how, under some 

circumstances, GTRs may be located outside the actual treatment unit (DWTL, Section II.B.2.f.3 

Planning). For snags in lodgepole pine stands the Strategy states that 1.8 hard snags/acre are needed posttreatment to meet 100% MPP (maximum population potential). This number is based on Thomas et al. 

(1979) review of nesting habitat. According to assumptions in the DWTL, 20 GTRs >10” dbh are to be 

retained per acre to meet the snag requirements within lodgepole pine regeneration units during the 

rotation period, assuming the residual stand has an average diameter of 3 inches. In ponderosa pine 

stands, according to the DWTL, 2.25 hard snags/acre are needed to meet 100% MPP. In even-aged 

ponderosa pine units with an average residual stand diameter of 3 inches, 18.3 GTRs >15 inches are 

required to meet the 100% MPP. Although these numbers are presented here on a per acre basis, the 

DWTL focuses on the treatment unit as the area of accountability for snag and log objectives (DWTL, p. 

4).

Interim Management Direction (Screens) requires that sale activities retain snag and GTR levels at 100% 

MPP, and that the largest trees be left to meet this requirement. The 100%MPP level “should be 

determined using the best available data on species requirements as applied through current snag models 

or other documented procedures.” The DWTL also was to evolve as new research becomes available.

Information on Cavity Nesting Wildlife Response to Snag Levels

Bull et al. (1997) indicated that the Thomas et al. (1979) snag guidelines are not sufficient to provide 

habitat to support woodpecker populations at 100% MPP. For example, the Thomas model did not 

provide sufficient numbers of trees for foraging; additionally, it did not consider habitat needs for wildlife 

that seek shelter under loose bark of snags (e.g. brown creepers and several bat species). It follows that 

snag numbers recommended in the DWTL are not sufficient to support woodpecker populations at 100% 

MPP.

Ponderosa and Lodgepole pine stands provide different habitats for cavity-nesters. A set of cavity-nesters 

may select for one or the other forest type and select for different levels of snags to meet roosting, 

nesting, and foraging needs. For this project, stand types were largely classified as lodgepole or 

ponderosa pine , although there are normally a few ponderosa pine in some lodgepole pine stands and 

vice versa.

The following were considered as “new information” to develop recommendations for ponderosa and 

lodgepole pine forest types in the project area:

Bull et al. (1997)

Dixon (1995) as cited in Marshall (1997)

Goggans et al. (1988)

Hopkins (1992), Hopkins et al. (1993)

Parks et al. (1999)

Lodgepole pine

Rationale for managing GTRs at the 6 snags/acre level:

Provide snag habitat to replace that which is removed in the treatment units, e.g. cavity nesting, 

roosting, and foraging habitat; roosting and nesting sites under loose bark; display and drumming 

perches for woodpeckers.
Appendix B Page 3 of 20

Incorporate newer research that meets the needs of cavity-nesting species, and current direction. 

Hopkins (1992) determined that old growth lodgepole pine contained an average 5 snags/ac; 

Evans and Martens (1995) as cited in Bull et al. (1997) reported/recommended an average 6 snags 

>10 “ dbh/ac in lodgepole pine stands.

Ohmann and Waddell (2002) found a regional average of at least 6 snags >10” dbh/acre.

Ponderosa Pine, Mixed Conifer

Rationale for managing for 4 snags/acre

Provide structure for a variety of species needs (e.g. perches, drumming, flaking bark for roosts 

and nest, and some foraging habitat)

Provide some of this habitat in more open canopy habitat in the short-term

The minimum number of snags in old growth ponderosa pine was 3/acre (Hopkins et al. 1993), 

and Bull et al. (1997) reported or recommended an average of 3.5 snags/acre, with a majority 

over 20” dbh within ponderosa pine stands.

GTRs were calculated within the project area because current direction focuses on the project area.

From the DecAID Background Info page (Repository website): List of stand structural conditions

Open canopy structural condition: [tree stocking <10%] or [tree stocking >=10% and quadratic 

mean diameter (QMD) 1-9 inches (2.5-24.9 cm)] 

Small/medium trees structural condition: QMD 10-19 inches (25.0-49.9 cm) 

Larger trees structural condition: QMD >=20 inches (50.0 cm) 

Using this tool has provided a current snapshot of how the different habitats compare in their snag 

densities to what DecAID and the literature has found across the region in similar seral stages. 

Use of DecAID for analyzing cumulative effects to dead wood habitat within the Ogden 

Area:

A rule of thumb for determining the analysis area for green tree sales is 20 sq miles (=12,800 acres) 

minimum in EACH habitat type.

The following map illustrates the 10th field watersheds that overlap the Ogden project area and the 

cumulative effects area:
Appendix B Page 4 of 20

A majority of the project area and cumulative effects area overlaps the Lower Little Deschutes 

Watershed. Within the overlapping 10th field watershed (Lower Little Deschutes River) and, separately 

the Ogden cumulative effects area there is the following breakdown:

 Table B-1.

Habitat Type Lower Little Des (ac) Ogden Cumulative effects area (ac)

EMC* 16,698 3,874

LP 32,312 35,330

MMC 3,403 5,801

NONE 10,556 16,673

PPDF* 22,397 43,547
Appendix B Page 5 of 20

The one watershed meets the minimum analysis area size for the EMC, LP, and PPDF. Although the 

NONE type does meet the minimum size, it represents areas that would not have snags or logs anyway 

(e.g. rock slopes, meadows, water features). Therefore this habitat type not meeting the minimum is not a 

concern. The MMC habitat type, however, is well below the minimum level. If we include the MMC 

habitat from the adjacent (overlapping) watersheds the following acreages will be added:

Lower Little Deschutes MMC = 3,403.31 ac

Long Prairie MMC = 230.40

Lower Dry River MMC = 1,019.90

North Unit Diversion Dam – Deschutes River MMC = 17.57 ac

Pine Lake-Devils Garden MMC = 39.36 ac

Upper Dry River MMC = 261.54 ac

TOTAL MMC = 4,972.08 acres

This is still below the minimum level, suggesting that this habitat type is naturally rare over the landscape 

with the largest portion (68%) of it being within the Lower Little Deschutes watershed.

Because a bulk of the project area and cumulative effects are lies within the Lower Little Deschutes 

Watershed, and in effort to keep the entire EIS analysis consistent and meaningful to an informed 

decision, the landscape level analysis for dead wood using the DecAID tool will focus on the Lower Little 

Deschutes Watershed.

Although the watershed does not encompass the entire cumulative effects area, the relative proportions of 

each habitat type in the watershed compared to the cumulative effects area are similar.

Table B-2. Percent of landscape/watershed with the snag density (# >10 “ dbh/acre)

DecAID 

Habitat Totals % Watershed 0 0-6 6-12 12-18 18-36 36+

EMC 16,698 19.56 32% 48% 9% 5% 5% 0%

LP 32,312 37.85 52% 32% 15% 1% 1% 0%

MMC 3,403 3.99 100% 0% 0% 0% 0% 0%

NONE 10,556 12.36 100% 0% 0% 0% 0% 0%

0 0-4 4-8 8-12 12+

PPDF 22,397 26.24 59% 33% 6% 0% 2%

This table shows that a majority of the watershed, and thus landscape, has relatively low snags densities 

(0-12/acre). Similarly, areas with high densities of snags, regardless of habitat type, are relatively rare on 

the landscape. Therefore habitat for species that use areas with high densities of snags (e.g. Williamson’s 

sapsuckers) is relatively rare on the landscape.

In comparing the local watershed data (derived from FVS) for snag levels and the wildlife data within 

DecAID (along with the S&Gs for snags), the following observations can be made:
Appendix B Page 6 of 20

Table B-3. Snag densities for wildlife species at 30, 50, 80 percent tolerance level for snags > 10”dbh based on 

wildlife data in DecAID (Table references included).

1 Current Direction (LRMP & NWFP) is provided by habitat type and densities >10”. It is not broken down into tolerance levels 

but rather represents a biological potential which has been determined to be a flawed technique (Rose et al. 2001 in Johnson and 

O’ Neil 2001)

For the LP Habitat Type:

2% of this habitat type in the watershed meets the 30-80% tolerance levels for marten 

(12-14 snags/ac >10” dbh)

17% of this habitat type in the watershed meets or exceeds S & G levels (6 snags/acre)

30% Tolerance level 

(#snags/acre)

50% Tolerance level 

(#snags/acre)

80% Tolerance level 

(#snags/acre)

>10”dbh >10”dbh >10”dbh

LP_S/L (reference Table LP_S/L.sp-22)

AMMA 12 13 14

Current Direction for LP 6

PPDF_S/L (reference Table 

PPDF_S/L.sp-22)

Black-backed woodpecker (BBWO) 2.5 14 29

Cavity-Nesting Birds (CNB) 1 5 10

Pileated Woodpecker (PIWO) 15 30 49

Pygmy Nuthatch (PYNU) 1 6 12

White-headed woodpecker (WHWO) 0.3 2 4

Williamson’s Sapsucker (WISA) 14 28 50

Current Direction for the Ponderosa 

Pine1 

4

EMC_ECB_S/L (reference Table 

EMC_ECB_S/L.sp.22)

Black-backed woodpecker (BBWO) 2.5 14 29

Pileated Woodpecker (PIWO) 15 30 49

Pygmy Nuthatch (PYNU) 1 6 12

White-headed woodpecker (WHWO) 0.3 2 4

Williamson’s Sapsucker (WISA) 14 28 50

American Marten (AMMA) 12 13 14

Current Direction for Mixed Conifer 4

MMC_S/L (reference Table 

MMC_S/L.sp-22)

American Marten (AMMA) 12 13 14

Pacific Fisher (FISH) ? 13 ?

Current Direction for Mixed Conifer 4
Appendix B Page 7 of 20

For the PPDF Habitat Type:

8% of this habitat type meets or exceeds S & Gs (4 snags/acre)

41% of this habitat type in the watershed meets the 30% tolerance level for blackbacked woodpeckers (2.5 snags/ac >10” dbh)

8% of this habitat type in the watershed meets the 50-80% tolerance levels for blackbacked woodpeckers (14-29 snags/ac >10” dbh)

41% of this habitat type in the watershed meets the 30-50% tolerance levels for whiteheaded woodpeckers (0.3-2 snags/ac >10” dbh)

8% of this habitat type in the watershed meets the 80% tolerance level for whiteheaded woodpeckers (4 snags/ac >10” dbh)

2% of this habitat type in the watershed meets the 30-80% tolerance levels for 

Williamson’s sapsuckers (14-50 snags/ac >10” dbh)

8% of this habitat type in the watershed meets the 50-80% tolerance levels for cavitynesting birds (5-10 snags/ac >10” dbh)

41% of this habitat type in the watershed meets the 30% tolerance level for cavitynesting birds (1 snags/ac >10” dbh)

2% of this habitat type in the watershed meets the 30-80% tolerance levels for pileated 

woodpeckers (15-49 snags/ac >10” dbh)

41% of this habitat type in the watershed meets the 30% tolerance level for pygmy 

nuthatches (1 snags/ac >10” dbh)

8% of this habitat type in the watershed meets the 50% tolerance level for pygmy 

nuthatches (6 snags/ac >10” dbh)

2% of this habitat type in the watershed meets the 80% tolerance level for pygmy 

nuthatches (12 snags/ac >10” dbh)

For the EMC Habitat Type

68% of this habitat type meets or exceeds S & Gs (4 snags/acre)

68% of this habitat type in the watershed meets the 30% tolerance level for blackbacked woodpeckers (2.5 snags/ac >10” dbh)

10% of this habitat type in the watershed meets the 50% tolerance levels for blackbacked woodpeckers (14 snags/ac >10” dbh)

5% of this habitat type in the watershed meets the 80% tolerance levels for blackbacked woodpeckers (29 snags/ac >10” dbh)

68% of this habitat type in the watershed meets the 30-80% tolerance levels for whiteheaded woodpeckers (0.3-4 snags/ac >10” dbh)

10% of this habitat type in the watershed meets the 30% tolerance levels for 

Williamson’s sapsuckers (14snags/ac >10” dbh)

5% of this habitat type in the watershed meets the 50% tolerance levels for 

Williamson’s sapsuckers (28 snags/ac >10” dbh)

0% of this habitat type in the watershed meets the 80% tolerance levels for 

Williamson’s sapsuckers (50 snags/ac >10” dbh)

10% of this habitat type in the watershed meets the 30% tolerance level for pileated 

woodpeckers (15 snags/ac >10” dbh)

5% of this habitat type in the watershed meets the 50% tolerance level for pileated 

woodpeckers (30 snags/ac >10” dbh)

0% of this habitat type in the watershed meets the 80% tolerance level for pileated 

woodpeckers (49 snags/ac >10” dbh)
Appendix B Page 8 of 20

68% of this habitat type in the watershed meets the 30% tolerance level for pygmy 

nuthatches (1 snags/ac >10” dbh)

19% of this habitat type in the watershed meets the 50% tolerance level for pygmy 

nuthatches (6 snags/ac >10” dbh)

10% of this habitat type in the watershed meets the 80% tolerance level for pygmy 

nuthatches (12 snags/ac >10” dbh)

10% of this habitat type in the watershed meets the 30-80% tolerance levels for marten 

(12-14 snags/ac >10” dbh)

For the MMC Habitat Type:

No snags were recorded in this habitat type within the watershed; therefore 0% of this 

habitat type in the watershed meets any tolerance level for marten and fisher (12-14 

snags/acre >10” dbh)

In tabular format: 

Table B-4. Percent of watershed meeting the tolerance level for selected species 

30% Tolerance Level

(#snags >10”dbh/ac)

50% Tolerance Level

(#snags >10”dbh/ac)

80% Tolerance Level

(#snags >10”dbh/ac)

Lodgepole Pine

American Marten 2 2 2

Standard and Guideline 17

Ponderosa Pine/Douglasfir

Black-backed Woodpecker 41 8 8

Cavity Nesting Birds 41 8 8

Pileated Woodpecker 2 2 2

Pygmy Nuthatch 41 8 2

White-headed Woodpecker 41 41 8

Williamson’s Sapsucker 2 2 2

Standard and Guideline 8

Eastside-Mixed Conifer

Black-backed Woodpecker 68 10 5

Pileated Woodpecker 10 5 0

Pygmy Nuthatch 68 19 10

White-headed Woodpecker 68 68 68

Williamson’s Sapsucker 10 5 0

American Marten 10 10 10

Standard and Guideline 68

Montane Mixed Conifer
Appendix B Page 9 of 20

American Marten 0 0 0

Pacific Fisher 0 0 0

Standard and Guideline 0

According to the above table, white-headed woodpeckers appear to have the greatest amount of habitat, 

this may be due to the fact that the literature cited within DecAID showing white-headed woodpecker 

using areas with relatively low densities of snags (0.3-4 snags/acre) as compared to a species such as the 

Williamson’s sapsucker that utilizes areas with 14-50 snags per acre.

In relation to Standard & Guideline levels, a majority of the Eastside Mixed Conifer habitat type appears 

to be meeting the standard and guideline levels. The landscape is deficient in meeting the standard and 

guideline levels in the Lodgepole, Ponderosa Pine/Douglas-fir,and Montane Mixed Conifer habitats.

In comparing the inventory data within DecAid, each habitat type is displayed with the only unharvested 

plots and then all plots (which include harvested and unharvested). The inventory data can give a 

comparison of the watershed with the larger landscape at a given snapshot in time (i.e. when the plot 

measurements were taken). This is useful when comparing the watershed information with the larger 

landscape in order to determine the relation of the watershed densities with the inventory densities. The 

densities were derived from the histograms within the DecAID tool for the small/medium habitat type 

(tree dbh averaging 10-19 inches) for this best represented the average size classes within the project area:

Table B-5. Percent of landscape/watershed with the snag density (# >10 “ dbh/acre)

DecAID 

Habitat 0 0-6 6-12 12-18 18-36 36+

EMC Watershed 32% 48% 9% 5% 5% 0%

low Unharvested plots 15% 25% 17% 18% 19% 7%

All Plots 28% 31% 18% 10% 10% 3%

LP Watershed 52% 32% 15% 1% 1% 0%

low Unharvested plots 26% 13% 23% 11% 17% 9%

All Plots 33% 21% 21% 9% 11% 5%

MMC Watershed 100% 0% 0% 0% 0% 0%

low Unharvested plots 5% 14% 19% 15% 32% 15%

All Plots 6% 17% 20% 14% 29% 12%

0 0-4 4-8 8-12 12+

PPDF Watershed 59% 33% 6% 0% 2%

Close to 

expected Unharvested plots 54% 30% 10% 3% 3%

All Plots 60% 26% 9% 2% 1%

Only the ponderosa pine/Douglas-fir habitat type within the watershed comes close to the plot data. All 

of the habitat types are low. This watershed is deficient in snags at the larger landscape level.
Appendix B Page 10 of 20

Wildlife – PAULINA CREEK OLD GROWTH MANAGEMENT AREA 

PLAN

Introduction

Fuels reduction and large structure maintenance are proposed management actions within the Paulina Old 

Growth Management Area (hereafter referred to as OGMA). The Environmental Impact Statement (EIS) 

for the Ogden Vegetation and Fuels Management Project is expected to cover the full analysis of these 

actions as they relate to the larger landscape. 

The LRMP designated OGMAs (i.e. Management Area 15) and provides Standards and Guidelines 

(LRMP 4-149-151) for their management. In addition, the Wildlife Program and Activity Schedule in the 

LRMP Goal 4 (Chapter 5, Implementation of the Forest Plan, Appendix 15-4) has an objective of 

determining existing condition together with management needs, if any, of Old Growth Management 

Areas. It also directs two activities: 1) survey to determine how much is old growth and identify 

management needs, and 2) prepare a management plan for old growth management areas in need of 

special treatment measures. 

Current Condition

The management indicator species for the OGMA are the black-backed woodpecker in lodgepole forest, 

goshawk in ponderosa pine forest, and the American marten in the mixed conifer forest. All three forest 

types can be found within the Paulina OGMA (see Table B-6 and Figure B-1).

Table B-6: Size Class and Species Distribution within the Paulina Creek OGMA

Ponderosa Pine Mixed Conifer Lodgepole Pine PIPO & LP Open, Grass or 

Shrub

Total (acres) 408 104 371 49 330

Size Class:

Large 21 0 2 0

Medium 56 48 9 1

Small 198 48 19 6

Pole 133 8 322 43

Seed/Sap 0 0 18 0
Appendix B Page 11 of 20

A large part of the OGMA is made up of the smaller size classes (<15” average dbh) and lower canopy 

closures (< 40%). For the focal species this condition is not ideal particularly for the American marten or 

goshawk. Marten favors an understory with high levels of dead and down wood and a dense overstory 

canopy (Maser 1998). Martens prefer mature forests with closed canopies, but sometimes use openings in 

forests, if there are sufficient downed logs to provide cover. The type of forest is less important to 

martens than forest structure (Csuti et al., 2001). Small mammals are a large portion of their diet, so the 

understory micro-habitats to support shrews, voles, rabbits, chipmunks, etc. are important. Both pine 

(Douglas) squirrels and chipmunks were observed in the OGMA. Berry producing shrubs are also 

important (Maser 1998). 

Figure B-2. Species spatial distribution within the Paulina Creek OGMA.

0

100

200

300

400

500

600

Total Acres

Size Class

Fig. C-1 Size Class & Canopy Closure Distribution 

within the Paulina OGMA

Acres

25-40% Canopy

closure

40-55%

55-70%
Appendix B Page 12 of 20

Figure B-3. Size class spatial distribution within the Paulina Creek OGMA.
Appendix B Page 13 of 20
Appendix B Page 14 of 20

Figure B-4. Canopy closure spatial distribution within the Paulina Creek OGMA.
Appendix B Page 15 of 20

The McKay Fire in 1998 burned through the OGMA. This was a stand replacing burn resulting in a gap 

in the continuous mature forest along the riparian area. Habitat for the marten and goshawk was lost as a 

result of this fire.

The black-backed woodpecker prefers mature lodgepole pine habitats with dead or dying trees, but will 

utilize other types (Csuti et al. 2001). The species is strongly associated with natural fire cycles (Marshall 

et al., 2006). The burnt forest once provided both abundant forage opportunities, as well as nesting sites 

for black-backs. However, the burned area provides good foraging habitat for only a few years. The 

present condition of the OGMA does not provide an adequate amount of habitat because snags have 

blown down. 

The black-backed has a home range from 100 to 400 acres but may expand in areas with bark beetle 

outbreaks to 173-810 acres (Marshall et al., 2001). They use mature ponderosa pine and lodgepole pine 

habitat types at relatively low elevations (Goggins et al. 1988). Older forests with greater amounts of 

snags and down wood, which host wood-boring insects (average 59-74% of total diet), ants, beetles, and 

spiders, provide more foraging resources for this species (Csuti et al., 2001) than younger, managed 

forests. Both focal species are very mobile, and the OGMA will meet their needs on the landscape as 

time progresses and conditions change. The OGMA may act as a transition area of habitat to the east 

where the higher elevations has not received fire and have a mix of forest types and size classes to 

provide habitat.

In summary, the habitat quality of the original OGMA has deteriorated due to the fire and subsequent 

blow down. At the lower or eastern end there is a high risk wildfire due the presence of a developed 

campground and smaller dispersed campsites along the creek. 

Recommended Management Actions

As the sole stream course in this watershed, it is vital to retain this OGMA despite its current conditions 

that lack some overall old-growth characteristics (i.e. large trees common, high canopy closures). It does 

contain more species, size class, and canopy closure diversity than many of the other areas within the 

watershed.

As the sole stream course, the OGMA is also heavily used by recreationists. The Peter Skene Ogden 

National Scenic Trail follows through the OGMA. There is one designated campground, McKay, which 

receives heavy use nearly all year. There are at least two other dispersed recreation sites within the 

OGMA. The stream corridor is used by hikers, mountain bikers, and horseback riders. The advertised 

feature called the “Paulina Plunge” is a recreation opportunity whereby bikers can be shuttled to the crater 

and then rode down along the powerline on bikes with “jaunts” into the stream corridor. Many of these 

“jaunts” are within the OGMA. In summary, this OGMA does not give a feeling of seclusion.

Because of this heavy recreation use, especially the camping, there is high risk of another wildfire burning 

through the OGMA. The 1998 fire was lightning started and ran north to south. Should a fire start from 

an ill-tended campfire, it would certainly burn up through the stream course. Fuels reduction efforts in 

the vicinity of the developed campground and dispersed sites are recommended.

This OGMA contains the feature whereby the south-facing slopes contain largely ponderosa pine and 

other hot, dry favoring species. Whereas the north-facing slopes contain the true fir, Douglas-fir, and 

western white pine associated with cooler, moister sites. This is unique to the watershed. 

The south-facing slopes east of the 1998 burn, in particular, contain groves of large ponderosa pine. 

Because of the inherent size-class and tree species diversity in a relatively small area (1,263 acres), it is 

recommended that these groves of large ponderosa pine on the south facing slopes also have fuelreduction and thinning treatments applied to prolong and protect the larger trees.
Appendix B Page 16 of 20

Recommended treatments should be extended into the riparian reserve boundary; with extra care given to 

the unique riparian vegetation zones. Extra care may entail restrictions on machinery and slash 

treatments.

Other recommendations would include the discouragement of dispersed camping within the OGMA. 

Access to some of these sites is by breeching closed roads. These closures need to be better fortified and 

patrolled to make it harder to get to these sites thereby reducing the risk of an ill-tended campfire.

Summary of Recommendations

Conduct fuel reduction activities (thinning and burning of piled slash) around the developed 

campground and dispersed sites in order to reduce the likelihood of a fire start due to carelessness by 

campers. 

Focus old growth ponderosa pine restoration and protection on the south-facing slopes where large 

ponderosa pines are already present. This would include some understory thinning.

Any thinning should attempt to leave adequate down and dead wood for marten and prey species, e.g. 

large logs, piles.

Monitor the existing road closures and if any are breeched immediately address the problem via 

closure or obliteration in order to maintain solitude within the OGMA.
Appendix B Page 17 of 20

Further Evaluation for Road Density within the Ogden Planning 

Area

The Deschutes LRMP contains the following Standard and Guidelines in regards to road densities and 

wildlife impacts:

Mule Deer Outside Deer Management Area 7 (Summer Range)

WL-53 Target open road densities are 2.5 mi/sq. mi to achieve deer summer range habitat effectiveness 

targets unless impacts on deer can be avoided or the proposed project would result in a net benefit to deer 

habitat. The density will be applied as an average for an implementation unit and will be used as a 

threshold requiring a further evaluation...If existing or proposed open road densities would exceed the 

threshold guideline. The final judgment on open road density will be based on the further evaluation 

rather than the density guideline.

TS-11 To achieve the Forest’s wildlife objectives, open road density must be managed. Density 

guidelines are not intended to be objectives in themselves, but are means to accomplish wildlife resource 

objectives. Therefore, open road densities will be evaluated in relation to the needs and sensitivity of sitespecific wildlife habitats and populations. 

TS-12 ...Guideline densities will be used as thresholds for a further evaluation and will not serve as the 

basis for assessing conformance with the Forest Plan.

TS-13 If a preferred project alternative would exceed these guidelines, a detailed further evaluation by a 

wildlife biologist would be required. The evaluation would include the biologist’s best professional 

judgment on the effects of proposed projects open road density on wildlife habitat use, site-specific 

factors supporting this judgment, and possible mitigation measures. If the evaluation concludes the net 

effect of the project is compatible with Forest Plan wildlife objectives as proposed or with mitigation 

measures, or significantly enhances the conformance of the Implementation Unit with wildlife objectives, 

the project will be considered compatible with Forest Plan direction.

TS-14 The biologist’s evaluation would be used by the project ID Team and line officer in deciding on a 

plan which best satisfies multi-resource needs, and in preparing the NEPA document and Decision 

Notice. The line officer may select an open-road density that exceeds the biologist’s evaluation. 

Selection of project alternatives, which the further evaluation finds are not compatible with Forest Plan 

wildlife objectives or will not significantly enhance conformance of the Implementation Unit with 

wildlife objective, will require an amendment of the Plan.

Implementation Unit: In 1990, when the Forest Plan was written and adopted, Implementation Units 

were a larger landscape unit by which to address effects. Often they took in multiple project areas, but 

did not necessarily follow landscape features (e.g. watershed boundaries). In 2011 and 2012, the Forest 

undertook a Forest-level analysis for Management Indicator Species (MIS). Deer and elk are MIS species 

along with many other species. In order for the Forest level analysis be consistent with current vegetation 

databases, species analyses, and be able to be compared and analyzed across project and district 

boundaries, the artificial Implementation Unit designation was replaced with the overlapping 

Subwatershed boundaries for the project.

Ogden Planning Area

Road densities for summer range vary drastically by watershed. Some sub-watersheds which are highly 

associated with wilderness areas have very low road densities. All but one of the 12th field subwatersheds exceeds Forest Plan objectives for open road densities. Upper Paulina Peak Subwatershed is 

largely taken up by the Newberry Crater itself, thus it is the Subwatershed with the lowest road density.
Appendix B Page 18 of 20

Table B-7 Mule Deer Summer Range habitat at different landscape scales 

Landscape Scale overlapping the 

Ogden Project Area

Acres of Hiding 

cover

% of 

Subwatersh

ed 

Open Road Density

(mi./sq. mi.) 

Deschutes National Forest 715,226

Long Prairie Watershed 49,715

Finley Butte 6,229 62 4.03

Paulina Peak South 10,394 66 3.74

Lower Little Deschutes Watershed 38,613

Kawak Butte 5,890 53 2.84

Lower Paulina 9,228 54 3.31

LaPine 1,320 37 4.61

Wickiup Junction 4,595 51 4.30

Upper Paulina Peak 8,155 64 1.13

Ogden Planning Area 13,308 50 4.22

The current road density in the Ogden project area is 4.22 miles per sq. mile. An additional total of 8.5-

11.4 miles (in 0.09-0.8 mile segments) of temporary road will be built in order to access 33-43 different 

units. These will be closed upon project completion. Furthermore, implementation of the Access and 

Travel Management Plan reduces use on 0.05 mi/sq. mile of roads (i.e. roads closed under previous 

NEPA decisions not showing up on maps).

Evaluation:

Current open road densities within the project area and most of the subwatersheds are clearly exceeding 

the 2.5 mi/sq. mile threshold (Table B-7). Hiding cover is also currently exceeding within the project area 

and many of the subwatersheds. Because hiding cover levels are relatively high, the impacts of the road 

densities may be small on the big game populations because the deer and elk have escape/security cover.

The action alternatives will not change the road density in the project area or the subwatersheds.

The action alternatives will reduce the amount of hiding cover in the project area and subwatersheds. In 

some areas this may be a short-term impact as stands are allowed to grow back. However within the 

Wildland-Urban Interface along the west end of the project area, and around developed recreation sites 

the impact would potentially be for the long-term as maintenance of low fuel loadings is often 

recommended. Potential need for maintenance fuel treatments in these areas and subsequent hiding cover 

loss would be additive to the high open road densities and its negative impacts to big game.

Permanent road closures (i.e. obliterations) within the Ogden project area are difficult to achieve because 

of other resource needs (e.g. fire management) and the degree of recreation use throughout the year. The 

project area is popular in spring, summer, and fall for camping, hunting, and hiking/biking. In the winter, 

it is a popular area for snowmobiling and cross-country skiing. Although deer and elk may minimally use 

the area in the winter, the infrastructure for the winter activities are there year round (e.g. snoparks, 

routes, etc.). The added use of the area for geothermal exploration and volcanic monitoring also 

contributes to the need for roads.

A formal roads analysis was associated with the foreseeable Lava Rock OHV proposal. This effort

recommends 58 miles of road closure within the Ogden planning area. The resulting road density after 

the proposed 58 miles of road closure will be 2.8 mi/square mile; slightly more than the LRMP 
Appendix B Page 19 of 20

recommended level of 2.5 mi/square mile. This would significantly enhance conformance with the 

LRMP to move towards the 2.5 mi/square mile density, once the proposal is implemented. 

Recent literature (Frair et al. 2008) has suggested that the threshold of approximately 0.8 mi/sq. mi. (0.5 

km/sq. km) or less had the highest probability of elk occurrence where elk were hunted. Road effects 

began to saturate the landscape at 1.6-2.4 mi/sq. mi (1-1.5 km/sq. km), and higher densities may be 

tolerated if human access were managed (e.g. seasonal closures). Although the proposed road closures 

will help meet the intent of the LRMP, the foreseeable closing of roads associated with the Lava Rock 

OHV proposal may not eliminate all impacts to big game. The effectiveness of the road closures may be 

compromised by the current need to provide safe and suitable access to geothermal actions being 

conducted or planned within the project area (letter from Mr. Perry, President Davenport Newberry 

Holdings LLC, February 10, 2010), and the reasonably foreseeable maintenance and expansion of 

snowmobile and OHV trails, which are not necessarily factored into road density estimates. These 

ongoing and foreseeable actions contribute to negative impacts to big game security and potentially 

survivability (i.e. lack of escape cover and hunting mortality).

The current high density and existing recreational and management use of the roads underscores a need to 

retain large patches of cover for big game. Alternative 3 has fewer additive effects than Alternative 2 

because it treats fewer acres of hiding cover with fuels prescriptions (e.g. mowing and underburning). 

Big game use of the area may shift spatially as a result of either alternative and effort was made to 

maintain large patches of hiding cover in areas where it has been shown deer use. The reduction of hiding 

cover as a result of the proposed actions coupled with the ongoing recreational use will cause big game to 

either move through the area faster or remain in areas with cover and without disturbances, or both. This 

may put pressure on the foraging conditions in the areas where there is hiding cover. The larger 

geothermal developments would add to the loss of hiding cover in the case of drilling pads being 

constructed.

The cumulative effects of the proposed actions with the ongoing and foreseeable recreational uses and 

geothermal developments will decrease the number of acres of refugia or areas of habitat without 

disturbance. This may result in a shift in use patterns for big game and likely have a negative effect on 

big game population trends on the Forest. Therefore negative impacts to big game (e.g. more movement, 

less security, and more mortality) will continue to occur.

Table B-8. Summary of proposed activities’ effects by alternative. 

Existing/No

Action

Alternative 2 Alternative 3

Hiding Cover (acres)

Forest (in summer range) 715,226 (45%) 709,647 (45%) 710,548 (45%)

Subwatersheds 45,811 (58%) 40,232 (51%) 41,133 (52%)

LRMP Standard & Guideline 30% 30% 30%

Road Density (mi/sq. mi.)

Range over Subwatersheds 1.08-4.56 1.72-4.51* 1.72-4.51*

Project Area 4.22 4.17 4.17

Standard & Guideline 2.5 2.5 2.5

*There is a net reduction of 0.05 mi/sq.mi of road in the project area. This figure represents the range of the 

subwatersheds that make up the largest part of the project area (i.e. Lower Paulina Creek and Wickiup Junction)
Appendix B Page 20 of 20

Determination

Although the proposed actions would have negative impacts on deer and elk due to the removal of hiding 

cover and exceeding the threshold for open road density, hiding cover would remain above the Standard 

and Guideline level for the subwatersheds overlapping the project area (WL-54 that says “Hiding areas 

must be present over at least 30 percent of the National Forest in each implementation unit”). Therefore 

the project is compatible with Forest Plan wildlife objectives and an amendment is not required (TS-13).

Wildlife objectives in the Forest Plan would be best met with implementation of the road closures 

proposed within the analysis conducted for the Lava Rock OHV proposal.
Appendix C Page 1 of 17

APPENDIX C

Soils Analysis – Estimated Detrimental Disturbance 

by Unit and Alternative
Appendix C Page 2 of 17

– –

Table D-1: Soils - Alternative 2 - Unit Table 

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

1 42 5% PP_LP_1 18%

2 19 HCR 15% PP_LP_1 20 – 25% 20%

3 13 5% PP_LP_1 18%

4 3 HCR 15% PP_LP_1 20 – 25% 20%

5 22 5% PP_LP_1 18%

6 138 5% PP_LP_1 18%

7 15 5% PP_LP_1 18%

8 63 HCR 15% PP_LP_1 20 – 25% 20%

9 38 5% PP_LP_1 18%

10 28 HOR 15% PP_LP_1 20 – 25% 20%

11 44 HOR 15% PP_LP_1 20 – 25% 20%

13 12 HCR 15% PP_LP_1 20 – 25% 20%

14 147 5% PP_LP_1 18%

15 31 HCR 15% PP_LP_1 20 – 25% 20%

16 10 HOR 15% PP_LP_1 20 – 25% 20%

17 53 HOR 15% PP_LP_1 20 – 25% 20%

18 36 5% PP_LP_1 18%

19 56 HFR 15% PP_LP_1 20 – 25% 20%

20 20 5% PP_LP_1 18%

21 60 5% PP_LP_1 18%

22 114 5% PP_LP_1 18%

23 17 5% PP_LP_1 18%

24 55 5% PP_LP_1 18%

25 143 5% PP_LP_1 18%

26 36 5% PP_LP_1 18%

27 11 5% PP_SPC 15%

28 96 HOR 15% PP_LP_1 20 – 25% 20%

29 45 HTH 15% PP_LP_1 20 – 25% 20%

30 41 HOR 15% PP_1 20 – 25% 20%

31 84 HPR 10% PP_1 15%

32 39 HOR 15% PP_1 20 – 25% 20%

33 82 HPR 10% PP_1 15%

34 11 HPR 10% PP_1 15%

35 128 HTH 15% PP_1 20 – 25% 20%

36 252 HTH 15% PP_1 20 – 25% 20%

37 138 HTH 15% PP_1 20 – 25% 20%

38 26 HTH 15% PP_1 20 – 25% 20%

39 96 HTH 15% PP_1 20 – 25% 20%

40 138 HTH 15% PP_1 20 – 25% 20%

41 93 HTH 15% PP_1 20 – 25% 20%

42 44 HTH 15% PP_1 20 – 25% 20%

43 20 HPR 10% PP_1 15%

44 19 HTH 15% PP_1 20 – 25% 20%

45 22 5% PP_1 15%

46 65 5% PP_1 15%

47 85 HPR 10% PP_1 15%
Appendix C Page 3 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

48 17 HPR 10% PP_1 15%

49 117 HFR 15% None 20 – 25% 15%

50 60 HTH 15% PP_1 20 – 25% 20%

51 10 HTH 15% PP_1 20 – 25% 20%

52 25 HPR 10% MC_1 18%

54 12 HPR 10% MC_1 18%

55 41 HPR 10% MC_1 18%

56 4 5% MC_1 15%

57 60 HFR 15% MC_1 20 – 25% 20%

59 5 HPR 10% MC_1 18%

60 20 HCP 15% MC_SPC 20 – 25% 20%

61 10 HCP 15% MC_SPC 20 – 25% 20%

62 1 HCP 15% MC_SPC 20 – 25% 20%

63 34 HCC 15% LP_SPC 20 – 25% 20%

64 43 HCP 15% PP_SPC 20 – 25% 20%

65 34 HCC 15% LP_SPC 20 – 25% 20%

66 25 HCC 15% PP_SPC 20 – 25% 20%

67 19 HCR 15% LP_1 20 – 25% 20%

68 39 HCC 15% LP_SPC 20 – 25% 20%

69 23 5% LP_3 18%

70 37 HCC 15% LP_SPC 20 – 25% 20%

71 31 HCC 15% LP_SPC 20 – 25% 20%

72 5 HSV 15% LP_3 20 – 25% 20%

73 44 HCU 15% LP_1 20 – 25% 20%

74 5 HPR 10% LP_3 18%

75 9 HSV 15% LP_3 20 – 25% 20%

76 39 HCR 15% LP_1 20 – 25% 20%

77 5 5% LP_3 18%

78 63 HCR 15% LP_SPC 20 – 25% 20%

79 68 HCR 15% LP_1 20 – 25% 20%

80 8 HCR 15% LP_1 20 – 25% 20%

81 15 HSV 15% LP_3 20 – 25% 20%

82 23 HCR 15% LP_1 20 – 25% 20%

83 24 5% LP_3 18%

84 41 HCR 15% LP_1 20 – 25% 20%

85 8 5% LP_3 18%

86 37 HCR 15% LP_1 20 – 25% 20%

87 34 HCR 15% LP_1 20 – 25% 20%

88 5 5% LP_3 18%

89 28 HSV 15% LP_3 20 – 25% 20%

90 28 HCR 15% LP_1 20 – 25% 20%

91 88 HCR 15% LP_1 20 – 25% 20%

92 3 HCR 15% LP_1 20 – 25% 20%

93 14 HCR 15% LP_1 20 – 25% 20%

94 170 HCR 15% LP_SPC 20 – 25% 20%

95 67 HCR 15% LP_1 20 – 25% 20%

96 19 HCR 15% LP_1 20 – 25% 20%

97 36 HPR 10% MC_1 18%

98 31 HCR 15% LP_1 20 – 25% 20%

99 28 HCR 15% LP_1 20 – 25% 20%
Appendix C Page 4 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

100 27 HCC 15% LP_SPC 20 – 25% 20%

101 21 HFR 15% PP_SPC 20 – 25% 20%

102 16 HCU 15% PP_SPC 20 – 25% 20%

103 30 HCP 15% PP_SPC 20 – 25% 20%

104 37 HCC 15% LP_SPC 20 – 25% 20%

105 58 HSV 15% LP_3 20 – 25% 20%

106 77 HCR 15% LP_1 20 – 25% 20%

107 13 HCP 15% PP_SPC 20 – 25% 20%

108 13 5% MC_1 18%

109 11 HCC 15% LP_1 20 – 25% 20%

110 1 HPR 10% MC_1 18%

111 9 HPR 10% RHCA_MC 10-15%

112 5 HPR 10% RHCA_MC 10-15%

113 8 5% RHCA_MC 10-15%

114 14 5% RHCA_MC 10-15%

115 33 5% MC_1 18%

116 7 5% MC_1 18%

117 6 HPR 10% MC_1 18%

118 19 HPR 10% MC_1 18%

119 42 HFR 15% None 15%

120 11 HFR 15% PP_SPC 20 – 25% 20%

121 11 5% MC_1 18%

122 8 HPR 10% MC_1 18%

123 20 HTH 15% PP_SPC 20 – 25% 20%

124 76 HPR 10% MC_1 18%

125 48 HTH 15% None 15%

126 16 HTH 15% None 15%

127 9 HTH 15% None 15%

128 11 HCC 15% PP_SPC 20 – 25% 20%

129 4 HSV 15% PP_SPC 20 – 25% 20%

130 34 HCC 15% PP_SPC 20 – 25% 20%

131 106 HSV 15% PP_SPC 20 – 25% 20%

132 29 HCC 15% PP_SPC 20 – 25% 20%

133 43 HTH 15% None 15%

134 66 HTH 15% MC_1 20 – 25% 20%

135 8 5% MC_1 18%

136 61 HPR 10% MC_1 18%

137 21 5% MC_1 18%

138 27 5% RHCA_MC 10-15%

139 21 5% MC_1 18%

140 9 5% RHCA_PP_LP 10-15%

141 85 5% RHCA_PP_LP 10-15%

142 25 5% PP_1 15%

143 37 5% PP_1 15%

144 82 HFR 15% MC_1 20 – 25% 20%

145 87 HFR 15% MC_1 20 – 25% 20%

146 91 HFR 15% MC_1 20 – 25% 20%

147 32 HFR 15% MC_1 20 – 25% 20%

148 99 HTH 15% PP_1 20 – 25% 20%

149 20 HCR 15% PP_1 20 – 25% 20%
Appendix C Page 5 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

150 20 HFR 15% PP_1 20 – 25% 20%

151 135 HPR 10% PP_1 15%

152 5 HFR 15% PP_1 20 – 25% 20%

153 59 HFR 15% PP_1 20 – 25% 20%

154 20 5% PP_1 15%

155 16 HFR 15% PP_1 20 – 25% 20%

156 103 HOR 15% PP_1 20 – 25% 20%

157 38 5% PP_LP_1 18%

158 204 5% PP_LP_1 18%

159 80 5% RHCA_PP_LP 10-15%

160 44 5% PP_LP_1 18%

161 54 5% PP_LP_1 18%

162 173 SPC 5% PP_1 15%

163 23 HFR 15% PP_1 20 – 25% 20%

164 4 5% PP_1 15%

165 3 5% PP_1 15%

166 12 5% PP_1 15%

167 225 5% PP_1 15%

168 6 HFR 15% PP_1 20 – 25% 20%

169 10 HFR 15% PP_1 20 – 25% 20%

170 135 HFR 15% PP_1 20 – 25% 20%

171 55 5% PP_LP_1 18%

172 11 5% RHCA_PP_LP 10-15%

173 29 HOR 15% PP_LP_1 20 – 25% 20%

174 121 5% PP_LP_1 18%

175 41 5% PP_1 15%

176 8 5% PP_LP_1 18%

177 41 5% PP_LP_1 18%

178 136 HFR 15% PP_1 20 – 25% 20%

179 15 5% PP_1 15%

180 66 5% PP_1 15%

181 3 5% PP_1 15%

182 21 5% PP_1 15%

183 55 5% PP_1 15%

184 9 5% PP_1 15%

185 17 HFR 15% PP_1 20 – 25% 20%

186 20 5% PP_1 15%

187 141 HFR 15% PP_1 20 – 25% 20%

188 21 HFR 15% PP_1 20 – 25% 20%

189 7 5% PP_1 15%

190 18 5% PP_1 15%

191 13 5% PP_1 15%

192 23 5% PP_1 15%

193 31 5% PP_1 15%

194 36 HSV 15% PP_SPC 20 – 25% 20%

195 7 5% PP_SPC 15%

196 11 HFR 15% PP_1 20 – 25% 20%

197 28 HTH 15% PP_1 20 – 25% 20%

198 2 5% PP_LP_1 18%

199 23 HPR 10% PP_LP_1 20%
Appendix C Page 6 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

200 3 5% PP_LP_1 18%

201 25 HSL 10% PP_LP_1 20%

202 6 HCC 15% PP_LP_1 20 – 25% 20%

203 4 5% PP_LP_1 18%

204 22 HPR 10% PP_LP_1 20%

205 4 HOR 15% PP_LP_1 20 – 25% 20%

206 14 HPR 10% PP_LP_1 20%

207 30 5% PP_LP_1 18%

208 78 HCC 15% PP_LP_1 20 – 25% 20%

209 91 5% PP_LP_1 18%

210 7 HCP 15% PP_LP_SPC 20 – 25% 20%

211 56 5% PP_LP_1 18%

212 13 5% PP_LP_1 18%

213 7 HOR 15% PP_LP_1 20 – 25% 20%

214 170 HIM 10% PP_LP_1 18%

215 32 HOR 15% PP_LP_1 20 – 25% 20%

216 61 HSL 10% PP_LP_1 20%

217 4 5% PP_LP_1 18%

218 21 HCC 15% PP_1 20 – 25% 20%

219 12 HCC 15% PP_SPC 20 – 25% 20%

220 62 HSV 15% PP_SPC 20 – 25% 20%

221 6 HSV 15% PP_SPC 20 – 25% 20%

222 6 HIM 10% PP_SPC 15%

223 48 5% PP_SPC 15%

224 181 HSV 15% PP_SPC 20 – 25% 20%

225 30 HSV 15% PP_SPC 20 – 25% 20%

226 19 HCC 15% PP_SPC 20 – 25% 20%

227 9 5% PP_LP_1 18%

228 38 HOR 15% PP_LP_1 20 – 25% 20%

229 34 5% PP_LP_1 18%

230 98 HOR 15% PP_LP_1 20 – 25% 20%

231 30 5% PP_LP_1 18%

232 31 HOR 15% PP_LP_1 20 – 25% 20%

233 43 5% PP_LP_1 18%

234 20 HOR 15% PP_LP_1 20 – 25% 20%

235 35 5% PP_LP_1 18%

236 31 5% PP_LP_1 18%

237 20 HCR 15% LP_1 20 – 25% 20%

238 64 HOR 15% PP_LP_1 20 – 25% 20%

239 5 5% PP_LP_1 18%

240 5 HCC 15% PP_LP_1 20 – 25% 20%

241 36 HSL 10% PP_LP_1 20%

242 44 HOR 15% PP_LP_1 20 – 25% 20%

243 34 HSL 10% PP_LP_1 20%

244 25 HIM 10% PP_LP_1 18%

245 5 5% PP_LP_1 18%

246 14 5% PP_LP_1 18%

247 70 HOR 15% PP_LP_1 20 – 25% 20%

248 14 HSL 10% PP_LP_1 20%

249 31 HCP 15% PP_LP_1 20 – 25% 20%
Appendix C Page 7 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

250 43 HCP 15% PP_LP_1 20 – 25% 20%

251 126 5% PP_LP_1 18%

252 15 HOR 15% PP_LP_1 20 – 25% 20%

253 45 5% PP_LP_1 18%

254 94 HOR 15% PP_LP_1 20 – 25% 20%

255 22 HSL 10% PP_LP_1 20%

256 36 5% PP_LP_1 18%

257 51 5% PP_LP_1 18%

258 84 HOR 15% PP_LP_1 20 – 25% 20%

259 31 HSL 10% PP_1 15%

260 29 HSL 10% PP_1 15%

261 16 HSL 10% PP_1 15%

262 10 HSL 10% PP_1 15%

263 62 HSL 10% PP_1 15%

264 11 HFR 15% PP_LP_1 20 – 25% 20%

265 151 5% PP_LP_1 18%

266 29 HFR 15% PP_LP_1 20 – 25% 20%

267 86 5% PP_LP_1 18%

268 106 5% PP_LP_1 18%

269 115 5% PP_LP_1 18%

270 16 HCC 15% PP_LP_1 20 – 25% 20%

271 10 5% PP_LP_1 18%

272 45 HSL 10% PP_LP_1 20%

273 150 HFR 15% PP_LP_1 20 – 25% 20%

274 45 HOR 15% PP_LP_1 20 – 25% 20%

275 27 HSL 10% PP_LP_1 20%

277 24 HIM 10% PP_LP_1 18%

278 86 HOR 15% PP_LP_1 20 – 25% 20%

279 59 5% PP_LP_1 18%

280 4 HCC 15% PP_LP_SPC 20 – 25% 20%

281 91 HTH 15% PP_1 20 – 25% 20%

283 86 HTH 15% MC_1 20 – 25% 20%

284 19 HSL 10% MC_1 18%

285 25 5% MC_1 18%

286 12 5% MC_1 18%

287 25 HOR 15% MC_1 20 – 25% 20%

288 13 HSV 15% PP_SPC 20 – 25% 20%

289 14 HCR 15% LP_1 20 – 25% 20%

290 45 HCR 15% LP_SPC 20 – 25% 20%

291 9 HSV 15% MC_1 20 – 25% 20%

292 2 5% MC_1 18%

293 20 HCU 15% LP_1 20 – 25% 20%

294 3 5% LP_3 18%

295 10 HSV 15% LP_3 20 – 25% 20%

296 27 HCC 15% LP_SPC 20 – 25% 20%

297 13 5% LP_3 18%

298 25 HCU 15% LP_1 20 – 25% 20%

299 15 5% LP_3 18%

300 9 HSV 15% LP_3 20 – 25% 20%

301 7 5% LP_3 18%
Appendix C Page 8 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

302 5 5% LP_3 18%

303 17 HSV 15% LP_3 20 – 25% 20%

304 15 5% LP_3 18%

305 24 HCU 15% LP_1 20 – 25% 20%

306 8 5% LP_3 18%

307 13 HCU 15% LP_1 20 – 25% 20%

308 7 HSV 15% MC_2 20 – 25% 20%

309 37 HCC 15% PP_SPC 20 – 25% 20%

310 27 HCU 15% LP_1 20 – 25% 20%

311 14 HCC 15% LP_SPC 20 – 25% 20%

312 15 HCC 15% PP_SPC 20 – 25% 20%

313 13 HCU 15% LP_1 20 – 25% 20%

314 28 HCR 15% LP_1 20 – 25% 20%

315 1 HCR 15% LP_1 20 – 25% 20%

316 1 HCR 15% LP_1 20 – 25% 20%

317 6 5% LP_3 18%

318 9 HCC 15% LP_SPC 20 – 25% 20%

319 1 HCC 15% LP_SPC 20 – 25% 20%

320 9 5% LP_3 18%

321 17 HSV 15% LP_3 20 – 25% 20%

322 12 HCR 15% LP_1 20 – 25% 20%

324 6 5% LP_3 18%

325 26 HCR 15% LP_1 20 – 25% 20%

326 1 HCR 15% LP_1 20 – 25% 20%

327 12 5% MC_1 18%

328 5 5% LP_3 18%

330 10 HCR 15% LP_1 20 – 25% 20%

331 23 5% MC_1 18%

332 14 HCR 15% LP_1 20 – 25% 20%

333 39 5% MC_1 18%

334 28 HCR 15% LP_1 20 – 25% 20%

335 10 HCU 15% PP_SPC 20 – 25% 20%

337 3 HFR 15% MC_1 20 – 25% 20%

338 13 HCU 15% MC_1 20 – 25% 20%

339 19 HCU 15% PP_SPC 20 – 25% 20%

340 67 HFR 15% MC_SPC 20 – 25% 20%

341 23 HOR 15% LP_SPC 20 – 25% 20%

342 48 5% MC_1 18%

343 19 HSL 10% MC_1 18%

345 11 HFR 15% MC_1 20 – 25% 20%

346 67 HFR 15% MC_SPC 20 – 25% 20%

347 12 HCU 15% LP_1 20 – 25% 20%

348 15 HCU 15% MC_1 20 – 25% 20%

350 13 HTH 15% MC_1 20 – 25% 20%

351 6 5% MC_1 18%

352 55 5% MC_1 18%

353 25 5% MC_1 18%

354 10 HOR 15% LP_SPC 20 – 25% 20%

355 1 5% LP_3 18%

356 1 5% LP_3 18%
Appendix C Page 9 of 17

Alternative 2

Unit Acres Past 

Activity

Existing 

Detrimental

Prescription 

(see key to codes 

in Appendix A)

Estimated interim 

Detrimental

Estimated Detrimental

after restoration subsoiling

357 16 HSL 10% PP_LP_1 20%

358 3 5% LP_3 18%

365 21 HOR 15% PP_LP_SPC 20 – 25% 20%

366 12 HFR 15% PP_1 20 – 25% 20%

367 8 HCC 15% PP_LP_SPC 20 – 25% 20%

368 8 HFR 15% PP_1 20 – 25% 20%

369 90 HTH 15% PP_1 20 – 25% 20%

370 118 HFR 15% PP_LP_1 20 – 25% 20%

371 24 HSV 15% PP_SPC 20 – 25% 20%

372 9 SPC 5% PP_SPC 15%

373 66 HSV 15% PP_SPC 20 – 25% 20%

374 6 HSL 10% PP_SPC 15%

375 25 HSV 15% PP_SPC 20 – 25% 20%

376 11 HFR 15% PP_SPC 20 – 25% 20%

377 149 HSV 15% PP_SPC 20 – 25% 20%

378 45 HSV 15% PP_SPC 20 – 25% 20%

379 10 HSV 15% PP_SPC 20 – 25% 20%

380 27 HSV 15% PP_SPC 20 – 25% 20%

381 7 HSV 15% PP_SPC 20 – 25% 20%

382 29 5% MC_1 18%

383 13 5% MC_1 18%

384 19 5% MC_1 18%

385 24 5% MC_1 18%

386 25 5% MC_1 18%

387 18 HCC 15% MC_1 20 – 25% 20%

388 3 5% MC_1 18%

926 3 HPR 10% MC_1 18%

944 89 HPR 10% None 10%

945 9 HPR 10% MC_1 18%

947 29 HPR 10% MC_1 18%

948 5 HTH 15% MC_1 20 – 25% 20%

950 12 HPR 10% MC_3 20%

951 17 HPR 10% MC_1 18%

952 20 HPR 10% MC_3 20%

953 3 5% MC_3 20%

954 8 HPR 10% LP_3 18%

955 19 HCP 15% PP_LP_SPC 20 – 25% 20%

956 8 HOR 15% MC_SPC 20 – 25% 20%

957 22 HOR 15% MC_SPC 20 – 25% 20%

958 6 HOR 15% MC_SPC 20 – 25% 20%

961 4 HSV 15% LP_3 20 – 25% 20%

962 6 HSV 15% LP_3 20 – 25% 20%

963 9 5% LP_3 18%

967 36 HPR 10% MC_1 18%
Appendix C Page 10 of 17

– –

Table D-2: Soils - Alternative 3 - Unit Table

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

1 5% PP_LP_2 15%

2 HCR 15% PP_LP_2 18%

3 5% PP_LP_2 15%

4 HCR 15% PP_LP_2 18%

5 5% PP_LP_2 15%

6 5% PP_LP_2 15%

7 5% PP_LP_2 15%

9 5% PP_LP_2 15%

13 HCR 15% PP_LP_2 18%

14 5% PP_LP_2 15%

15 HCR 15% PP_LP_2 18%

16 HOR 15% PP_LP_2 18%

17 HOR 15% PP_LP_2 18%

18 5% PP_LP_2 15%

19 HFR 15% PP_LP_2 18%

20 5% PP_LP_2 15%

21 5% PP_LP_2 15%

22 5% PP_LP_2 15%

23 5% PP_LP_2 15%

24 5% PP_LP_2 15%

25 5% PP_LP_2 15%

26 5% PP_LP_2 15%

27 5% PP_SPC 15%

28 HOR 15% PP_LP_2 18%

29 HTH 15% PP_LP_2 18%

30 HOR 15% PP_1 20 – 25% 20%

31 HPR 10% PP_1 15%

32 HOR 15% PP_1 20 – 25% 20%

33 HPR 10% PP_1 15%

34 HPR 10% PP_1 15%

35 HTH 15% PP_1 20 – 25% 20%

36 HTH 15% PP_1 20 – 25% 20%

37 HTH 15% PP_1 20 – 25% 20%

38 HTH 15% PP_1 20 – 25% 20%

39 HTH 15% PP_1 20 – 25% 20%

40 HTH 15% PP_1 20 – 25% 20%

41 HTH 15% PP_1 20 – 25% 20%

42 HTH 15% PP_1 20 – 25% 20%

43 HPR 10% PP_1 15%

44 HTH 15% PP_1 20 – 25% 20%

45 5% PP_1 15%

46 5% PP_1 15%

47 HPR 10% PP_1 15%

48 HPR 10% PP_1 15%

49 HFR 15% None 15%

50 HTH 15% PP_1 20 – 25% 20%

51 HTH 15% PP_1 20 – 25% 20%
Appendix C Page 11 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

52 HPR 10% MC_2 15%

53 GSHK_PFAmc

54 HPR 10% MC_2 15%

55 HPR 10% MC_2 15%

56 5% MC_2 15%

60 HCP 15% MC_SPC 20 – 25% 20%

61 HCP 15% MC_SPC 20 – 25% 20%

62 HCP 15% MC_SPC 20 – 25% 20%

63 HCC 15% LP_SPC 20 – 25% 20%

64 HCP 15% PP_SPC 20 – 25% 20%

65 HCC 15% LP_SPC 20 – 25% 20%

66 HCC 15% PP_SPC 20 – 25% 20%

67 HCR 15% LP_1 20 – 25% 20%

68 HCC 15% LP_SPC 20 – 25% 20%

70 HCC 15% LP_SPC 20 – 25% 20%

71 HCC 15% LP_SPC 20 – 25% 20%

73 HCU 15% LP_1 20 – 25% 20%

76 HCR 15% LP_1 20 – 25% 20%

78 HCR 15% LP_SPC 20 – 25% 20%

79 HCR 15% LP_1 20 – 25% 20%

80 HCR 15% LP_1 20 – 25% 20%

82 HCR 15% LP_1 20 – 25% 20%

84 HCR 15% LP_1 20 – 25% 20%

86 HCR 15% LP_1 20 – 25% 20%

87 HCR 15% LP_1 20 – 25% 20%

90 HCR 15% LP_1 20 – 25% 20%

91 HCR 15% LP_1 20 – 25% 20%

92 HCR 15% LP_1 20 – 25% 20%

93 HCR 15% LP_1 20 – 25% 20%

94 HCR 15% LP_SPC 20 – 25% 20%

95 HCR 15% LP_1 20 – 25% 20%

96 HCR 15% LP_1 20 – 25% 20%

97 HPR 10% MC_2 15%

98 HCR 15% LP_1 20 – 25% 20%

99 HCR 15% LP_1 20 – 25% 20%

100 HCC 15% LP_SPC 20 – 25% 20%

101 HFR 15% PP_SPC 20 – 25% 20%

102 HCU 15% PP_SPC 20 – 25% 20%

103 HCP 15% PP_SPC 20 – 25% 20%

104 HCC 15% LP_SPC 20 – 25% 20%

106 HCR 15% LP_1 20 – 25% 20%

107 HCP 15% PP_SPC 20 – 25% 20%

108 5% MC_2 15%

109 HCC 15% LP_1 20 – 25% 20%

118 HPR 10% MC_2 15%

119 HFR 15% None 15%

120 HFR 15% PP_SPC 20 – 25% 20%

121 5% MC_2 15%

122 HPR 10% MC_2 15%

123 HTH 15% PP_SPC 20 – 25% 20%

124 HPR 10% MC_2 15%
Appendix C Page 12 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

125 HTH 15% None 15%

126 HTH 15% None 15%

127 HTH 15% None 15%

128 HCC 15% PP_SPC 20 – 25% 20%

129 HSV 15% PP_SPC 20 – 25% 20%

130 HCC 15% PP_SPC 20 – 25% 20%

131 HSV 15% PP_SPC 20 – 25% 20%

132 HCC 15% PP_SPC 20 – 25% 20%

133 HTH 15% None 15%

134 HTH 15% MC_2 18%

135 5% MC_2 15%

136 HPR 10% MC_2 15%

137 5% MC_2 15%

138 5% RHCA_MC 10-15%

139 5% MC_2 15%

140 5% RHCA_PP_LP 10-15%

141 5% RHCA_PP_LP 10-15%

142 5% PP_1 15%

143 5% PP_1 15%

144 HFR 15% MC_1 20 – 25% 20%

145 HFR 15% MC_1 20 – 25% 20%

146 HFR 15% MC_1 20 – 25% 20%

147 HFR 15% MC_1 20 – 25% 20%

148 HTH 15% PP_1 20 – 25% 20%

149 HCR 15% PP_1 20 – 25% 20%

150 HFR 15% PP_1 20 – 25% 20%

151 HPR 10% PP_1 15%

152 HFR 15% PP_1 20 – 25% 20%

153 HFR 15% PP_1 20 – 25% 20%

154 5% PP_1 15%

155 HFR 15% PP_1 20 – 25% 20%

156 HOR 15% PP_1 20 – 25% 20%

157 5% PP_LP_2 18%

158 5% PP_LP_2 18%

159 5% RHCA_PP_LP 10-15%

160 5% PP_LP_2 15%

161 5% PP_LP_2 15%

162 SPC 5% PP_1 15%

163 HFR 15% PP_1 20 – 25% 20%

164 5% PP_1 15%

165 5% PP_1 15%

166 5% PP_1 15%

167 5% PP_1 15%

168 HFR 15% PP_1 20 – 25% 20%

169 HFR 15% PP_1 20 – 25% 20%

170 HFR 15% PP_1 20 – 25% 20%

171 5% PP_LP_2 18%

172 5% RHCA_PP_LP 10-15%

173 HOR 15% PP_LP_LFR 20 – 25% 20%

174 5% PP_LP_2 15%

175 5% PP_1 15%
Appendix C Page 13 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

176 5% PP_LP_2 15%

177 5% PP_LP_2 15%

178 HFR 15% PP_1 20 – 25% 20%

179 5% PP_1 15%

180 5% PP_1 15%

181 5% PP_1 15%

182 5% PP_1 15%

183 5% PP_1 15%

184 5% PP_1 15%

185 HFR 15% PP_1 20 – 25% 20%

186 5% PP_1 15%

187 HFR 15% PP_1 20 – 25% 20%

188 HFR 15% PP_1 20 – 25% 20%

189 5% PP_1 15%

190 5% PP_1 15%

191 5% PP_1 15%

192 5% PP_1 15%

193 5% PP_1 15%

194 HSV 15% PP_SPC 20 – 25% 20%

195 5% PP_SPC 15%

196 HFR 15% PP_1 20 – 25% 20%

197 HTH 15% PP_1 20 – 25% 20%

198 5% PP_LP_2 15%

199 HPR 10% PP_LP_LFR 10%

200 5% PP_LP_2 15%

201 HSL 10% PP_LP_2 18%

202 HCC 15% PP_LP_2 18%

203 5% PP_LP_2 15%

204 HPR 10% PP_LP_LFR 10%

205 HOR 15% PP_LP_LFR 15%

206 HPR 10% PP_LP_LFR 10%

207 5% PP_LP_2 15%

208 HCC 15% PP_LP_2 18%

209 5% PP_LP_2 15%

210 HCP 15% PP_LP_SPC 20 – 25% 20%

211 5% PP_LP_2 15%

212 5% PP_LP_2 15%

214 HIM 10% PP_LP_2 15%

215 HOR 15% PP_LP_LFR 15%

216 HSL 10% None 10%

217 5% PP_LP_2 15%

218 HCC 15% PP_1 20 – 25% 20%

219 HCC 15% PP_SPC 20 – 25% 20%

220 HSV 15% PP_SPC 20 – 25% 20%

221 HSV 15% PP_SPC 20 – 25% 20%

222 HIM 10% PP_SPC 15%

223 5% PP_SPC 15%

224 HSV 15% PP_SPC 20 – 25% 20%

225 HSV 15% PP_SPC 20 – 25% 20%

226 HCC 15% PP_SPC 20 – 25% 20%

227 5% PP_LP_2 15%
Appendix C Page 14 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

228 HOR 15% PP_LP_LFR 15%

229 5% PP_LP_2 15%

230 HOR 15% PP_LP_LFR 15%

231 5% PP_LP_2 15%

232 HOR 15% PP_LP_LFR 15%

233 5% PP_LP_2 15%

234 HOR 15% PP_LP_LFR 15%

235 5% PP_LP_2 15%

236 5% PP_LP_2 15%

237 HCR 15% LP_1 20 – 25% 20%

238 HOR 15% PP_LP_LFR 15%

239 5% PP_LP_2 15%

240 HCC 15% PP_LP_2 18%

241 HSL 10% PP_LP_2 18%

242 HOR 15% PP_LP_LFR 15%

243 HSL 10% PP_LP_LFR 10%

244 HIM 10% PP_LP_2 15%

245 5% PP_LP_2 15%

246 5% PP_LP_2 15%

247 HOR 15% PP_LP_LFR 15%

248 HSL 10% PP_LP_2 18%

249 HCP 15% PP_LP_LFR 15%

250 HCP 15% PP_LP_LFR 15%

251 5% PP_LP_2 15%

252 HOR 15% PP_LP_LFR 15%

253 5% PP_LP_2 15%

254 HOR 15% PP_LP_LFR 15%

255 HSL 10% PP_LP_2 18%

256 5% PP_LP_2 15%

257 5% PP_LP_2 15%

258 HOR 15% PP_LP_2 18%

259 HSL 10% None 10%

260 HSL 10% None 10%

261 HSL 10% None 10%

262 HSL 10% None 10%

263 HSL 10% None 10%

264 HFR 15% PP_LP_LFR 15%

265 5% PP_LP_2 15%

266 HFR 15% PP_LP_2 18%

267 5% PP_LP_2 15%

268 5% PP_LP_2 15%

269 5% PP_LP_2 15%

273 HFR 15% PP_LP_2 18%

274 HOR 15% PP_LP_2 18%

275 HSL 10% None 10%

277 HIM 10% None 10%

278 HOR 15% PP_LP_2 18%

279 5% PP_LP_2 15%

280 HCC 15% PP_LP_SPC 20 – 25% 20%

281 HTH 15% PP_1 20 – 25% 20%

283 HTH 15% MC_1 20 – 25% 20%
Appendix C Page 15 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

285 5% MC_1 18%

286 5% MC_2 15%

287 HOR 15% MC_1 20 – 25% 20%

288 HSV 15% PP_SPC 20 – 25% 20%

289 HCR 15% LP_1 20 – 25% 20%

290 HCR 15% LP_SPC 20 – 25% 20%

291 HSV 15% MC_2 18%

292 5% MC_2 15%

293 HCU 15% LP_1 20 – 25% 20%

296 HCC 15% LP_SPC 20 – 25% 20%

298 HCU 15% LP_1 20 – 25% 20%

305 HCU 15% LP_1 20 – 25% 20%

306 5% LP_4 18%

307 HCU 15% LP_1 20 – 25% 20%

308 HSV 15% MC_2 20 – 25% 20%

309 HCC 15% PP_SPC 20 – 25% 20%

310 HCU 15% LP_1 20 – 25% 20%

311 HCC 15% LP_SPC 20 – 25% 20%

312 HCC 15% PP_SPC 20 – 25% 20%

313 HCU 15% LP_1 20 – 25% 20%

314 HCR 15% LP_1 20 – 25% 20%

318 HCC 15% LP_SPC 20 – 25% 20%

319 HCC 15% LP_SPC 20 – 25% 20%

322 HCR 15% LP_1 20 – 25% 20%

325 HCR 15% LP_1 20 – 25% 20%

326 HCR 15% LP_1 20 – 25% 20%

330 HCR 15% LP_1 20 – 25% 20%

331 5% MC_2 18%

332 HCR 15% LP_1 20 – 25% 20%

333 5% MC_2 15%

334 HCR 15% LP_1 20 – 25% 20%

335 HCU 15% PP_SPC 20 – 25% 20%

337 HFR 15% MC_LFR 15%

338 HCU 15% MC_LFR 15%

339 HCU 15% PP_SPC 20 – 25% 20%

341 HOR 15% LP_SPC 20 – 25% 20%

342 5% MC_2 15%

343 HSL 10% MC_2 15%

345 HFR 15% MC_2 18%

346 HFR 15% MC_LFR 15%

351 5% MC_2 15%

352 5% MC_2 15%

353 5% MC_1 18%

365 HOR 15% PP_LP_SPC 20 – 25% 20%

366 HFR 15% PP_1 20 – 25% 20%

367 HCC 15% PP_LP_SPC 20 – 25% 20%

368 HFR 15% PP_1 20 – 25% 20%

369 HTH 15% PP_1 20 – 25% 20%

370 HFR 15% PP_LP_2 20 – 25% 20%

371 HSV 15% PP_SPC 20 – 25% 20%

372 SPC 5% PP_SPC 15%
Appendix C Page 16 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

373 HSV 15% PP_SPC 20 – 25% 20%

374 HSL 10% PP_SPC 15%

375 HSV 15% PP_SPC 20 – 25% 20%

376 HFR 15% PP_SPC 20 – 25% 20%

377 HSV 15% PP_SPC 20 – 25% 20%

378 HSV 15% PP_SPC 20 – 25% 20%

379 HSV 15% PP_SPC 20 – 25% 20%

380 HSV 15% PP_SPC 20 – 25% 20%

381 HSV 15% PP_SPC 20 – 25% 20%

382 5% MC_2 15%

383 5% MC_2 15%

384 5% MC_2 15%

385 5% MC_2 15%

386 5% MC_2 15%

387 HCC 15% MC_2 18%

388 5% MC_2 15%

901 5% PP_LP_2 15%

902 HFR 15% PP_LP_2 18%

903 HSL 10% None 10%

904 5% PP_LP_2 15%

905 SPC 5% PP_1 18%

906 HFR 15% PP_1 18%

907 5% PP_1 18%

909 SPC 5% GSHK_PFAmc

912 HFR 15% MC_1 18%

913 5% GSHK_PFAmc

914 HSL 10% MC_2 15%

916 5% LP_4 15%

918 HSL 18% MC_1 20 – 25% 20%

919 SPC 5% MC_1 18%

920 HTH 15% MC_1 20 – 25% 20%

921 HSV 15% MC_1 20 – 25% 20%

922 HTH 15% MC_1 20 – 25% 20%

923 5% MC_1 18%

924 HFR 15% PP_LP_SPC 20 – 25% 20%

925 HFR 15% MC_1 20 – 25% 20%

926 HPR 10% MC_2 18%

927 HPR 10% MC_2 18%

928 5% MC_2 15%

929 5% PP_LP_2 15%

930 HOR 15% PP_LP_LFR 15%

931 HFR 15% PP_1 20 – 25% 20%

932 5% PP_LP_2 15%

933 HTH 15% PP_LP_2 18%

934 SPC 5% PP_LP_2 15%

935 HTH 15% PP_1 20 – 25% 20%

943 SPC 5% PP_LP_2 15%

944 HPR 10% None 10%

945 HPR 10% MC_1 18%

946 5% GSHK_NST

947 HPR 10% MC_2 18%
Appendix C Page 17 of 17

Alternative 3

Unit 

#

Past 

Activity

Existing 

Detrimental Prescriptions Estimated InterimDetrimental

Final Estimated 

Detrimental

948 HTH 15% MC_1 20 – 25% 20%

949 HTH 15% GSHK_PFA

951 HPR 10% MC_2 18%

955 HCP 15% PP_LP_SPC 20 – 25% 20%

956 HOR 15% MC_SPC 20 – 25% 20%

957 HOR 15% MC_SPC 20 – 25% 20%

958 HOR 15% MC_SPC 20 – 25% 20%

964 SPC 5% PP_1 15%

965 HFR 15% GSHK_PFA

966 5% GSHK_NSTmc

967 HPR 10% MC_1 18%

969 5% PP_LP_2 15%
Appendix D Page 1 of 3

APPENDIX D

Map of Geothermal Activities

List of Units Affected
Appendix D Page 2 of 3
Appendix D Page 3 of 3

Figure D-1. Location of Geothermal Activities in the Ogden Project Area. See Tables 13 and 14 in the 

DEIS for a description of activities.

Units overlapping geothermal exploration locations and/or EGS Locations

Alternative 2

78, 84, 107, 118, 331, 377, 99, 93, 320, 89

Alternative 3

78, 84, 107, 118, 331, 377, 99

Units Overlapping Potential Lease Areas (Consent to Lease)

Alternative 2

63, 66, 67, 68, 69, 70, 71, 72, 73, 74, 93, 94, 95, 96, 97, 109, 110, 111, 112, 113, 114, 115, 116, 

117, 118, 131, 337, 347, 348, 377, 382, 383, 384, 385, 386, 387, 388, 950, 951

Alternative 3

63, 66, 67, 68, 70, 71, 73, 93, 94, 95, 96, 97, 109, 118, 131, 337, 377, 382, 383, 384, 385, 386, 

387, 388, 951

Units Overlapping Existing Lease Areas

Alternative 2

47,48, 50, 54, 55, 63, 66, 67, 68, 69, 70, 71, 72, 73, 74, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 

95, 96, 97, 99, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, 116, 117, 

118, 120, 121, 122, 123, 124, 129, 130, 131, 283, 284, 285, 286, 287, 288, 289, 290, 291, 292, 

293, 294, 295, 296, 297, 298, 305, 306, 307, 308, 309, 310, 311, 312, 313, 314, 322, 323, 324, 

325, 326, 327, 328, 330, 331, 332, 333, 334, 335, 337, 338, 339, 340, 341, 342, 343, 345, 346, 

347, 348, 350, 351, 352, 353, 354, 355, 356, 357, 358, 365, 366, 367, 369, 371, 372, 373, 375, 

377, 382, 383, 384, 385, 386, 387, 388, 926,947, 950, 951, 952, 953, 954, 956, 957, 958, 959, 960, 

961, 962, 963, 967

Alternative 3

47, 48, 50, 53, 54, 55, 63, 66, 67, 68, 70, 71, 73, 84, 86, 87, 90, 91, 92, 93, 94, 95, 96, 97, 99, 101, 

102, 103, 104, 106, 107, 108, 109, 118, 120, 121, 122, 123, 124, 129, 130, 131, 283, 285, 286, 

287, 288, 289, 290, 291, 292, 293, 296, 298, 305, 306, 307, 308, 309, 310, 311, 312, 313, 314, 

322, 325, 326, 330, 331, 332, 333, 334, 335, 337, 338, 339, 341, 342, 343, 345, 346, 351, 352, 

353, 365, 366, 367, 369, 371, 372, 373, 375, 377, 382, 383, 384, 385, 386, 387, 388, 905, 909, 

913, 914, 916, 917, 918, 919, 920, 921, 922, 923, 924, 925, 926, 927, 928, 933, 934, 947, 949, 

951, 956, 957, 958, 959, 960, 964, 965, 966, 967
APPENDIX E

Additional Stand Information and Modeling 

Existing condition of trees per acre and basal area per acre by size class

Histograms showing cut/leave and fire related mortality
Appendix E Page 2 of 12

Forest Vegetation Simulator (FVS) Version and Variant Used

The Forest Vegetation Simulator (FVS) Growth and Yield Model (Version 2010.10.14) and the South 

Central Oregon and Northeast California (SO) variant were used to predict the relative difference in 

effects of proposed treatments on future forest conditions. Treatments analyzed included no action, 

thinning, and burning. More details are contained in the Silviculture specialist’s report.

Units sampled and Stand Exams Used in Projections

Six units were selected to portray treatment differences between alternatives. Table E-1 lists the units 

selected, the associated stand exam (USDA Forest Service 2010), the year stand exam data was 

collected, and the treatment proposed in each unit.

Table E-1. Stand exams used to portray effects of proposed thinning and burning treatments.

Ogden 

Unit 

Number

Stand Exam Number Exam 

Year Alternative Treatment Planned

10 060103OGDEN0010 2010

1 and 3 No Action

2

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn

36 06010339535694 1995

1 No Action

2 and 3

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn

209 060103OGDEN0102 2009

1 No Action

2

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn

3

Thin, retaining lodgepole pine as needed to 

meet desired stocking levels.

No Burn

251 060103OGDEN0103 2009

1 No Action

2

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn

3

Thin, retaining lodgepole pine as needed to 

meet desired stocking levels.

Mow/Burn

254 060103OGDEN0254 2010

1 No Action

2

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn

3

Reduce ladder fuels

Mow/Burn

949 06010339535698 1995

1 and 2 No Action

3

Thin, retaining lodgepole pine as needed to 

meet minimum stocking levels.

Mow/Burn
Appendix E Page 3 of 12

Figure E-1. Existing condition of sample ponderosa/lodgepole pine stands with prior harvest (Units 10 and 254).

Unit 10 (Exam 010) Unit 254 (Exam 254)

575

50 17 1 0

0

100

200

300

400

500

600

700

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP

321

29

6 0 0

0

100

200

300

400

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP

1

4

13

1

0

0

5

10

15

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP

0

3

4

0 0

0

10

20

30

40

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP
Appendix E Page 4 of 12

Figure E-2. Existing condition in ponderosa/lodgepole pine stands with no prior harvest (Units 209 and 

251).

Unit 209 (Exam 102) Unit 251 (Exam 103)

500

205

36

3 0

0

100

200

300

400

500

600

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP

460

94 53

0 1

0

100

200

300

400

500

600

700

800

900

1000

1100

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP

1

24

22

4

0

0

10

20

30

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP

1

10

30

0

2

0

10

20

30

40

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP
Appendix E Page 5 of 12

Figure E-3. Existing condition in ponderosa pine stands with prior harvest (Units 36 and 949).

Unit 36 (Exam 694) Unit 949 (Exam 698)

27

4

1 0 0

0

10

20

30

40

50

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP

16

0

3

0 0

0

10

20

30

40

50

60

70

80

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Trees per Acre

DBH Class (Inches)

Trees per Acre by Size Class

PP LP WF

0 0 1 1 0

0

10

20

30

40

50

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP

0 0

3

0 0

0

10

20

30

40

50

60

70

LT2 GTE2_LT8 GTE8_LT15 GTE15_LT20 GTE20

Basal Area per Acre

DBH Class (Inches)

Basal Area per Acre by Size Class

PP LP WF
Appendix E Page 6 of 12

Figure E-4: Unit 10 histograms showing harvest cut/leave and fire related mortality. Unit 10 represents 

“multi-stratum without large trees” structural stage; mixed Ponderosa and lodgepole pine stand with 

low Ponderosa pine stocking; 85% UMZ; prior harvest.

Alternative 2 (Alternative 3 proposes no action)

0

1

2

3

4

5

6

7

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

100

200

300

400

500

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

10

20

30

40

50

60

70

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-19.9 20.0-29.9 30.0-39.9 40.0-49.9 >=50

Trees per Acre

Species and 5-inch Diameter Class 

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 7 of 12

Figure E-5: Unit 36 histograms showing harvest cut/leave and fire related mortality. Unit 36 represents 

“understory reinitiation” structural stage; high ponderosa pine stocking mixed with lodgepole; 122% 

UMZ; prior harvest.

Alternatives 2 and 3

0

5

10

15

20

25

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

10

20

30

40

50

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

35

40

PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-19.9 20.0-29.9 30.0-39.9 40.0-49.9 >=50

Trees per Acre

Species and 5-inch Diameter Class 

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 8 of 12

Figure E-6: Unit 209 histograms showing harvest cut/leave and fire related mortality. Unit 209 

represents “multi-stratum without large trees” structural stage; mixed ponderosa and lodgepole stand 

with low ponderosa stocking; 235% UMZ; no prior harvest.

Alternative 2 Alternative 3

No underburn planned after thinning treatments.

0

5

10

15

20

25

30

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

50

100

150

200

250

300

350

400

450

500

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

50

100

150

200

250

300

350

400

450

500

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

35

40

45

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-

19.9

20.0-

29.9

30.0-

39.9

40.0-

49.9

>=50

Trees per Acre

Species and 5-inch Diameter Class 

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 9 of 12

Figure E-7: Unit 251 histograms showing harvest cut/leave and fire related mortality. Unit 251 represents a 

combination of “understory reinitiation” and “multi-stratum without large trees” structural stages; mixed 

ponderosa and lodgepole pine stand with variable ponderosa pine stocking; 293% UMZ; no prior harvest.

Alternative 2 Alternative 3

0

5

10

15

20

25

30

35

40

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

35

40

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

200

400

600

800

1000

1200

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

200

400

600

800

1000

1200

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-

19.9

20.0-

29.9

30.0-

39.9

40.0-

49.9

>=50

Trees per Acre

Species and 5-inch Diameter Class

Fire Related Mortality

Dead Trees

Live Trees

0

5

10

15

20

25

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-

19.9

20.0-

29.9

30.0-

39.9

40.0-

49.9

>=50

Trees per Acre

Species and 5-inch Diameter Class

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 10 of 12

Figure E-8: Unit 254 histograms showing harvest cut/leave and fire related mortality. Unit 254 

represents “multi-stratum without large trees” structural stage; mixed ponderosa and lodgepole 

stocking with low ponderosa pine stocking; 121% UMZ; prior harvest.

Alternative 2 Alternative 3

0

2

4

6

8

10

12

14

16

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

2

4

6

8

10

12

14

16

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

50

100

150

200

250

300

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

50

100

150

200

250

300

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

35

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-

19.9

20.0-

29.9

30.0-

39.9

40.0-

49.9

>=50

Trees per Acre

Species and 5-inch Diameter Class

Fire Related Mortality

Dead Trees

Live Trees

0

50

100

150

200

250

300

350

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-

19.9

20.0-

29.9

30.0-

39.9

40.0-

49.9

>=50

Trees per Acre

Species and 5-inch Diameter Class

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 11 of 12

Figure E-9: Unit 949 histograms showing harvest cut/leave and fire related mortality. Unit 949 

represents “stem exclusion closed canopy” structural stage; High ponderosa pine stocking with 

lodgepole and white fir; 149% UMZ; prior harvest.

Alternative 3 (Alternative 2 proposes no action)

0

5

10

15

20

25

30

35

LP PP LP PP LP PP LP PP LP PP LP PP LP PP LP PP

SZ08 SZ10 SZ12 SZ14 SZ16 SZ18 SZ20 GT20

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre >= 8 inches DBH

Cut Trees

Leave Trees

0

2

4

6

8

10

12

14

16

LP PP LP PP LP PP LP PP LP PP

SZ01 SZ02 SZ04 SZ06 SZ08

Trees per Acre

Species and 2-inch Diameter Class

Cut and Leave trees per acre <=8 inches DBH

Cut Trees

Leave Trees

0

5

10

15

20

25

30

35

LP PP LP PP LP PP LP PP LP PP LP PP LP PP

0-5.0 5.0-9.9 10.0-19.9 20.0-29.9 30.0-39.9 40.0-49.9 >=50

Trees per Acre

Species and 5-inch Diameter Class

Fire Related Mortality

Dead Trees

Live Trees
Appendix E Page 12 of 12
APPENDIX F

Consideration of Public Comments on Draft EIS
Appendix F Response to Public Comments 

Page 2 of 45

Consideration of Public Comment

During the public comment period (July 22, 2011 – September 6, 2011), twelve responses were received 

from individuals, agencies or organizations listed in the table below. One additional letter was received 

after the comment period closed.

Consistent with the National Environmental Policy Act, 40 CFR 1503.4(b), this volume focuses on 

addressing substantive comments on the DEIS. Substantive comments include those which challenge the 

information in the DEIS as being inadequate or inaccurate, or which offer specific information that may 

have a bearing on the decision. Non-substantive comments are those that express opinions or position 

statements without any accompanying factual basis or rationale to support the opinion. Some comments 

have been summarized or paraphrased. 

A process for responding to comments on a DEIS has been outlined in the Forest Service Handbook 

(1909.15 Chapter 20) which states that the agency preparing the EIS must “review, analyze, and respond 

to substantive comments on the draft EIS.” Possible responses to substantive comments include: 

1. Modify alternatives including the proposed action.

2. Develop and evaluate alternatives not previously given serious consideration by the agency.

3. Supplement, improve, or modify its analyses.

4. Make factual corrections.

5. Explain why the comments do not warrant further agency response, citing the sources, authorities, 

or reasons which support the agency’s position, and, if appropriate, indicate those circumstances 

which would trigger agency reappraisal or further response.

All comments and response are part of the administrative record for this EIS, and have been considered 

during the decision-making process. Full text of the comment letters are on file at the Bend/Ft. Rock 

Ranger District. Letters received from federal agencies are included in full at the end of the appendix.

Agencies and organizations that submitted comments during the 45-day comment period:

Comments and Responses: The following comments, arranged by topic, are followed by the Forest 

Service response. Similar comments are grouped and given one response. 

Jean Public

Lydia Garvey

Todd Jaffe, VP, Davenport Newberry Holdings LLC

Irene K. Jerome, Eastern Oregon/SW Idaho Representative, American Forest Resource Council

Karen Coulter, Director, Blue Mountains Biodiversity Project

Joe Stutler, Deschutes County Forester, Deschutes County

Ivan Maluski, Conservation Director, Oregon Chapter Sierra Club

Doug Heiken, Oregon Wild

Nicholas Cady, Cascadia Wildlands 

Chuck Burley, Interfor

Allison O’Brien, Regional Environmental Officer, U.S.D.I., Office of the Secretary, Office of 

Environmental Policy and Compliance

Christine B. Reichgott, Manager, Environmental Review and Sediment Management Unit, 

Environmental Protection Agency
Appendix F Response to Public Comments

 Page 3 of 45

PURPOSE AND NEED

Comment: Some of the commercial thinning areas in ponderosa pine look like they have been already 

thinned and don’t need further logging. Others only need small diameter thinning up to 8-10” dbh, not 

up to 21” dbh. 

Response: There are units included in either alternative that have been thinned in the past. Many 

stands only need to have smaller tree thinning (such as up to 8” dbh) and these are shown in 

Appendix A with a tree treatment code of “SPC”. Table 3 of the FEIS shows that 2,115 acres are 

proposed for only small tree thinning under Alternative 2, and Table 4 shows 2,014 acres of small tree 

thinning under Alternative 3.

-------------------------------------------------------------------------------------------------------------------------

Comment: We are skeptical about the purported risk of a pine bark beetle epidemic, given that under the 

No Action alternative, the threshold for pine bark beetle “attack” is not expected to be exceeded for all 

stands until 2040! Apparently not a very imminent risk of high beetle attack: 29 years from now?

Response: The ecological purpose and need for thinning in the Ogden project area is for increasing 

resilience to insects, disease, and stand-replacing fire, to improve growth and health of residual trees, 

and to increase the proportion of LOS ponderosa pine. FEIS p. 5. The scientific bases for density 

management to avoid beetle attack are Cochran et al (1994). Barrett (1979) states that up to half of 

trees and up to 67% of the current basal area, mostly in the largest trees, could have expected 

mortality if a mountain pine beetle outbreak occurs. The FEIS shows that each alternative will 

increase the number of acres unlikely to be influenced by beetles during the next 20 to 50 years (see 

Figures 37, 38, and 39 showing the span of time that high density and beetle risk are present as large 

trees are developing). Avoiding beetle risk for 20 to 50 years on 50 or 52 percent of the ponderosa 

pine stands that are best situated to develop into LOS will address the purpose and need of increasing 

resilience and moving towards the HRV for ponderosa pine LOS.

------------------------------------------------------------------------------------------------------------------------------------

Comment: AFRC strongly supports the Purpose and Need for action. There is no question that the

need to reduce forest vegetation density and fuels to increase resilience to insects, disease, and stand

replacing fire is both critical and imminent in central Oregon east of the Cascade Mountains. 

Equally critical and equally imminent is the need to contribute to local and regional economies by

providing timber and wood fiber products and the associated jobs. Forest fuels reduction and 

providing various forms of wood fiber to the region are complementary and inseparable.

First, I could not agree more with the two needs for action. Second, I greatly appreciate you keeping the 

list of needs for action to a very short and clearly understood number. And last greatly appreciate your 

understanding and recognition of the importance of the local industry infrastructure and the heightened 

attention through the need to contribute by providing those products we need.

Response: The purpose and need for the Ogden project reflects the local need for timber and wood 

fiber as well as the goals and objectives of the Deschutes Forest Plan. 

----------------------------------------------------------------------------------------------------------------------------------

ALTERNATIVES / RANGE OF ALTERNATIVES

Comment: The DEIS does not provide a very useful summary of the existing conditions of the logging 

prescriptions. To better understand the effects of the proposed treatments, it would be very useful to have 

a clearer description of the size range of trees to be removed vs. retained in each unit. A histogram would 

be a very good way to show this kind of information. 

Response: Appendix E has been added to the Final EIS to respond to this comment. Stands that 

represent the range of conditions in the Ogden project area are displayed using Forest Vegetation 
Appendix F Response to Public Comment

Page 4 of 45

Simulator. Trees per acre and basal area per acre by size class are displayed for the existing 

condition, and histograms then display the trees cut and trees left in each representative stand. 

----------------------------------------------------------------------------------------------------------------------

Comment: While there are a few exceptions, Alternatives 2 and 3 are substantially similar in their 

overall reliance on mechanical thinning and temporary road construction, and do not provide a 

significant range of alternatives.

While we recognize that a substantial portion of the Ogden project area has experienced past intensive 

management, the difference between Alternatives 2 and 3 with regard to the protection of unroaded 

areas, the Paulina Creek RHCA, and Old Growth Management Areas appears to be quite minimal. While 

Alternative 3 would do a better job protecting these values where they largely overlap, we recommend 

that no mechanical entry or commercial logging be allowed in unroaded areas that have wilderness 

potential, as well as those adjacent to Newberry Crater National Monument. We similarly recommend no 

mechanical entry or commercial logging in the Paulina RHCA, and that management is limited to noncommercial activities that do not require the entry of heavy machinery. Similarly, activities occurring in 

the Old Growth Management Area should not be commercial in nature, and should not rely on groundbased machinery to complete the work.

Response: Alternative 3 was designed to address the issues of operating in RHCA, OGMA, and 

areas meeting the criteria for potential wilderness. The OGMA follows the Paulina Creek corridor so 

includes the RHCA (see FEIS Figure 2). A portion of this corridor is considered an area of high 

priority for the fuels reduction strategy (FEIS p. 140). The objectives for thinning and fuels reduction 

are to promote and/or maintain large tree structure that is important for stream shade and wildlife 

habitat, focusing ponderosa pine restoration and protection on the south-facing slopes. Under 

Alternative 3, all of the units in the OGMA and RHCA to the east of McKay Campground were 

dropped from treatment. 

The units within the RHCA that are proposed under both alternatives will be thinned from below, 

with diameter limits adjacent to the creek, and restrictions on the use of machinery in areas where it 

could create negative impacts (FEIS pp. 43-46). By reducing stocking levels within the RHCA, 

ponderosa pine can continue to develop toward large tree structure. Large tree development near 

Paulina Creek will recruit future large wood instream and improve stream shade (FEIS pp. 391-394, 

402). Also, Alternative 3 does not enter the stands that meet the criteria for potential wilderness, 

compared to 25 acres of treatment in such stands under Alternative 2.

--------------------------------------------------------------------------------------------------------------------------------

Comment: Because large live trees are so scarce in the planning area, we recommend that the project 

require that all trees exhibiting old characteristics be retained regardless of diameter.

Comment: We encourage retention of all trees with old-growth characteristics regardless of size and 

species.

Response: Alternatives 2 and 3 now include the provision to retain “old character” ponderosa pine 

trees, with some exceptions. This is described in the FEIS p. 37 as resource protection measure #2.

---------------------------------------------------------------------------------------------------------------------------------

Comment: While the Forest Service appears to recognize the importance of retaining trees 21” dbh and 

larger, the DEIS does not address the value in or need to recruit trees of that size over the next few 

decades by requiring retention of trees in the 16” to 18” dbh range in an area where larger trees are 

clearly lacking on the landscape.

Comment: We encourage the FS to recognize the potential ecological value of applying diameter limits 

smaller than 21” dbh.

Comment: We believe the Forest Service has failed to develop an adequate range of alternatives that 

addresses the need to restore old forests with large diameter trees to the Ogden project area, and has 
Appendix F Response to Public Comments

 Page 5 of 45

unfairly dismissed the development of alternatives that would retain all trees above 16” and 18” dbh. 

Alternatives 2 and 3 are overall quite similar in their impacts across the broader project area, with few 

exceptions.

Comment: The Sierra Club in our scoping comments and here as well have proposed the development of 

an alternative that considers a lower diameter limit for retention trees. While the Deschutes National 

Forest has repeatedly agreed to lower diameter limits for retention trees in other projects, including on 

the neighboring Lava Cast project, the development of an alternative that retains trees over 16” dbh or 

18” dbh was ruled out as an ‘alternative considered but not analyzed in detail’ (DEIS, pg. 50-51). If 

lower diameter limits were reasonable in neighboring Forest Service projects, why is the development of 

such an alternative not reasonable here?

Because of the regional deficit in trees > 15”, we recommend a 15” dbh limit for all commercial units 

otherwise not specified.

Response: Both action alternatives will meet the purpose and need of reducing tree density, reducing 

fuels, increasing resilience to insects, disease, and wildfire, and increasing the proportion of LOS 

ponderosa pine over time (FEIS p. 5). Because thinning is from below, the largest trees will be left to 

provide residual stocking. This potential alternative design was discussed in the FEIS p. 56. It is 

worth noting that monitoring of the nearby Sonny Timber Sale (which did not have lower diameter 

limits) project has shown that a larger proportion of trees between 16 and 21 inches dbh are retained 

than removed. 

-------------------------------------------------------------------------------------------------------------------------

Comment: Alternative 2 restores less total acres in Condition Classes 2 and 3 than Alternative 3, 

which begs the question “why?”

Response: Thinning and fuels treatments take place within CC 2 and 3 across 11,253 acres under 

Alternative 2 and 11,681 acres under Alternative 3. The difference in the amount of area treated is 

described in Chapter 2 – some areas have been dropped from Alternative 3 to respond to key issues. 

-------------------------------------------------------------------------------------------------------------------------

Comment: Alternative 2 removes the most wood fiber of the three alternatives and consequently best

meets the purpose and need.

Response: Both action alternatives will provide wood fiber and both meet the other elements 

of the purpose and need to different levels. Alternative 3 includes slightly more ponderosa 

sawlogs, but includes less lodgepole pine sawlogs and less fiber (FEIS p. 453). The difference 

arises because Alternative 3 addresses key issues.

-------------------------------------------------------------------------------------------------------------------------------------

KEY ISSUES

KEY ISSUE #1 Regeneration Harvest in Lodgepole Pine

Comment: Regeneration harvest is not a valid ecosystem restoration activity because it does not mimic 

natural processes. Natural mortality events retain the large tree structure. This proposal will remove too 

much wildlife habitat structure associated with mature trees. Large tree structures located in low vigor 

lodgepole stands provide high quality habitat for certain wildlife species including black-backed 

woodpeckers, three-toed woodpeckers, and marten. These forests will regenerate when they burn (not a 

matter of “if” but “when”), and the FS should retain existing habitat values until that time.

Seed tree removal harvest will likely move stands away from the historic range of variability for large 

tree structure in violation of the Eastside Screens. DEIS p 114 says that the vegetation management must 

move stands toward LOS. This applies to ppine, mixed conifer and lodgepole. However, removing the few 
Appendix F Response to Public Comment

Page 6 of 45

remaining large trees in the lodgepole seed tree removal prescriptions does not accomplish this LRMP 

requirement. In fact, Alt. 3 is worse than Alt. 2 which is worse than Alt. 1 in this regard. 

Comment: The spread of mistletoe is natural in lodgepole stands and provides important heterogeneity 

in heavily treated forests. Regeneration harvest in the past has not prevented the spread of mistletoe and 

therefore, preventing the spread of this native species is not an adequate justification for logging rare late 

seral lodgepole habitat or removing large mature lodgepole trees.

Response: LOS lodgepole is not rare on the landscape. As shown in the analysis, approximately 76 

percent of the lodgepole analysis area have no recorded regeneration harvest of fire disturbance, and 

are classified into the greater than 40 year age class, which is the oldest age class of live lodgepole

(FEIS pp. 77-78). Following treatments under Alternative 2, 73% of the lodgepole pine will remain 

in that age class and large contiguous blocks of older lodgepole pine habitat will remain on the 

landscape (FEIS p. 78). Under Alternative 2, the stand initiation structural stage would increase by 

1% for lodgepole pine, but remain at the low end of the HRV.

The FEIS does not claim that regeneration harvest methods in lodgepole pine are restoration 

activities. Regeneration harvest is proposed in lodgepole pine stands to maintain a diversity of stand 

age classes across the landscape. Consistent with the Forest Plan, stands no longer capable of 

optimum growth performance are proposed for ‘clearcut with seed trees reserved’. And for the 

lodgepole pine biophysical environment, LOS is within HRV (Table 23, FEIS p. 117). Therefore, 

under Scenario B of the Eastside Screens, timber harvest is allowed as long as LOS conditions do not 

fall below HRV. Neither alternative will reduce the amount of LOS to below HRV. A small patch of 

LOS lodgepole pine is included in unit 174, totaling about 8 acres. The IDT developed Alternative 3, 

which eliminated the ‘clearcut with seed trees reserved’ proposed on 397 acres and an analysis of that 

issue appears in the FEIS pp. 76-83.

---------------------------------------------------------------------------------------------------------------------------- 

Comment: We are adamantly opposed to any regeneration logging; there is no reason given why this 

should be considered necessary in mixed conifer.

In one unit totaling 35 acres, regeneration harvest (lodgepole removed, ponderosa pine and white fir 

retained) is proposed in lodgepole pine-dominated stands within the mixed conifer and ponderosa 

pine plant associations to move species composition closer to the ponderosa pine dominated stand 

conditions (described in FEIS p. 20). This desired condition is similar to that which was historically 

present. Without active efforts to regenerate ponderosa pine, lodgepole pine will continue to be the 

dominant tree cover. This occurs in one 35-acre unit in Alternative 2. This unit is not included in 

Alternative 3.

----------------------------------------------------------------------------------------------------------------------

Comment: We do not believe the benefits of clear cutting lodgepole pine forest that has reached a late 

seral condition outweighs the costs, and would encourage dropping the 362 acres of the lodgepole 

regeneration harvest. The area surrounding these proposed units have been heavily treated recently and 

the mature lodgepole stands are interspersed between young regenerated stands. Older high elevation 

stands provide habitat for the goshawk, pileated woodpecker and other older forest dependent species. 

Elimination of this rare and essential habitat will reduce population levels. 

Response: Of the 362 acres of lodgepole pine that would be regeneration harvested under Alternative 

2, about 222 have been previously harvested. Older stands of lodgepole pine (> 40 years old) are 

abundant within the analysis area. The location of the units adjacent to existing younger stands will 

create more contiguous blocks of young stands that will reduce the spread of dwarf mistletoe; large 

contiguous blocks of older lodgepole pine are retained on the landscape (FEIS p. 78). Wildlife effects 

of the regeneration harvest are disclosed in the FEIS. Alternative 3 provides a comparison of the 

project without 362 acres of lodgepole and 35 acres mixed conifer regeneration harvest.
Appendix F Response to Public Comments

 Page 7 of 45

--------------------------------------------------------------------------------------------------------------------------------------

Comment: Key Issue #1-Regen Harvest in Lodgepole Pine – Apparently you received comments during 

scoping and otherwise that raised some concerns about this proposed treatment of 362 acres. ..... under 

the proposed regeneration harvest there will be a small but crucial component of the 1-10 year age 

class to provide its ecological value for certain wildlife. We also see in Table 22 that the lodgepole 

PAG would still be Within or Above the HRV even with this small amount of regeneration harvest. 

And by creating a small amount of the early age class this action would help meet the general 

theme and objectives of the Forest Plan by managing the forest for a variety of age classes. So we 

support the proposed regeneration of 362 acres of late-seral lodgepole pine and believe it provides 

important ecological values; meets the Eastside Screens HRV criteria; and is consistent with the 

Forest Plan direction for the General Forest management area.

Comments: Maintain the regeneration harvest in the late-seral lodgepole pine stands. From a 

landscape perspective this would have a very nominal effect on the portion of those stands in the over 40 

year age class and would provide some acres in the 0-10 year age class that otherwise would not be 

present. These 0-10 year age class acres also provide ecological values for other wildlife and resources 

and meet the Forest Plan direction to manage for a variety of age classes. Furthermore there would be no 

effect on the HRV for lodgepole pine stands. 

Comments: The proposed action includes 336 acres of seed tree harvest in late-seral lodgepole pine

stands. The DEIS states these stands provide "ecological value for certain wildlife" which we won't

dispute. But we have to ask are these the last 336 acres of late-seral lodgepole pine in the vicinity or

on the district? The DEIS states that 76% of the analysis area consists of older stands of lodgepole

pine. The removal of the 336 acres in the proposed action represents only 3% of that area. 

Alternative 3 defers the seed tree harvest in these areas but there is no mention of how long you

intend to defer the seed tree harvest. 

Also, presuming these 336 acres of late-seral lodgepole pine are in the General Forest

Management Area, there are good reasons to regenerate the stands. The Forest Plan (page 4-117)

says this Management Area is to be managed for a ''variety of age classes" and that you should be 

"regenerating stands that are no longer capable of optimum growth performance.”

Response: The analysis of this issue is intended to disclose the trade-offs involved so that the 

responsible official can make an informed decision. The FEIS shows that Alternative 2 would 

slightly alter the amount of late seral lodgepole forest in the analysis area and that Alternative 3 

(by eliminating the regeneration units) creates no change in the level of late seral lodgepole 

forest. The FEIS also shows that this type of forest correlates to three-toed woodpecker habitat 

and regeneration harvest eliminates the habitat on 254 acres; whereas Alternative 3 removes 

only 2 acres (FEIS p. 320, Table 125).

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Comment:... the forest plan (page 4-117) says "The objective of timber management in this

Management Area is to continue to convert unmanaged stands to managed stands. The aim of a

managed forest is to have stands in a variety of age classes with all stands utilizing the site growth 

potential. This is achieved through stand treatments which include (but are not limited to)

controlling stocking levels; maintaining satisfactory growth rates; protecting stands from insects,

disease, and damage; controlling species composition; and regenerating stands that are no longer

capable of optimum growth performance."(Emphasis added.) So not all of the General Forest 

Management Area should be in LOS but should be in a "variety of age classes". If thinning to

accelerate LOS is deemed more important than utilizing site growth potential, you could do a forest

plan amendment but I don't think that's really necessary because the site growth potential is an

"aim" not an "objective"or a "standard"for that matter

Response: The General Forest management area also has a goal of providing forage 

production, visual quality, wildlife habitat and recreational opportunities. In addition, forest-
Appendix F Response to Public Comment

Page 8 of 45

wide standards and guidelines apply. The Eastside Screens amended the Forest Plan and 

provide even more guidance for timber management. The HRV analysis shows that a variety 

of age classes of lodgepole pine will be present in the project area following either action 

alternative.

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KEY ISSUE #2

Comment: Key Issue #2: Individual Tree Growth vs. Stand Growth Potential. ...if we understand this

correctly, the issue is the proposed action of thinning to accelerate LOS conditions would require

thinning to a level below what may be optimal for site growth potential. Your letter states that "The

objective in General Forest is for all stands to 'utilize site growth potential." Thus you are

suggesting that the proposed action would not be implementing the forest plan.

Comment: The question is raised whether the MSL would meet the Forest Plan objective of utilizing the 

site growth potential. Specifically the DEIS at page 77 states that the MSL “may not be high enough for a 

significant portion of the site resources, such as water and nutrients, to be captured in tree growth.” This 

statement suggests that there is a threshold measured in stocking density below which there would be 

excess water and nutrients and this may be the case. 

But on the other hand those remaining trees will have the benefit of being able to utilize to their maximum 

extent possible the water and nutrients and likely grow at a rate that would exceed that of higher densities 

thus accelerating the move to LOS and a more resilient landscape. And isn’t this what the Purpose and 

Need for Action calls for?

Response: The proposed thinning under either alternative would be meeting the General Forest goal 

of emphasizing timber production and meeting the purpose and need described on page 5 of the FEIS. 

Because the amount of LOS ponderosa pine across the analysis area is far below the HRV (due to 

past harvest removing large trees), the proposed action encourages development of LOS structure in 

ponderosa pine by accelerating individual tree growth. The two alternative go a long way in 

implementing the Forest Plan (as amended by the Eastside Screens) in the project area, but provide a 

relative comparison of the trade-offs involved in two different approaches. 

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Comment: Table 6 is not the easiest to understand as written in the DEIS. It’s difficult to take such 

esoteric topics and try to present them easily in a table format. I discussed this with your staff and trust 

the final documents will explain this more clearly so everyone can understand what is being discussed.

Response: This table has been modified in the Final EIS and clarifying text has been added (see 

FEIS pp. 29-30).

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Comment: It seems to me this issue revolves around the MSL and LMZ measures and the notion of 

utilizing site growth potential. There is no definition of MSL found in the DEIS glossary or 

anywhere else I can find aside from Table 6. The only definition for LMZ I could find is the footnote on 

page 7 that says the LMZ is “often set at 67% of the upper management zone and is the zone which 

maintains enough stocking to capture a significant portion of the site resources in tree growth.” The 

Upper Management Zone is defined in the Glossary as the level of stocking beyond which there is 

imminent risk of loss of overstory to bark beetles and doesn’t say anything about capturing the site 

resources.

Response: These terms are defined and their use in this project explained in the Forested Vegetation 

section under the stand density header (FEIS pp. 71-73).

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Appendix F Response to Public Comments

 Page 9 of 45

Comment: [I]f you choose to retain more of the lodgepole and white fir to meet stocking levels, do not 

allow for underburning afterward. Doing so would only point out that the lodgepole and white fir is 

really not necessary for stocking levels as they will likely die from the underburning. 

My suggestion would be to implement prescriptions as close to those in the Proposed Action or 

Alternative 2. The MSL is a perfectly legitimate stocking level from a silvicultural perspective. 

However I recognize that stocking level may seem too low to the casual eye. On the other hand, the 

LMZ, though commonly used, is arbitrary in the 67% of the Upper Management Zone. It could easily 

be a lower percentage.

So another option would be to thin the mixed ponderosa pine stands to a point somewhere between 

the MSL and the LMZ. I don’t think the site growth potential would be a problem because the residual 

stands will take full advantage of the additional resources provided the stands have not stagnated 

which is unlikely.

Whichever way you choose to go, there is one thing for certain. Leaving lodgepole pine and white fir 

to meet whatever stocking levels are targeted and following up with underburning would be totally 

counterproductive. If in the final decision the underburning is still prescribed for these stands, then 

obviously those trees and their contribution to stocking are unnecessary as they will likely die by fire. 

So if you decide to do the underburning, then I believe the stocking levels should be such that the 

residual stands are ponderosa pine at the minimum stocking levels.

Response: Under Alternative 3, where prescribed underburning is proposed following a treatment 

that leaves lodgepole and white fir in the understory, the burning prescription will need to be 

modified (see FEIS pp. 8, 23); there may be post-sale conditions that limit the ability to underburn at 

all.

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Comment: The analysis of this alternative shows there is an increased vulnerability to bark

beetle outbreaks in these stands beginning in the year 2040, which also means an increased 

vulnerability to wildfire. Given the vast number of acres on the Deschutes that need treatment in

the next several decades it is not appropriate to inadequately treat stands in Ogden during this

entry.

Response: Compared to the No Action alternative, both Alternatives 2 and 3 provide for a 

reduction in bark beetle risk. With Alternative 3, the model projections indicate that some 

stands will remain at low risk through 2080 and some will become vulnerable again to bark 

beetle outbreaks as early as 2030. The difference in alternatives is due to the key issue #2.

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KEY ISSUE #4 THINNING IN OGMA, RHCA, UNROADED

Comment: Our field surveys found little tree density within the riparian zone or on steep slopes over the 

creek – not much fuel loading.

Comment: Drop all RHCA units with slopes greater than 30%. Concerned with sediments into Paulina 

Creek.

Response: The units that fall within the Riparian Habitat Conservation Area (RHCA) of Paulina 

Creek are above the upper management zone (UMZ), so density is a concern within 300 feet of the 

creek. Project design features will ensure that sediment into Paulina Creek does not occur. For 

example, machinery buffers of 75 to 100 feet from the creek are adequate buffers to limit 

sedimentation after timber harvest. Lakel et al (2010) concluded that stream buffers as little as 25 

feet were effective in limiting sedimentation after timber harvest but recommended a minimum of 50 

feet. Also, although there is a predominance of gentle slopes, the project is designed so that 

machinery would not be within 75-100 feet of the creek, and even further away when the slope is 
Appendix F Response to Public Comment

Page 10 of 45

moderately steep to steep (FEIS pp. 43-46). Under Alternative 2, only 4.5 acres within RHCA units 

planned for commercial thinning exceed 30% slope and only 1 acre under Alternative 3 (FEIS Table 

156, Figures 87, 88). Machinery would be excluded from these areas over 30% slope within RHCA 

units. Hand thinned areas would comprise 14 RHCA acres over 30% slope under Alternative 2 and 5 

acres under Alternative 3. Thinning and underburning will reduce fuels and accelerate LOS structure 

in ponderosa pine, which will eventually benefit the stream by increasing large woody material and 

shade. Fire behavior would be changed to lower intensity surface fire. Soils within RHCAs have 

high permeability and low to moderate sedimentation yield potential, limiting overland flow of 

sediments (FEIS pp. 359, 386). Additional discussion on soil disturbance is found on FEIS pp. 373 

and 380.

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Comment: Key Issue #4: Treatments within unroaded/undeveloped areas. The proposed action 

includes treating an area of 750 acres that "currently has no roaded access and was identified during

public scoping as a place to avoid except for hand thinning and underburning." In other words, no

roads would be constructed whether temporary or otherwise. Your January 11 scoping letter did not

mention any inventoried roadless areas. In fact it said that "The majority of the project area is

General Forest (MA-8) where timber production is to be emphasized..." Presuming these 750 acres

is in MA-8, there is absolutely no reason not to enter the stands. The MA-8 objective is to "convert 

unmanaged stands to managed stands" and the standard and guidelines allow for roads -both

permanent and temporary.

Response: There are no inventoried roadless areas impacted; however, public comments 

requested that any areas that appear to be undeveloped be analyzed and alternatives to 

commercial logging be considered. This became a key issue for the analysis and the IDT used 

the issue to develop Alternative 3. The difference between alternatives is where areas that 

meet criteria for potential wilderness are purposely dropped in Alternative 3. Other 

undeveloped lands (67 acres treated with Alternative 2 and 74 acres treated with Alternative 3) 

do not meet the inventory criteria for potential wilderness; most of those areas remain 

untreated under both action alternatives. The FEIS discloses the trade-offs between the two 

alternatives. An assessment of areas that appear to have no evidence of roads and meet the 

inventory criteria of potential wilderness areas is included in Chapter 3.14.

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Comment: To further reduce the contentious nature of this project, we request the Forest Service drop 

the 278 acres of potential wilderness area proposed for logging and other management and the 717 acres 

of forest that shows no evidence of past logging or road construction identified within the lodgepole pine 

forest type within the higher elevations of the Ogden project area, as the identified purpose and need for 

the lodgepole treatment does not apply to such areas.

Response: Of the 278 acres of land that meets the inventory criteria for potential wilderness in the 

Ogden project area, approximately 25 acres are proposed for treatment under Alternative 2 (see Table 

168, p. 340). In Alternative 3, these units are dropped for management. The other undeveloped 

lands, as described in the FEIS are polygons that do not meet potential wilderness criteria, and are 

small and scattered in between roads and harvest units. The majority of these areas are not treated 

under either alternative. See entire analysis pages 430-443 of the FEIS.

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Comment: Key Issue #4: Use of mechanized equipment in Riparian Habitat Conservation Area 

(RHCA) and Old Growth Management Area (OGMA). 

The executive summary states that "Scoping revealed some public opposition to using any

mechanized equipment in these areas because of the perceived potential for adverse impacts." We

object to a final decision on this Project based on what the "public"opposes and perceives. Your job
Appendix F Response to Public Comments

 Page 11 of 45

is to manage the forest and disclose the potential impacts and benefits-short-term and long-termof doing so.

Response: NEPA regulations require more than disclosing impacts. “An alternative should 

meet the purpose and need and address one or more significant issues related to the proposed 

action. Since an alternative may be developed to address more than one significant issue, no 

specific number of alternatives is required or prescribed.” 36 CFR 220.5. Alternative 3 

addresses several issues, such as using mechanized equipment within RHCAs, and it also 

meets the purpose and need for action. The Responsible Official considers how well the 

alternatives meet the purpose and need as well as how well they address key issues (FEIS p. 

15). 

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Comment: The need to protect roadless and unroaded areas (especially along Paulina Creek and the 

Monument boundary) by conducting only low-impact non-commercial restoration treatments in those 

areas. An analysis of “potential wilderness areas” does not fully capture the ecological importance of, 

and impacts to, ecologically significant unroaded areas.

Response: The FEIS evaluates the impacts of the alternatives to the areas meeting the 

inventory criteria of potential wilderness. Because the Ogden project area has been extensively 

logged since the first half of the twentieth century, the amount of areas meeting the inventory 

criteria of potential wilderness is very low. Alternative 3 would not conduct any vegetation or 

fuels treatments within those areas that meet the inventory criteria for potential wilderness. 

Those areas at issue within the Ogden project are not considered ecological significant in 

existing condition descriptions of the FEIS. The type of habitat that is provided in the PWA 

portion of the project correlates to the eastern part of the OGMA; habitat provided in that area 

is described in Appendix B, pp. 10-16.

KEY ISSUE #5

Comment: Starting at DEIS page 193, there is an excellent discussion of the goshawks’ nests, PFAs, and 

territories within the Ogden project area. Based on the analysis of the existing stand structures of these 

areas and the favorable characteristics, the proposed treatments for the PFAs in Alternative 3 seem very 

reasonable and sound. In addition, such treatments are consistent with the Forest Plan direction as 

amended by the Eastside Screens. We would support these proposed treatments for PFAs in Alternative 3.

Comment: Implement the proposed treatments for the goshawk PFAs found in Alternative 3. These 

proposed treatments are based on sound science and would lead to better conditions for the goshawk.

Response: The Forest agrees that fuels reduction and thinning proposed under alternative 3 

will provide benefit to the sustainability of the stands, but the FEIS points out that there are 

trade-offs involved between alternatives. FEIS pp. 235-240.

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TREE SIZE

Comment: In the Final EIS, we request that the Forest Service disclose how many trees (and of which 

species) between diameter 18” dbh and 21”dbh will be removed as part of the project, as well as how 

many per acre in individual units. Additionally, we request the same data for the number of trees (and 

species) and trees per acre between 16” dbh and 21” dbh that will be removed in the project. How does 

this affect overall timber volume and the potential to meet the project’s proposed purpose and need?

Response: The FEIS provides an assessment of the diameter distribution across the project area. 

This is based on stand exam data that can be extrapolated across the larger area because it portrays the 

range of stand conditions in the project area. Figures E-4 through E-9 in FEIS Appendix E display 
Appendix F Response to Public Comment

Page 12 of 45

the ratio of trees cut and retained within each size class for each of the representative stand type by 

alternative. The amount of timber volume estimated to be removed by each alternatives is based on 

those representative stand conditions. Ponderosa pine is considered saw timber when it is about 8” 

dbh and larger; lodgepole pine is considered saw timber when it is about 7” dbh and larger. The 

volume estimate does not make any finer distinction; however, the histograms in Appendix E provide 

information on size classes within the various stand types and the proportion of trees cut and retained 

within each size class.

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Comment: We urge that treatments throughout the RHCAs avoid heavy equipment and use a 10-15” dbh 

cap and retain a higher basal area of live trees. Removal of larger trees (or removal of too many trees) 

will reduce and delay recruitment of large wood to meet desired conditions for riparian and upland 

habitat. In the outer half of the RHCA, a portion of the trees up to 15” could be cut and retained onsite. 

The DEIS does not disclose the adverse effect of commercial logging in terms of reducing and delaying 

recruitment of dead wood in the riparian area. The analysis must reflect the importance of both quantity

and quality of dead wood and the long-term effects on recruitment over time.

Response: Thinning prescriptions within the RHCA will follow project design that 1) does not allow 

any thinning of trees of any size in the zone that includes riparian vegetation; 2) limits the size of 

trees to be removed nearest the stream to avoid removing shade; and 3) excludes machinery within 

75-100 feet or more of the stream, and up to 100-125 feet nest the Peter Skene Ogden Trail Only 

trees < 10” dbh will be thinned, by hand, between the machinery boundary and the stream. The 

expected benefit is maintenance and enhancement of larger trees that will provide shade and large 

down wood material in the future, thereby meeting the standards and guidelines of INFISH for 

harvest within RHCAs to not retard or prevent attainment of Riparian Management Objectives. FEIS 

p. 402 The action alternatives include protection measures to retain snags and coarse woody debris 

during thinning and fuels treatments. Although some coarse woody debris would be reduced from 

underburning, there are stream setbacks for ignition and piling, and burning must be conducted under 

conditions that limit consumption of ground cover and coarse woody debris. Adequate dead wood 

will be left on the ground to meet soil and wildlife requirements.

FUEL REDUCTION / FIRE BEHAVIOR

Comment: We support the approach in Alternative 3 of maintaining stands at or above the lower 

management zone, and the lighter touch within the RHCA. We are also cognizant, however, of recent 

research demonstrating that intensive thinning treatments are the most effective in reducing the 

probability of crown fires in the dry forests. The DEIS demonstrates that Alternative 3 would increase the 

percent of the landscape with low flame length potential (p. 149) and reduce crown fire potential (p. 154) 

but we encourage the Forest to consider this recent research as the final selected alternative is analyzed. 

(Johnson, Morris C.; Kennedy, Maureen C; Peterson, David L. 2011. Simulating fuel treatment effects in dry forests 

of the western United States: testing the principles of a fire-safe forest. Canadian Journal of Forest Research. 41(6): 

1018-1030. http://www.treesearch.fs.fed.us/pubs/38390).

Response: The change in thinning prescription between the two alternatives had no apparent effect 

to low hazard rating. Thinning prescriptions (see Figures 14-26 of Forested Vegetation section for 

projected trees to the acre) generally go to or below recommended levels of recent science regarding 

fuel treatment effectiveness as discussed in Johnson et al. (FEIS p. 163). The most important factor in 

the changing of fire hazard between the two alternatives was the reduction of underburning and 

mowing acres.

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Comment: The Forest Plan amendments will leave highly flammable slash on the ground longer, thereby 

increasing fire risk.
Appendix F Response to Public Comments

 Page 13 of 45

Response: Areas along ingress/egress routes will be prioritized for slash treatment and will be 

treated as soon as possible. The amendment allows for the visible effects to last up to five years, 

which will primarily be the effects of underburning (e.g. scorched vegetation). FEIS p. 410. 

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Comment: DEIS, Page 360: The Department recommends that the following reference be revised to

reflect the appropriate URL:

Agee, J. K., Bahro, Berni, Finney, Mark A., Omi, Philip N., Sapsis, David B., Skinner, Carl N., van 

Wagtendonk, Jan W., Weatherspoon, C. Phillip, The Use of Fuelbreaks in Landscape Fire

Management. http://www.qlg.org/pub/miscdoc/agee.htm.

Response: This has been corrected in the FEIS.

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Comment: We are opposed to spring burning during the reproductive season (after greenup) due to 

higher impacts to wildlife, fledglings, soil moisture retention, and sensitive plants not yet seeded, also to 

the Crater Lake tightcoil.

Response: The FEIS allows for both spring and late fall burning. Spring is often the preferred 

season for prescribed underburning because soils exhibit better moisture conditions, and there are 

more opportunities for burning. When possible the burning will occur outside of the nesting period 

(see FEIS pp. 47-48). Limiting burn temperatures by burning in the spring can prevent impacts to 

cultural resources that may be on or near the ground surface and also limits consumption of coarse 

woody debris while still removing fine fuels. Crater Lake tightcoil habitat occurs in the upper reaches 

of Paulina Creek (FEIS p. 220). Activities will not occur within the first 12 feet of the creek which 

provides the best potential habitat for the tightcoil. Allowing fire to back down towards the creek has 

the potential to minimally impact habitat by removing vegetative cover or burning individual 

tightcoils if present. Reducing fuel loads along the creek will be beneficial to the species’ habitat by 

reducing the risk of a wildfire such as the McKay fire that could negatively impact much more 

habitat.

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OHV AND OTHER OFF-ROAD USE

Comment: While the EIS cites potential impacts from additional anticipated OHV use in the area, it does 

not discuss or analyze the risk of creating the potential for unauthorized ATV use on reconstructed roads, 

temporary roads, or logging skid trails created as part of the project. This is a substantial issue to 

consider, particularly if the Forest Service does not have adequate resources to address the need for 

enforcement of potential illegal OHV use in the area that may accompany overall OHV use in the area 

over time.

Response: Temporary roads will be restored following their use which may serve to discourage use 

by ATV riders. Because the newly implemented Travel Management Plan closes the area to crosscountry travel, the Forest is in a better position than previously when there was no restriction to riding 

off of trails, and can utilize the motor vehicle use map to enforce the travel rule. Subsoiling and 

disguising will discourage use of the temporary roads or skid trails with ATVs.

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FORESTED VEGETATION

Comment: We support using variable treatments to achieve “clumpy, patchy, gappy” conditions using a 

combination of untreated “skips” heavily thinned “gaps,” culturing of small group s of 2-10 trees, and 

thinning to variable basal area targets.
Appendix F Response to Public Comment

Page 14 of 45

Response: Proposed treatments, including thinning and underburning, will provide “clumpy, patchy, 

gappy” conditions at varying scales. Existing stand conditions will drive where these variable 

conditions occur and the extent to which they occur. Monitoring has shown this to be effective in 

achieving “clumpy, patchy, gappy” conditions. Alternative 3 varies treatments the most by using a 

variety of thinning and burning treatment combinations (FEIS 3.3.8, Key Issue #2).

At the treatment unit scale, dwarf mistletoe and species composition will drive where heavily thinned 

“gaps” occur and the size of gaps. Within ponderosa pine dominated stands, heavily thinned “gaps” 

will occur where dwarf mistletoe infection levels are high. In mixed species stands, heavily thinned 

“gaps” will also occur where ponderosa pine stocking is light. In addition to creating gaps, removal 

of lodgepole pine from these stands will culture small groups of ponderosa pine. In mixed species 

stands, heaviest thinning would occur with Alternative 2 (FEIS 3.3.8, Key Issue #2). Landings 

created to facilitate harvest operations would function as small “gaps”. Proposed underburns could 

also create small “gaps” within treatment units.

At the treatment unit scale, existing tree diameters and site productivity will drive where higher basal 

areas occur, contributing to “clumpy, patchy” conditions. Higher basal areas will be retained where 

trees are greater than or equal to 18 inches dbh (FEIS p. 30, Table 6). “Skips” would occur where 

small groups of trees greater than 21 inches dbh occur. On higher productivity sites within the project 

area (mixed conifer plant associations), higher basal areas will be retained (70 to 80 square feet). On 

the lower productivity sites, lower basal areas will be retained (50 to 60 square feet).

At the landscape scale, the project retains patches that have not been treated since the area was logged 

historically. These areas, distributed across the project area, provide untreated “skips” that vary in 

size.

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Comment: We encourage the FS to recognize the ecological value and importance of natural 

disturbance processes including beetles which help thin over-stocked forests and large trees infected with 

mistletoe, and the need to retain large tree structure associated with infected trees. Even if the FS thinks 

large infected trees should be killed, they should be retained on-site to meet ecological goals associated 

with large snags which are currently in short supply. We urge the FS to tolerate ecologically appropriate 

levels of beetles and mistletoe and not try to manage as if beetles and mistletoe were ecologically adverse 

conditions.

Response: In developing Alternatives 2 and 3, the Forest Service recognized the ecological value of 

natural disturbance processes, including beetles and dwarf mistletoe. Both alternatives retain areas of 

1) high density stand conditions and 2) past seed tree harvest where lodgepole pine seed trees are 

infected with dwarf mistletoe. Proposed treatments will not eliminate beetles or mistletoe from the 

project area or surrounding landscape, but the Forest Service desires to keep disturbance processes 

within proportions that move treatment areas and the larger landscape towards desired conditions.

While Alternatives 2 and 3 increase the proportion of the landscape resilient to bark beetles, the 

alternatives also retain a proportion of the landscape in conditions that would be susceptible to bark 

beetle attack. Resilience to bark beetles will be improved on a large enough proportion of the 

landscape that large tree structure could potentially develop to within the mid-range of Historic Range 

of Variability (FEIS, pp. 119-123). At the same time, Alternatives 2 and 3 retain high density stand 

conditions on approximately 30 to 35 percent of ponderosa pine and mixed conifer biophysical 

environments. Bark beetles would continue to function as an agent of change within these dense 

stands which have a component of medium and large diameter trees.

While Alternatives 2 and 3 propose treatments to remove lodgepole pine seed trees on 968 and 954 

acres respectively (seed trees are generally 8 to 10 inches dbh), both alternatives also include a 

proposal to retain on site all existing seed trees present on approximately 230 acres.
Appendix F Response to Public Comments

 Page 15 of 45

Alternatives 2 and 3 treat existing lodgepole pine seed tree regeneration harvest units with the 

objective of moving them to an intermediate age/size class (FEIS, p. 50, Table 9)1. Where seed tree 

removal is proposed, additional objectives include continuing development towards an even-aged 

stand condition and minimizing mistletoe spread to developing young lodgepole pine. The meeting 

of these objectives will move these lodgepole pine units towards the desired condition described in 

the Forest Plan and in the FEIS (pp. 3-4). Both Alternatives 2 and 3 would retain 3 trees per acre of 

the existing seed trees to provide for future snag habitat within treatment units. 

Alternatives 2 and 3 forgo removal of seed trees from 230 acres of existing seed tree regeneration 

units. Within these units, in addition to the objective of moving stands to an intermediate age/size 

class, there is an objective to maintain existing vertical diversity for wildlife habitat (FEIS, p. 50). 

Small understory trees would be thinned to facilitate the recruitment of future large diameter trees. 

Alternative 2 would create an additional 362 acres of habitat conditions similar to that found in 

existing seed tree units.

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Comment: There is some concern that the 6 units used as examples for purposes of analysis may not be 

representative of the very large project area. NEPA is supposed to be site-specific, not hypothetical.

Response: The FEIS (Section 3.3.3, pp. 68-70) describes a general overview of the analysis methods 

used to evaluate effects to forest vegetation. Additional descriptions of methods used to analyze 

effects are documented in each subsection of the Forested Vegetation Section. The Forest Vegetation 

Simulator software (FVSS) was used to analyze, in detail, different thinning and underburning 

treatment combinations used between alternatives. Other methods of analysis were used to assess the 

more general effects across treatment units and across the broader landscape.

The FEIS describes how the 6 sample units were selected for the detailed FVSS analysis (Section 

3.3.3, pp. 68-70). Additional descriptions of the 6 sample units are found in Table 19 (FEIS, p. 86). 

Selection was based on data availability, stand condition, and proposed treatments. The six selected 

sample units and associated treatments were considered to adequately portray the range of conditions 

and treatment combinations, allowing for a comparison of effects associated with each alternative.

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Comment: Figures 34 and 35 are confusing. It looks like the “multi-stratum” and “stem exclusion” 

forest types are being eliminated, but those forest types have a role to play and should not be eliminated. 

Also, these figures make it look like the “pie is getting smaller” over time without explanation. 

“Combined structures” is a vague term that does not convey much ecologically useful information.

Response: Figures 34 and 35 are two of a series of five similar figures that attempt to display 

1) the proportion of ponderosa pine and mixed conifer structural stages currently found within the 

HRV analysis area, and 2) the proportion of those structural stages closest to developing into late and 

old structure (understory reinitiation and multi-stratum without large trees) stocked at low, moderate, 

and high density. The understory reinitiation and the multi-stratum without large tree structures are 

described in the FEIS p. 114. For display purposes in these figures, these two similar structural stages 

have been combined. Some clarification of these figures has been added to the FEIS.

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Comment: In looking at the “unmanaged” units unique to Alternative 3 in the SW end of the sale area, it 

appears that more of the dense lp/pp is sustainable (w/ healthy pp and some natural succession die off of 

lp) than assumed in this DEIS. 

 

1 These are stands that were clear cut harvested between 1983 and 2000, to establish a new stand of lodgepole pine. 
Appendix F Response to Public Comment

Page 16 of 45

Response: Dense LP/PP stand conditions are not sustainable due to lack of resistance to fires/beetles. 

When beetles attack lodgepole pine they can kill nearby ponderosa pine as well. The Ogden project 

area includes a number of examples of stand replacing wildfires that occur in these conditions.

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Comment: EIS estimate for HRV to be reached by 2060 does not account for natural disturbance; no 

beetle influence is unrealistic and unnatural.

Logging of mature trees also removes potential to develop into large trees. 

Response: The analysis does address how natural disturbance, specifically bark beetles, could 

influence the potential to develop late and old structure (LOS). The DEIS (Section 3.3.3, p. 68 and 

elsewhere) documents that while FVS model projections do not reflect mortality that could result 

from bark beetle attacks, FVS model projections were compared to reference conditions for bark 

beetle risk. The FEIS (Section 3.3.9) documents the analysis pertaining to the Historic Range of 

Variability (HRV). Figures 36 to 39 (pp. 117 – 119) display the number of large trees projected to be 

present within selected sample units through the year 2080. Large tree projections consider thinning 

and underburning effects. Large trees projected to be present through time are compared to historic 

late and old reference conditions. Figures 36 to 39 also display the timing of large trees development 

in relation to the development of high stand density and beetle risk. The HRV analysis documents 

that depending on level of mortality resulting from bark beetle attack, the time projected for large tree 

structure to increase to reference conditions could be further delayed.

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Comment: How is more logging the answer to the existing condition being attributed to historic logging 

practices?

Response: The existing condition is attributed not only historic logging practices (which removed 

the large trees), but also fire suppression which has contributed to densely stocked stands and high 

levels of surface fuels over much of the area. 

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Comment: How is it known that fire suppression played a role in the development of the current 

condition? What is the number of lightening fires in the area that were suppressed during the time period 

since logging?

Response: Chapter 3.4.5 of the FEIS describes past fire occurrence within the project area. Records 

are available from 1904 to present. Of 52 lightning-caused fires recorded since 1980, 39 were kept to 

< 0.1 acres, only one reached more than 3 acres. It is well established that fire historically played a 

role in keeping stocking levels low. Fire suppression has also led to increased ladder fuels and the 

proportion of lodgepole pine and true fir.

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Comment: Why log in stands that are within the UMZ now?

Response: A few reasons for harvesting trees from stands currently stocked between the lower and 

upper management zones include: 

1) To extend the length of time stands remain resilient to bark beetle attack, 

2) To reduce lodgepole pine stocking levels where use of prescribed fire is planned, 

3) To accelerate individual tree growth so large diameter trees are recruited faster, 

4) To reduce tree density to levels more common with historic conditions, and 

5) To create open habitat conditions favored by certain wildlife or plant species.

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Appendix F Response to Public Comments

 Page 17 of 45

Comment: Departure from HRV in ponderosa and mixed conifer PAGs is due to mature or large tree 

logging. Need to give trees time to grow larger.

Response: The thinning and fuels reduction proposed in each action alternative will provide more 

time for the understory reinitiation and multi-stratum without large tree structural stages to develop 

into large tree structures without the influence of beetles or wildfire. The analysis documents that 

beetles could delay the time it will take for large tree structure to develop. Stand replacing wildfires 

could result in large patches of early seral conditions, lengthening the time it will take for the 

proportion of large tree structure to reach HRV.

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Comment: The desired condition states that stand densities would be below the level at which mortality 

from mountain pine beetle can become serious. What is “serious” and on what basis is it determined the 

stand “can become” serious?

Response: The desired condition described in the FEIS (pp. 4-5) describes undesirable impacts from 

insects in the context of integrated resource management objectives. The desired condition described 

is taken from the LRMP.

The Forested Vegetation section (FEIS, p. 72) does define the upper management zone as “those 

stand densities above which mortality from mountain pine beetle can become serious” (Cochran’s 

definition of upper management zone). In the analysis of HRV, what can happen when an outbreak 

of mountain pine beetle occurs in ponderosa pine is described (p. 118). Up to 67 percent of the 

current basal area, mostly in the largest trees, could have expected mortality. The analysis of bark 

beetles documents that if beetle populations build up to outbreak levels, 40 to 60 percent of the stand 

can be killed (FEIS p. 130). 

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Comment: When stating that there is an overabundance of mid-seral ponderosa pine, it’s a mis-use of 

the “seral” terminology regarding natural succession.

Response: The referenced statement has been modified to state that within ponderosa pine, there is 

an overabundance of the “multi-stratum without large trees” structural stage.

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Comment: Why are larger seed trees removed in lodgepole seed tree harvest units?

Response: The seed tree harvest units were established by regeneration harvest (clearcut) between 

1983 and 2000. Seed trees were retained in the units to provide a seed source for regeneration of a 

new stand. The understory has reached a point where the seed trees are no longer needed and the 

stand is adequately stocked. The Forest Plan describes the desired condition for lodgepole pine 

stands as being even-aged. Removal of seed trees would move stands more towards this condition 

and would reduce potential for mistletoe to spread to developing understory trees.

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Comment: Re: an alternative that involves no commercial logging, why does merchantable material 

need to be removed to begin the restoration process (DEIS p. 50)?

Response: The purpose and need for the Ogden project includes providing timber and other forest 

products to the local and regional economies (FEIS p. 5). Additionally, one of the “Restoration 

Principles” identified by the Upper Deschutes Basin Fire Learning Network is making by-products of 

forest restoration treatments available for utilization in ways that support local businesses and 

workers and that build local capacity to implement further restoration work. The EIS analyzes an 

alternative that drops commercial harvest from those units where desired resilience to disturbing 

events would still be provided and where the units would continue on a trajectory towards LOS (993 
Appendix F Response to Public Comment

Page 18 of 45

acres). This is summarized in Table 5 (FEIS p. 25). An alternative that would not remove any 

merchantable material was not considered in detail because it would not meet the purpose and need of 

providing wood fiber. 

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Comment: Logging to minimum stocking levels is a harsh and sudden large-scale alteration of the forest, 

not in keeping with restoration principles of making changes gradually and maintaining biodiversity.

We want no use of the min. stocking levels and higher than the LMZ stocking levels in sale units now 

considered under Alt. 3. 

Response: Alternative 3 was developed to respond to the Issue #2, which addresses thinning level

and residual stocking. Alternative 2 and 3 thinning treatments are consistent with the Principles of 

Restoration described by the Upper Deschutes Fire Learning Network. Making changes gradually is 

not one of the restoration principles described by the Fire Learning Network.

Upper and lower management zones used to guide thinning were developed using the best available 

science (e.g. Cochran et al 1994). Thinning to minimum stocking levels would only be used in those 

areas where ponderosa pine stocking is lacking. Analysis of proposed thinning and burning shows 

the effects of treatments on potential for stands to develop large trees to levels historically present.

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Comment: Re: regeneration cutting in mixed conifer – In general, if grand fir and lodgepole pine are 

coming in, that’s what it naturally is, and it shouldn’t be clearcut. We want all acres (35) dropped. 

Response: Alternative 3 drops these 35 acres. The Restoration Planning Sub-committee for the 

Deschutes Skyline CFLRP developed dry mixed-conifer management recommendations. These 

recommendations can be applied to areas outside the CFLRP. Recommendations include promoting 

tree species that are resilient to fire and retaining dominant ponderosa pine regardless of spacing to 

achieve large structures and clumps. Regeneration harvest proposed with Alternative 2 in mixed 

conifer and ponderosa pine plant associations is consistent with these recommendations.

Regeneration harvest is proposed in lodgepole pine dominated stands within the mixed conifer and 

ponderosa pine plant associations to move species composition closer to the ponderosa pine 

dominated stand conditions. This desired condition is similar to that which was historically present. 

Without active efforts to regenerate ponderosa pine, lodgepole pine will continue to be the dominant 

tree cover.

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Comment: We are in favor of all seed tree logging be dropped or reduced to only mistletoe-infected 

lodgepole.

Response: While Alternatives 2 and 3 propose treatments to remove lodgepole pine seed trees on 

about 950 acres, both alternatives also include a proposal to retain on site all existing seed trees 

present on approximately 230 acres.

Alternatives 2 and 3 treat existing lodgepole pine seed tree harvest units with the objective of moving 

them to an intermediate age/size class (FEIS, p. 50, Table 9). Where seed tree removal is proposed, 

additional objectives include continuing development towards an even-aged stand condition and 

minimizing mistletoe spread to developing young lodgepole pine. The meeting of these objectives 

will move these lodgepole pine units towards the desired condition described in the Forest Plan and in 

the FEIS (p. 4). Alternatives 2 and 3 would retain 3 trees per acre of the existing seed trees to provide 

for future snag habitat within treatment units (FEIS pp. 30-31). 

Alternatives 2 and 3 forgo removal of seed trees from 230 acres of existing seed tree regeneration 

units. Within these units, in addition to the objective of moving stands to an intermediate age/size 
Appendix F Response to Public Comments

 Page 19 of 45

class, there is an objective to maintain existing vertical diversity for wildlife habitat (FEIS, pp. 50). 

Small understory trees would be thinned to facilitate the recruitment of future large diameter trees. 

Alternative 2 would create an additional 362 acres of habitat conditions similar to that found in 

existing seed tree units.

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Comment: We disagree with the use of mandated arbitrary “desired stocking levels” (generally 

excessively low basal areas) at the expense of dominant and co-dominant crown classes and healthy tree 

retention. Stand density optimum for a site is not fixed in stone, but varies greatly across the forest 

landscape based on slope aspect, elevation, moisture retention, soil productivity, and other microclimate 

conditions. The lower management zone is probably too low for historic mixed conifer and the minimum 

in Table 6 is too low in general – a virtual clearcut.

Response: The FEIS (pp. 70-71) describes reference conditions for historic tree densities, stand 

density concepts, and procedures used to determine management zones (or desired stocking levels). 

Upper and lower management zones were developed using best available science (e.g. Cochran et al 

1994; Simpson 2007). Recognizing different site productivity within the Ogden project, upper and 

lower management zone vary by ponderosa pine and mixed conifer plant associations (Table 16, FEIS 

pp. 73). Within mixed conifer plant associations, areas dominated by ponderosa pine will be thinned 

to 70 to 80 square feet of basal area (Table 6, FEIS pp. 30). In contrast, in the ponderosa/lodgepole 

pine associations, thinning will be to 50 to 60 square feet of basal area (Table 6, FEIS pp. 30). 

Thinning as described in the DEIS (p. 29) would be from below favoring the best, most dominant 

trees with the least amount of dwarf mistletoe. Where thinning from the low crown classes will not 

reduce stocking to the lower management zone, trees from the dominant and codominant crown 

classes will be removed to favor the best trees of those same crown classes. 

The FEIS documents the analysis of how thinning and burning treatments effect potential for 

developing large trees to densities historically present (pp. 109-128, Figures 37-39, pp. 126-128).

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Comment: Not all trees contribute to excess stand density, especially in an area like Ogden that lacks 

large trees. It is not true that generally trees between 16” and 21” are contributing to stand density 

(DEIS p. 51). 

Response: Histograms have been added to the EIS (see Appendix E) and these provide information 

on the size of trees that contribute to stocking in the Ogden project units.

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BOTANY / INVASIVE PLANTS

Comment: Section 3.11 Botany, Invasive Plants I Noxious Weeds: In addition to this Section, invasive

plant mitigation was discussed in the Section 2.5 Protection Measures and also in Section 2.7

Monitoring Common to Alternatives 2 and 3. None of these Sections mentioned the need for

rechecking for noxious weeds after work is completed and monitoring for an additional.

Response: Monitoring for effectiveness of prevention measures is listed as a sale area improvement 

plan. Monitoring takes place following subsoiling of skid trails, landings, and other areas.

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Comment: What about measures to prevent increased introduction and dispersal of exotic invasive 

plants?

Response: The project involves clean-equipment provisions and a requirement to treat certain 

existing weed sites prior to implementation (the treatment of these sites is covered under existing 
Appendix F Response to Public Comment

Page 20 of 45

invasive plant treatment NEPA or would be hand pulled). The prevention strategy for timber and 

road management activities is described in the FEIS pp. 417-418.

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ROADS / TEMPORARY ROADS

Comment: We are opposed to re-opening closed roads and construction of “temporary” roads, which 

defeats Forest Service programs to reduce the road system.

Response: The overall road system in the project area will be reduced as proposed in the Lava Rock 

OHV project. About 58 miles of roads will be closed or decommissioned as a reasonably foreseeable 

future action. In order to implement the Ogden project access is need for equipment and trucks. The 

use of already existing roads is the best way to provide access; the use of temporary roads in

necessary is some locations. These roads are not part of the road system and will be restored 

following use by establishing ground cover protection and possibly subsoiling.

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Comment: Why are no roads proposed for closure and decommissioning?

Response: A proposal to designate trails for off road vehicles and to close some system roads was 

published in the Schedule of Project and scoped with the public in 2009 as the Lava Rock project, at 

about the same time the Ogden project was announced. The Ogden project has considered the road 

closures proposed in the Lava Rock project as a reasonably-foreseeable future project under the 

cumulative effects analysis. 

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Comment: We urge the FS to avoid and minimize road construction.

Response: Neither alternative includes permanent road construction. The location of temporary 

roads utilizes past logging systems as much as possible to minimize new impacts.

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GEOTHERMAL ACTIVITIES

Comment: Upon review of the DEIS, our primary concern is regarding the potential for

conflicts with our geothermal activities.

Comment: The Ogden project could adversely affect our ability to plan and implement geothermal

exploration and development activities on our leases. ... Access to and implementation of our field

operations, including any that may be planned in the future, must not be hindered or restricted and

the use of the geothermal leases must not be constrained because of the Ogden project.

Given the proximity of federal geothermal leases and our exploration projects, geothermal

activities within the Ogden project area should be more fully addressed in the EIS. It would be

important to include a map which overlays existing geothermal leases to best depict how our

projects correlate with Ogden units. 

Comment: To prevent conflicts with our operations, the EIS should include a protection measure

which ensures geothermal activities will not be restricted or delayed because of the Ogden project. 

We request that you ensure that the Forest Service maintains productive communication and

coordination with Davenport regarding projects in this area and suggest this requirement be listed as

a protection measure.

Comment: Section 2.5, Resource Protection Measures Common to Alternative 2 and Alternative 3: 

Please add another category, "To protect geothermal project sites and operations", to this list.
Appendix F Response to Public Comments

 Page 21 of 45

Protection Measure #6: Please coordinate operations with "geothermal operators and lease

holders".

Protection Measure #50: Please clarify what is meant by and included in "disturbing activities".

Comment: Davenport sees the Ogden project providing opportunities to coordinate and further

minimize effects associated with our geothermal exploration and development projects by siting any

future geothermal activities within openings and areas disturbed by the Ogden project. Because any

future geothermal projects to be sited in the Ogden area would likely address the same resources, we

also see future opportunities to share, utilize, and supplement resource data collected, analyzed, and

referenced in the Ogden EIS.

Response: The FEIS Appendix D displays the location of geothermal lease areas being considered 

by the Forest Service in an Environmental Assessment, as well as the locations of current exploration 

activities. The Forest Service understands that there is potential for geothermal and project treatments 

to potentially occur concurrently. It is important that when activities begin, communication and 

coordination take place so that potential conflicts can be rectified prior to implementation activities. 

The Ogden units that require this kind of coordination are listed in Appendix D and in Chapter 2 

project design feature #7. The project Implementation Plan will specify contacts that will be 

responsible for seeing that coordination occurs. Protection measures (now #54 and 55) that restrict 

disturbing activities near nests are for activities under this vegetation management project. Any 

restrictions on geothermal activities would be identified in those NEPA decisions and/or permits.

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Comment: Chapter 2, description of Alternatives 2 and 3: This chapter summarizes treatments

being proposed in individual units, but it does not disclose timing and duration of these treatments

nor the sequence in which the units will be treated. So that we can have a better understanding of

the project and how it may affect our activities, it would be very helpful to have an idea of when and

where the various operations would be occurring. We request that this be added in the final EIS.

Response: Coordination with permittees in the Ogden project is part of the project design and will be 

incorporated into implementation plans. We have incorporated a general description of the sequence 

of treatments into Chapter 2. The entire implementation will take several years to complete, 

beginning with the commercial timber sale operations, so the exact timing and duration cannot be 

precisely predicted. The Forest will coordinate with all permit holders, including geothermal 

operators.

WILDLIFE

Comment: Logging to modify fire behavior does not provide habitat benefits for species that prefer 

dense forests (such as goshawk, pileated woodpecker, and marten), because logging reduces stand 

density and habitat quality for these species, and since the location and timing of fire (and insects) cannot 

be predicted, fuel treatments must be extensive and will end up treating many acres that will not 

experience fire (or insects) during the period that treatments are effective. Thus, the adverse habitat 

effects of “logging plus fire” will degrade more habitat than “fire alone.” For an analytic explanation 

and example, see Heiken, D. 2010. Log it to save it? The search for an ecological rationale for fuel 

reduction logging in Spotted Owl habitat. Oregon Wild. V 1.0. May 2010. 

http://dl.dropbox.com/u/47741/Heiken_Log_it_to_Save_it_v.1.0.pdf. In discussing habitat for species 

that prefer dense forests and abundant dead wood, the DEIS did not clearly disclose the adverse 

cumulative effects of logging+fire compared to fire alone.

Response: The referenced document focuses on western Oregon and spotted owl habitat. The 

Ogden project does not involve any spotted owl habitat. The forests of the Ogden project area are 

primarily ponderosa pine that because of industrial logging of the last century and fire exclusion are 

outside of HRV and in need of thinning and fuels reduction. Underburning after thinning is intended 
Appendix F Response to Public Comment

Page 22 of 45

to reduce surface fuels, increase crown base height, and potentially decrease crown bulk density. In 

some stands, thinning alone or underburning alone is proposed when it can meet the objectives. The 

EIS addresses the potential reduction in dead wood resulting from prescribed fire. The objectives for 

burning are to retain large woody material to meet Forest Plan standards while recognizing that the 

project area historically saw more frequent fire that maintained lower stocking and large woody 

material. The wildlife section of the FEIS discloses that by thinning, mowing, and burning these 

stands the action alternatives will benefit some species while negatively impacting others. 

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Comment: DEIS, Page 254: The work of the USGS investigator is inaccurately captured in this section. 

Here, the DEIS states that “Hagar (2007) supports this rationale by suggesting large dead wood is

difficult to provide because of past harvest and safety reasons;” however, in Hagar’s work she stated:

“As more information is revealed about the ecological and habitat values of decaying wood, 

concern has increased over a reduction in the current amounts of dead wood relative to historic

levels (Ohmann and Waddell, 2002). ... Current guidelines for managing dead wood may be 

inadequate to maintain habitat for all associated species because they largely focus on a single

use of dead wood (nesting habitat) by a small suite of species (cavity-nesting birds), and may

under represent the sizes and amounts of dead wood used by many wildlife species (Rose et al., 

2001, Wilhere, 2003).”

The FEIS should reflect that Hagar suggests that the guidelines for managing dead wood may be 

inadequate.

Response: The FEIS now references Bull et al (1997) in support of the discussion regarding impacts 

to down wood (FEIS p. 350).

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Comment: The DEIS acknowledges that Alternative 2 would remove 87.5 acres, and Alternative 3 would 

remove 91 acres, of habitat for the Pacific fisher respectively. The Pacific fisher is currently a candidate 

for listing under the Endangered Species Act and a determination from the US Fish and Wildlife Service 

is due by 2014. As a result, we suggest that no removal of Pacific fisher habitat occur as part of the 

Ogden project regardless of whether the Forest Service has determined whether Pacific fisher currently 

occupy this suitable habitat.

Response: The FEIS discloses that within the cumulative effects analysis area, there is 4,681 acres of 

fisher habitat available. Alternatives 2 and 3 treat about 90 acres of marginal habitat that will have 

few direct or indirect impacts to fishers. Since the DEIS was released, an additional resource 

protection measure has been added (#61) to retain all down logs in certain units as a mitigation for 

marten habitat and some of these units are also considered fisher habitat (54, 285, 342, 947, and 951). 

The FEIS includes analysis of the No Action alternative which does not harvest within any Pacific 

fisher habitat. 

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Comment: There’s no ecologically sound reason to eliminate lodgepole pine forest that has reached a 

late seral condition and provides good hiding and thermal cover for elk and deer.

Response: The objectives for treating in lodgepole pine units are summarized in Table 9 of the FEIS. 

These objectives are based on the purpose and need and direction in the Forest Plan. The FEIS 

addresses hiding and thermal cover for elk and deer on pages 259-268. Management in the summer 

range is designed to provide adequate habitat quantity and quality to meet herd management 

objectives, which requires a mosaic of forested conditions (FEIS p. 259). Late seral lodgepole pine 

forest will not be eliminated with either action alternative. Currently, about 76 percent of the 

lodgepole pine analysis area is considered older stands (which is > 40 years for lodgepole pine) (FEIS 

p. 78). Under Alternative 2, regeneration harvest in lodgepole pine (either clearcut with seed trees 
Appendix F Response to Public Comments

 Page 23 of 45

reserved – 362 acres, or clearcut with ponderosa pine and white fir reserved – 35 acres) is proposed 

on 397 acres (223 acres that have been previously harvested and 174 acres that have not been 

previously harvested). 

Under Alternative 3, these 397 acres of regeneration harvest treatments within the lodgepole would 

not occur. Under the No Action alternative, none of this harvest would occur.

Under either action alternative, late seral lodgepole would continue to be abundant in the analysis 

area (Table 18, FEIS p. 78). Regeneration harvest (clearcut with seed trees reserved) in the lodgepole 

pine is expected to remove 292 acres of cover, with a future increase in cover from regeneration 

(FEIS p. 263). The amount of cover available on the landscape currently exceeds levels 

recommended in the LRMP. Under both action alternatives, cover will remain above levels 

recommended in the LRMP for the landscape and the areas with high concentrations of deer use will 

retain hiding cover (FEIS p. 268). 

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Comment: Goshawks are very sensitive to human disturbance and are adapted specifically to denser 

forest conditions, so logging degrades or eliminates post-fledging area security for goshawk 

reproduction.

Comment: If goshawk are using the PFA within the last 5 years, leave them alone and do fire risk

reduction around goshawk territories (e.g. Malheur Soda Bear collaborative project).

Comment: We can’t agree with logging goshawk PFAs and don’t understand why this is part of 

Alternative 3, which is otherwise a more environmentally sound alternative (though not ideal). There 

should be no commercial size logging or disturbance in any nest stands, and no commercial thinning, 

burning, mowing, or widespread non-commercial thinning in any of the PFAs. The vast majority of the 

planning area would be wide open and unsuitable for goshawk under either action alternative; more 

density and diversity needs to be retained. 

Response: The analysis in the FEIS supports the statement that goshawk are sensitive to disturbance 

and are adapted to denser forest conditions. Effects to goshawk are disclosed in the FEIS pp. 235-

240. The goshawk PFAs in the Ogden project area are 631, 446, and 445 acres in size. Thinning will 

with Alternative 3 occur on 50 (8%), 146 (33%), and 147 acres (33%) respectively. Nest sites are 

always protected, and a nest core area is not entered. Alternative 1 (No Action) and Alternative 2 

both avoid treatment within the PFAs.

The treatments proposed under Alternative 3 are also consistent with direction in the Eastside Screens 

to retain LOS and enhance younger stands towards LOS condition and have the objective of 

promoting larger tree structure focusing on the more fire resistant ponderosa pine. Because the stands 

that comprise the PFAs are not sustainable in the long term in their current condition (beetles are 

already causing mortality in the lodgepole understory and moving into the larger ponderosa pine), 

reducing risk to the larger ponderosa pine (potential future nest trees) is necessitated because they 

take the longest to replace; the trade-off being a loss of close-canopied characteristics in the shortterm. 

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Comment: Naturally-denser moister mixed conifer types (e.g. with historic old growth grand fir) and 

higher elevation or natural lodgepole pine/fir stands should be left alone to provide needed hiding and 

thermal cover for deer and elk; habitat for goshawk; pileated woodpecker, and other denser-forest 

associated species; greater plant biodiversity; carbon storage in the advent of climate change; and 

recreational values. 

Response: Within the project area the plant associations are primarily dry (see Figure 29, p. 112) and 

lodgepole pine and white fir stocking is higher than historic levels. More frequent low intensity fires 

would have naturally kept the lodgepole and white fir stocking lower throughout much of the project 
Appendix F Response to Public Comment

Page 24 of 45

area. The HRV analysis shows that the understory reinitiation structural stage in mixed conifer and 

the stem exclusion closed canopy and understory reinitiation structural stages in lodgepole are above 

the HRV. In the understory reinitiation structural stage large trees are uncommon and overstory trees 

are small or medium diameter. This type of stand is well situated to develop into large tree structure, 

which is below the HRV but high stocking makes much of it at risk to bark beetle attack. The 

impacts to habitat for big game, goshawk, pileated woodpecker and other species are disclosed in 

Chapter 3: some species benefit from the retention of denser forest, while others benefit from a more 

open forest. 

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Comment: We are concerned by potential effects to wolverine and Pacific fisher from logging in de facto 

roadless areas and less disturbed areas or dense mixed conifer habitat. We are also concerned by 

potential impacts to Harlequin ducks, northern waterthrush, northern goshawk, and potential Pacific 

fishers from thinning and burning along Paulina Creek.

Response: The Biological Evaluation considered potential impacts to the California Wolverine 

(FEIS pp. 187-189). Because none of the actions in either alternative occur in wolverine habitat, 

there will be no direct impact to the species or their habitat. Pacific Fisher were also considered in 

the Biological Evaluation. The project would have few direct or indirect impacts to fishers; the 

determination was that the actions may impact individuals or habitat, but are not likely to contribute 

to a trend towards federal listing. Harlequin duck may be disturbed but only minimally impacted 

(FEIS pp. 200-201). Because the northern waterthrush uses habitat further from the creek, a small 

amount of their habitat will be impacted (as disclosed in the FEIS). There will be benefits to habitats 

occurring in the RHCA because of fuels reduction and thinning that will promote large tree structure.

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Comment: Logging of the OGMA would directly hurt any resident pileated woodpeckers, northern 

goshawk, pine marten, or Pacific fisher. Thinning out too much of the existing forest density could 

negatively affect northern goshawk, coopers’ hawk, sharp-shinned hawk, great grey owl, elk, pine 

marten, mule deer, brown creeper, flammulated owl, and hermit thrush (MIS and neotropical migratory 

songbirds).

Response: The OGMA provides various types of habitat as it grades up in elevation from west to 

east, but a large portion of the trees in the OGMA are in smaller size classes (FEIS Appendix B). The 

focal species are black-backed woodpecker in lodgepole, goshawk in ponderosa pine, and American 

marten in mixed conifer. The proposed actions in Alt. 2 will maintain the larger ponderosa pine that 

occur on south facing slopes by thinning and fuels reduction and the actions are subject to the 

restrictions described for RHCA, as they overlap. Alternative 3 treats fewer acres and foregoes units 

that would require temporary road construction. And Alternative 1 includes no treatment within the 

OGMA. All of the species listed in the comment are addressed in the FEIS section 3.6. Logging 

would not directly affect pileated woodpeckers and other species listed in the comment; rather there is 

an indirect effect because it impacts habitat. Habitat effects are disclosed in the analysis. The tradeoff where the OGMA is not thinned, is less fuels and density reduction, so the purpose and need is not 

addressed in that area.

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Comment: We are concerned by potential impacts to dispersing foraging wolverines especially if it is 

possible that wolverines are denning in the adjacent Newberry Crater and have 5,800 acres of suitable 

habitat in the nearby “cumulative effects” area. How is it determined that there are no indirect impacts 

when they could be denning in Newberry Crater?

Potential cumulative impacts to the wolverine from the Ogden project include increased human 

disturbance, fires and fragmentation, fewer elk and deer to scavenge due to lack of cover....
Appendix F Response to Public Comments

 Page 25 of 45

Response: Potential effects to wolverine are addressed in the FEIS pp. 187-189. Because no habitat 

will be affected by the project, and they are limited in the area because of existing uses, the 

determination is that there would be no direct, indirect, or cumulative impact. The quality of the 

wolverine habitat and their use of the area is limited by the high degree of human recreation use in the 

project area and Newberry Crater.

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Comment: Shorter term impacts [northern waterthrush DEIS p. 180] can be enough to negate any longterm benefits assumed because the species may no longer exist there. 

Response: Short-term impacts are not expected to remove species from the project area. The 

northern waterthrush, for example, may be disturbed during implementation but there are long-term 

benefits to making the habitat more sustainable. Disturbance along the stream is already ongoing, due 

to the popularity of the area with recreationists.

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Comment: Why are there no surveys for any of these species in the project area to ascertain population 

status and viability thresholds? There have also been no population studies or surveys for Pacific Fisher. 

Drop all potential fisher habitat. Lots of cumulative impacts, so let’s not restrict fishers more or further 

decrease habitat suitability through the Ogden project. 

Response: The analysis assumes that species occupy or could occupy habitat if appropriate habitat 

components are available. The FEIS describes what surveys and field reviews took place (FEIS p. 

187). The FEIS discloses that Alternative 2 would treat 87.5 acres and Alternative 3 would treat 91 

acres of the 4,681 acres of Pacific fisher habitat available in the cumulative effects analysis area. The 

habitat impacted is marginal for the species because the drier ponderosa and lodgepole forest types of 

the project area are not commonly associated with good fisher habitat.

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Comment: Drop the 83 acres of potential Crater Lake Tightcoil (snail?), especially in the absence of 

surveys. 

Response: Crater Lake tightcoil are found in perennially-wet areas of mature conifer forests. With 

alternative 2, no thinning will occur within the first 12 feet of the creek which serves as the most 

suitable habitat. The 83 acres that are thinned under Alternative 2 may have minimal impacts by 

potentially removing some cover during burning. Alternative 3 drops these 83 acres of treatment that 

is considered potential tightcoil habitat. Alternative 1 has no treatment within potential tightcoil 

habitat.

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Comment: A 15” dbh maximum cutting limit in goshawk territories is advised to limit impacts to 

goshawk while leaving larger trees to mature into old growth with no logging in PFAs. 

Response: The FEIS references recent science for goshawk habitat management (Youtz, et al 

(2007)). This paper does not suggest a maximum diameter limit. The FEIS explains that based on 

current science, goshawks will utilize a variety of habitats and/or forest size classes across a territory. 

FEIS p. 234. In this project, Alternatives 1 and 2 do not enter goshawk PFAs. 

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Comment: The Ogden action Alternative 3 would require an amendment to the Forest Plan due to 

proposed logging of goshawk nest stands. This is not advisable and logging of goshawk nest stands and 

PFAs has no ecological basis. We are opposed to such logging. Most science supports goshawk’s need 

for denser more closed-canopy forest, not openings. 
Appendix F Response to Public Comment

Page 26 of 45

Response: Neither alternative proposes thinning in nest stands; thinning within the PFAs is 

consistent with Forest Plan direction. The EIS discloses the trade-offs involved with opening up the 

canopy by thinning in order to keep the larger trees growing. 

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Comment: Alternate nest stands should be left intact due to the possibility of losing core active nest 

stands to disturbance-natural or human. PFAs should be left alone due to extensive planning logging all 

around them. Goshawk are very sensitive to disturbance and changed conditions. 

Response: The issue is reflected in Alternative 2, where the alternate nest stands are not treated. The 

PFAs are also left untreated under the No Action alternative.

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Comment: “Short term” impacts can mean the extirpation of an at-risk species, especially in the absence 

of adequate population viability studies re: reproduction success, viability thresholds, etc. 

Comment: re DEIS p. 199- This is an illusory trade-off as the long term benefits promised are moot if 

there are no goshawks left there by then to benefit. Significant cumulative impacts should advise against 

planned logging of goshawk, PFAs and historic nest stands. Don’t put in OHV trails adjacent to or 

through PFA or nest stands!

Response: The analysis did not determine that any species would be extirpated. The location of 

OHV trails under the Lava Rock proposal took into account the existing goshawk nest sites. The 

recreation use in the area and other nearby vegetation management projects are considered in the 

cumulative effects of human disturbance to goshawk. 

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Comment: re: DEIS p. 203, at what point do impacts render territories too small to be useable? What is 

the projected viability of the Cooper’s hawk in the project area and on the District based on what 

population studies? How would up-listing be prevented?

Response: The FEIS includes information on the habitat available on the Deschutes National Forest 

and in the Ogden project area. Potential habitat would be treated under both action alternatives, 

primarily within ponderosa pine forest. Cumulative effects to Cooper’s hawk are more concentrated 

in the Ogden project area than in the rest of the watersheds due to recreation and other activities, but 

impact only 1% of suitable habitat on the Forest. Continued viability of Cooper’s hawk on the Forest 

is expected.

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Comment: What is “Natureserve” and on what credentials do its conclusions rest?

Response: Natureserve is a non-profit conservation organization whose mission is to provide the 

scientific basis for effective conservation action. Information is provided at: www.natureserve.org.

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Comment: Why is there a neutral effect to big game and not a negative effect – it makes no sense based 

on the effects discussion. 

Response: The cumulative effects analysis has been updated in the FEIS. Under the cumulative 

effects analysis, reasonably foreseeable road closures will only minimally benefit big game because 

of recreational and other uses that decrease effectiveness of a reduced open road system. 

Cumulatively, the action alternatives with the other ongoing uses of the area will decrease acres of 

refugia or areas of habitat without disturbance. There may be a shift in use patterns for big game but 

the effect on population trends on the Forest is likely to be neutral. FEIS p. 259.

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Appendix F Response to Public Comments

 Page 27 of 45

Comment: Impacting 23% of marten habitat is too high for a vulnerable species. Drop all units that 

overlap habitat. Don’t remove “excess” LP logs – standards and guidelines do not replicate the higher # 

of snags and down logs found naturally in local Wilderness and Roadless Areas used by martens.

Response: Additional mitigation has been added to the action alternatives for marten habitat. The ID 

Team reviewed units that overlap high quality marten habitat. Where those units are not high priority 

for fuels reduction (e.g. not on a major travel corridor), the removal of down logs is dropped from the 

unit treatment (see Resource Protection Measure #66). Additionally, slash piles will be retained in 

units that require piling at a level of one per acre. The action alternatives do not include any of the 

habitat type that most likely provides the high down wood density and large snag habitat utilized by 

marten (montane mixed conifer). The overall impact to marten habitat is about 1% at the Forest level. 

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Comment: Drop logging in late seral lodgepole and better protect northern three-toed woodpeckers 

(DEIS p. 233) and roadless/wild character.

Response: The bulk of three-toed woodpecker habitat is found within the Newberry National 

Volcanic Monument. For the lodgepole pine component, Alternative 2 removes 254 acres while 

Alternative 3 removes just 2 acres. Also each alternative would alter about 1,000 acres and develop 

385 acres of habitat. Implementing forest health and fuels reduction objectives of the Ogden project 

area contribute to cumulative effects to three-toed woodpecker habitat; however, the project is 

consistent with the Forest Plan and continued viability on the Forest is expected. 

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Comment: Drop brown creeper habitat units that overlap goshawk habitat (909, 966, 913). Drop all 

seed tree cutting except heavily mistletoe-infected lodgepole in both alternatives to better assist northern 

three-toed woodpecker and other species.

Response: Units 909, 966, and 913 overlap a goshawk PFA and are specific to Alternative 3; 

Alternative 2 does not treat these units. Under Alternative 3, seed tree harvest is dropped.

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Comment: We are also concerned by the Ogden alternatives’ failure to follow the Conservation Strategy 

for hermit thrush (DEIS p. 227) and there are Williamson’s sapsucker in the project area so more care 

should be taken to reduce snag loss and preserve more mixed conifer habitat, in part by dropping units 

for hermit thrush and brown creeper.

Response: Habitat for the hermit thrush is limited in the Ogden project area because of the lack of 

high canopy closure coupled with large trees. The action alternatives 2 and 3 treat about 357 and 389 

acres of hermit thrush habitat respectively with the objective of density reduction. Alternative 1 treats 

zero acres. The conservation strategies for hermit thrush address loss of habitat from fire, grazing, 

and winter recreation, and is to retain tracts of forest as unmanaged or lightly managed to ensure 

structural diversity. The FEIS points out that much of the suitable habitat is within the Newberry 

Crater, and management of that area represents the conservation strategy to retain tracts of 

unmanaged or lightly managed forest. 

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Comment: The DEIS fails to mention that canopy closure would no longer be sufficient for pileated after 

logging. 

Response: The FEIS states that habitat for this species is naturally limited in the Ogden project area 

because of a lack of mixed conifer (fir and pine) stands and a lack of large trees and snags (p. 337). 

The action alternatives treat about 1 to 2 acres of currently mapped pileated habitat. Thinning in the 

ponderosa pine will make stands more open and will make trees more resilient and able to grow 

larger. The FEIS points out that although the desired larger tree structure may develop over time, the 
Appendix F Response to Public Comment

Page 28 of 45

resulting habitat may not be of the highest quality because the pileateds prefer a higher canopy 

closures.

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SNAGS and DOWN WOOD

Comment: DEIS page 216 indicates that the LRMP standards & guidelines for down wood are lower 

than the levels required by marten. The FS should design the project to retain more down wood, more 

green recruitment trees, and tolerate more mortality processes to ensure that marten habitat is recruited 

and maintained to meet the needs of this Management indicator species.

The dead wood appendix does not provide assurances that dead wood habitat needs will be met. The 

DEIS seems to imply that if snags and green trees to meet the 100% potential population level are 

provided immediately after logging then the intent of the LRMP is met. This is not the case. Snags and 

dead wood must be provided over time (“throughout the rotation”). This means that lots more green trees 

need to be retained, especially in regeneration harvest units in order to assure that after the first few 

snags fall down, there are green tree available for snag recruitment over time.

Response: The FEIS shows the relative range of snag and down wood used by marten. A Forestwide assessment of the habitat present on the Deschutes National Forest has been completed since the 

Draft EIS was released. The information from that assessment is used in the Final EIS. 

Snag recruitment over time is shown in Figures 61, 62 and 63. Over time, with the no action 

alternative, density of snags between 15 and 20” dbh falls while there is little change in the amount of 

large diameter snags being recruited. Under the action alternatives, a steady supply of snags are 

recruited throughout the years, at about the 50% tolerance level for white-headed woodpecker. 

Because over time there would be more snags over 20” dbh, there would be more nesting habitat 

available to white-headed woodpeckers. 

The majority of the project area will see increased health and vigor through thinning. Insect activity 

should be reduced in thinned stands. This does not eliminate mortality in these stands. Additionally, 

the 36% of the project area that would remain at high density levels will likely experience densityrelated mortality.

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Also, the potential population method is outdated and more snags need to be recruited in order to meet 

the needs of wildlife associated with dead wood. Recruitment of more snags requires retention of more 

green trees. The FS should not rely on outdated standards. See Rose, C.L., Marcot, B.G., Mellen, T.K., 

Ohmann, J.L., Waddell, K.L., Lindely, D.L., and B. Schrieber. 2001. Decaying Wood in Pacific Northwest 

Forests: Concepts and Tools for Habitat Management, Chapter 24 in Wildlife-Habitat Relationships in 

Oregon and Washington (Johnson, D. H. and T. A. O’Neil. OSU Press. 2001) 

http://web.archive.org/web/20060708035905/http://www.nwhi.org/inc/data/GISdata/docs/chapter24.pdf

The NEPA analysis of dead wood never really discloses the effect of removing trees from 12,000 acres in 

terms of future recruitment of snags and dead wood. Logging captures mortality and significantly reduces 

and delays recruitment of snags. This is why untreated skips are important, but the NEPA analysis never 

discloses why the selected mix of treated and untreated stands will result in adequate landscape level 

recruitment of snags and dead wood.

Response: Mortality will still occur in the project area, just not at a widespread scale. One aspect of 

the purpose and need is to create a more resilient landscape so that widespread mortality does not 

occur. The size of snags matters. As trees are allowed to grow and larger trees are maintained, there 

is potential for larger snags in the future. As stated in the referenced document, the FEIS 

acknowledges that the potential population method is a flawed technique (FEIS p. 340); effects to 

species dependent on snags and deadwood are based on the best science available from the DecAID 

tool. 
Appendix F Response to Public Comments

 Page 29 of 45

As discussed in the HRV analysis, certain structural stages are far above the HRV. Treating within 

these stands has the potential to move some structural stages in the area towards the HRV, but the 

amount of treatment in the Ogden project area (about 54% of stands in project area are treated in 

some way) will not move any structural stages away from the HRV.

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Comment: The Draft EIS assumes also that numerous snags will need to be felled for public safety in 

recreation areas, as well as for fire fighter safety during underburn activities. Because of the importance 

of retaining well developed snags in the project area, we recommended stricter guidelines that require 

clearer retention of snags in the project area in order to limit the felling of snags to only those that pose 

an imminent public safety threat.

Response: Falling of snags is limited to those that pose an imminent safety threat. Guidelines are 

based on OSHA requirements. All other existing snags are retained.

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Comment: We urge the FS to find an optimal mix of treated and untreated areas across the landscape 

and within each treatment unit to ensure adequate habitat for species that prefer dense forests (goshawk, 

marten, pileated woodpecker, etc), and to meet the needs of species that rely on moderate to abundant 

levels of snags and dead wood (e.g. woodpeckers and many others). This is especially important when 

landscape level treatments are proposed.

Response: Each alternative has a mix of treated and untreated areas that were determined through 

project planning and the consideration of wildlife needs, current stand conditions relative to HRV, 

fuels reduction strategies, and management area goals and objectives. The No Action leaves 100% of 

the area untreated.

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Table 58 shows that the current level of snags is tilted toward the lowest tolerance level (30%). Past management, 

including all forms of logging, fire suppression, and hazard tree removal have resulted in a significant regional 

deficit of large dead wood habitat. Future management should be designed to enhance snag habitat (both size and 

number, not just size). The DEIS (pp 245-254) analysis of snags, dead wood, and GTR is inadequate. There is no 

quantitative description of the effects of the action and no action alternatives on snag recruitment over time. 

Capturing and diverting mortality out of the ecosystem is one of the more profound effects of commercial logging 

and must be clearly disclosed. See Heiken, D. 2010. Dead Wood Response to Thinning: Some Examples from 

Modeling Work. http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf. We urge the FS to retain all snags and 

enough green trees to recruit optimal numbers of snags and down wood to meet the needs of wildlife over the shortand long-term (e.g. DecAID 50-80% tolerance levels). Figures 51, 52, and 53 are confusing and inconsistent with 

other quantitative analyses of snag recruitment. How can the alternative with the most retained trees (Alt 1) result 

in the fewest snags recruited? It is very unclear how the action alternatives that send 5,800 log trucks loads of logs

off-site can recruit a greater number of snags over time. The DEIS failed to show the analytic methods that 

produced Figures 51-53. It is also unclear why these figures show the effects to snags >15 dbh when the relevant 

biological criteria cited in the DEIS for white-headed woodpeckers refers to snags >10” dbh. It appears that the 

effects of logging with respect to recruitment of snags 10-15” are quite relevant to focal wildlife but are not 

disclosed in the DEIS. The analysis of effects to black-backed woodpeckers and three-toed woodpeckers failed to 

show similar snag recruitment data for small snags which are preferred by these species and will probably be 

provided in greater abundance by the no action alternative, or in untreated areas. We urge the FS to consider an 

optimized blend of treated and untreated areas to recruit for both snag size (in thinned areas) and snag abundance 

(in untreated areas).

Response: The referenced figures are now Figures 61, 62, and 63 in the FEIS. The FEIS points out that 

the graphs do not model mortality from bark beetle attack, but the action alternatives do reflect mortality 

that may be expected from prescribed underburning. The important point made with the graphs is that 

tree growth with the action alternatives leads to more large trees in the stands that through natural 

mortality become more large snags (> 20” dbh). The histograms in Appendix E of the FEIS also display 

The modeling shown in the referenced document from Heiken appear to be excerpts from west side forest 

projects with no indication of the factors included in the modeling. 
Appendix F Response to Public Comment

Page 30 of 45

In both action alternatives, all existing snags are retained except where they pose a safety hazard. Snags 

will continue to be created, even in areas that are thinned; and close to one half of the project area is left 

untreated in either action alternative. The effects to wildlife species that use snag habitat shows that for 

some species a pulse of small snags would be beneficial in the short term, but for other species the 

development of larger trees that will in the future become large snags is more important. For some 

wildlife species, the development of large trees with open park-like structure is the most important habitat 

component; for example, pygmy nuthatch are a focal species for large trees in ponderosa pine. Both 

action alternatives will continue stands on a trajectory for that kind of habitat which is lacking on the 

landscape; thus treatments will also move the area towards the historic range of variability and create 

more resilience to disturbance. 

SOILS

Comment: The DEIS acknowledges on page 281 that ‘units with high existing detrimental conditions 

may temporarily exceed the 20% LRMP standard following harvest, skidding and fuels related activities 

and would need restoration treatment (subsoiling) of impacts from previous entries in order to meet 

LRMP standards for maintaining soil productivity.’ How many acres would be affected by this? How long 

is ‘temporary,’ and how will the Forest Service ensure that post-logging restoration treatment occurs 

within one year of logging activities and is fully funded?

Response: The EIS estimates that impacts from previous entries within units 12, 14, 16, 20, 21, 23, 

32, 33, 35, 36, 39, 47, 50, 53, 56, 59, 67, 70 may require subsoiling following harvest and fuels 

treatment activities in order to meet LRMP standards for maintaining soil productivity. Previously 

impacted areas used as landings and primary skid trails under this entry would be designated for 

subsoiling restoration in these units. This activity would alleviate detrimental soil compaction on 5 to 

15% of the unit areas, or up to 101 acres under Alternative 3. Money for the restoration subsoiling 

would be prioritized for these unit acres as essential Knutson/Vandenberg (KV) funds generated from 

the timber sold within the Ogden planning area. The amount of time elapsed between the closure of the 

sale and the subsoiling restoration activity is generally between one and two years.

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Comment: The DEIS also only ‘recommends’ that winter logging on frozen ground occur to limit 

damage to soils, and that moist season and dry season or logging on non-frozen ground be avoided. We 

would suggest making these recommendations requirements in order to minimize risk of soil damage 

where mechanical entry occurs.

Response: The DEIS acknowledges that winter logging on frozen ground can reduce detrimental 

damage to soils (DEIS, p. 279). Units with elevated existing levels of detrimental soil damage have 

been prioritized for implementation under winter logging conditions should they occur during the 

contract period (FEIS, p. 43). However, winter logging conditions are variable in the Ogden planning 

area and are not guaranteed to occur within the length of a sale contract or for contiguous periods of 

time to be effective. As a result, winter logging is only recommended in the FEIS as an option to limit 

damage to the soil resource if it becomes available during the length of the sale contract. The FEIS also 

recommends that operations should be avoided during extremely moist conditions or on slopes 

exceeding 20% during extremely dry soil conditions to minimize the risk of excessive soil damage 

(FEIS, p. 43).

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Comment: We suggest that the Forest Service consider requiring alternative machinery for log removal 

that will be lighter on the land than mechanical tracked harvesters and ground-based yarding equipment. 

No discussion of alternative logging technologies and their potential for reduced impact on soils is 

discussed.

Response: The FEIS mentions the use of harvester/forwarder equipment as an alternative groundbased option for log removal (FEIS p. 366). In general, cut to length harvester/forwarder systems are 

available for use, are effective in the stand types being treated in the Ogden planning area and can 
Appendix F Response to Public Comments

 Page 31 of 45

generally reduce the total impacts to the soil resource. However, these systems are generally more 

expensive and the DEIS analyzes for the greatest amount of direct effects to the soil resource under a 

scenario using mechanical tracked harvesters and ground-based yarding equipment (DEIS, p. 269). 

General contracts let by the government to solicit harvest activities can specify objectives and end 

products for work in order to protect resources but do not specify the equipment to be used to complete 

the contract. A listing of high priority units recommended for full suspension yarding has been added 

to the Resource Protection Measure #38 (EIS, p. 43). 

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Comment: Drop units that require restoration by subsoiling (Units 12, 14, 16, 20, 21, 23, 32, 33, 35, 36, 

39, 47, 50, 53, 56, 59, 67, 70) that potentially are not meeting LRMP standards for soil productivity. 

Mitigation is not always effective and subsoiling creates impacts of its own to soils – e.g. mixing soil 

layers, bringing rocks to the surface, displacing shallow topsoils. Also, mitigations is not guaranteed to 

be funded or to happen. 

Response: Units with a high probability of needing restoration subsoiling to meet LRMP standards 

for soil productivity (Units 12, 14, 16, 20, 21, 23, 32, 33, 35, 36, 39, 47, 50, 53, 56, 59, 67, 70) have 

been prioritized for implementation under winter logging conditions, should they occur, to reduce the 

cumulative amount of detrimental soil damage incurred by the proposed activities. However, 

subsoiling restoration may still be necessary in these and other units to reduce the overall levels of 

detrimental soil compaction within an individual activity area. Although the shallow top soil is 

generally mixed or displaced after the use of skid trails and landings, subsoiling effectively reduces 

elevated detrimental compaction levels on these areas to or below natural levels capable of supporting 

vegetative growth and harboring microbiotic organisms. Subsoiling in similar soil types on the 

Deschutes National Forest has been effective in returning the infiltration and water holding capacity 

of the soil resource to levels capable of supporting vegetation and micro fauna integral to the 

maintenance of soil productivity on these sites. See earlier response to comment for the timing and 

KV funding priorities associated with subsoiling restoration activities.

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Comment: Ground-based logging associated with this project will add significantly and cumulatively to 

existing adverse soil impacts. This is another reason to seek and find the right mix of treated areas (where 

soil will be cumulatively impacted) and untreated areas (where soil will not be additionally impacted) 

across the landscape and within each treated stand. A lot of units will be right at the 20% threshold for 

detrimental soil compaction, but unfortunately the FS methods for measuring DSC is biased and ignores 

many detrimental soil impacts that are arbitrarily dismissed as de minimums.

Response: The DEIS discloses that ground-based logging will directly affect the soil resource and 

cumulatively affect existing levels of adverse soil impacts within proposed activity units (DEIS, pp. 

271-273; 280). However, these effects will be within threshold levels defined by LRMP standards and 

guidelines for maintaining soil productivity following all harvest, fuels and restoration activities 

(DEIS, pp. 275, 276, 280). The spatial extent of these impacts would be distributed across the 

planning area as a result of project design, under which approximately 48% if the Ogden planning 

area is not proposed for ground-based harvest treatments and would receive no additional impacts. 

The spatial extent of impacts within individual activity areas would also be minimized as a result of 

designated skid trail spacing and restricted machine travel (DEIS, pp. 39-41). 

Detrimental impacts associated with ground based harvesting are generally localized and variable as 

to their effects on soil productivity and watershed health. The LRMP standard that limits allowable

detrimental soil impacts to less than 20% of an activity area is recognized as a threshold that 

maintains long term site productivity and is logistically implementable. However, cumulative totals of 

detrimental compaction and displacement at or just above 20% of a harvest unit do not unravel the 

productivity of the soil resource. This is supported by findings from Long Term Site Productivity 

(LTSP) research plots across the National Forest land systems, including plots located on the 
Appendix F Response to Public Comment

Page 32 of 45

Deschutes National Forest, in which the long term effects to site productivity associated with 

detrimental impacts to the soil resource were studied. In addition, vegetative growth and the 

productivity of sites on the Deschutes National Forest that received heavy impacts from ground-based 

clearcut harvesting and machine piling during the 1950s through the 1980s show that the productivity 

of Mazama ash soils like those located in the Ogden project area is somewhat resilient to impacts 

from compaction and displacement, even when these levels exceed 30% or greater.

HYDROLOGY/WATER QUALITY – PAULINA CREEK

Comment: Sedimentation and water quality impairment of Paulina Creek is foreseeable since logging 

would occur on steep slopes and ashy, unstable soils over and next to the creek. 

Comment: What about sedimentation and possible increase in stream temperature, which already 

exceeds standards. Effects analysis are largely unsupported. Science not disclosed predicts increases in 

sedimentation with similar activities within 100-150 feet of the stream.

Response: The project is designed so that machinery would not be within 75-100 feet of the creek, 

and further when the slope is moderately steep to steep (FEIS p. 393), although there is a 

predominance of gentle slopes (FEIS p. 394, Table 156). In addition, Resource Protection Measure 

#9 would add another 25 foot buffer beyond the Peter Skene Ogden Trail, resulting in a machinery 

setback of approximately 100-125 feet in these areas. The trail is located throughout all the RHCA 

units on one side of the creek or the other. Under Alternative 2 only 4.5 acres within RHCA units 

planned for commercial thinning exceed 30% slope and only 1 acre under Alternative 3 (FEIS Table 

156, p. 394; Figures 87, 88). Machinery would be excluded from areas over 30% slope within RHCA 

units. Hand thinned areas would comprise 14 RHCA acres over 30% slope under Alternative 2 and 5 

acres under Alternative 3. Thinning and underburning would reduce fuels and accelerate LOS 

structure in ponderosa pine, which will eventually benefit the stream by increasing large woody 

material and shade. The potential of stand replacing wildfire within the RHCA would be reduced. 

Soils within RHCAs have high permeability and low to moderate sedimentation yield potential, 

limiting overland flow of sediments (FEIS p. 386). 

The alternatives include setbacks for thinning to maintain shade in accordance with direction of the 

USFS/BLM Northwest Forest Plan Temperature TMDL Implementation Strategies (FEIS p. 398). 

Literature is cited relative to potential effects of sedimentation from commercial thinning activities 

(FEIS p. 393) and underburning (FEIS p. 397). 

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Comment: Paulina Creek is water quality limited due to water temperatures exceeding the state 

standard for fish, so we feel it would further impair Paulina Creek water quality and fish viability by 

reducing stream shading through logging. We field-checked all along Paulina Creek and found no excess 

density of trees within the stream-shading riparian zone. Fire risk could be adequately reduced through 

thinning only up to 6-8” dbh by hand outside the riparian zone and only above the PSO trail, not next to 

the creek.

Comment: It’s not ethical or legal to further impair stream temperatures on a water-quality limited 

creek due to water temperature. We field checked all along Paulina Creek and found no excess density 

within the shade zone affecting the creek.

Comment: Paulina Creek is listed as water quality limited due to water temperatures exceeding state 

standards for fish, and we feel that further thinning along the riparian corridor will only serve to reduce 

water quality and shading. We believe there are not any density issues within the riparian areas and the 

fire risk can be reduced by thinning only trees up to 6 – 8 inches by hand outside the riparian zone.

Response: The existing water temperature is the result of warm surface water released from Paulina 

Lake (FEIS p. 389). The units that fall within the Riparian Habitat Conservation Area (RHCA) of 

Paulina Creek are above the upper management zone (UMZ), so stand density is a concern within 300 
Appendix F Response to Public Comments

 Page 33 of 45

feet of the creek. The action alternatives include setbacks for thinning to maintain shade in 

accordance with direction of the USFS/BLM Northwest Forest Plan Temperature TMDL 

Implementation Strategy (FEIS p. 393). The zone closest to the stream is not treated, the next zone is 

thinned by hand up to 10” dbh (see FEIS Figure 8). Riparian vegetation along Paulina Creek is 

typically very narrow (< 10 feet and often 3-4 feet) (Figure 80). No thinning would occur within 

riparian vegetation. No further impairment will occur as a result of either action alternative (FEIS pp. 

397-398).

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Comment: We feel strongly that logging commercial size trees (8” DBH and greater) in the Wild and 

Scenic corridor of Paulina Creek and in the OGMA would violate existing Deschutes Forest Plan 

guidelines for scenic views and old growth management and violate INFISH.

Response: Paulina Creek has not been included in the National Wild and Scenic Rivers System, but 

remains eligible. The effects to the INFISH Riparian Management Objectives are found on FEIS p. 

402. The action alternatives are consistent with INFISH standards and guidelines by applying 

silvicultural treatments to maintain shade in the short term and increase shade in the long term to have 

benefits to water temperature. Maintenance and enhancement of LOS in RHCAs would enhance 

large instream wood recruitment in the long term. Enhancement of LOS would facilitate the 

recruitment of these larger pieces of wood. Fuels treatments are consistent with INFISH by applying 

protection measures to not prevent attainment of RMOs. The project is not expected to impact the 

eligible wild and scenic status of Paulina Creek (FEIS pp. 403-404). The outstandingly remarkable 

values of hydrological/geologic and scenery are not negatively affected by either action alternative, as 

they occur upstream of the project area. The discussion of the OGMA shows that Alternative 2 

would largely benefit the sustainability of the stands within the OGMA, Alternative 3 treats fewer 

acres but avoids temporary road construction. Neither alternative violates Forest Plan standards and 

guidelines for OGMAs.

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Comment: As noted on p. 10 of DEIS, INFISH applies not only to the Paulina Creek RHCA, but to areas 

outside the RHCA that could degrade it. This would include the areas within the wild and scenic 

corridor, which includes steep slopes proposed for logging over the creek – e.g. but not exclusive to units 

110, 111, 112, 40, 131, 113, etc. Logging could impair water quality.

Response: RHCA widths of 300 feet slope distance apply to Paulina Creek. RHCAs would not be 

degraded from management activities occurring outside their boundaries as project design features 

limit effects to resources, including soils. Soil disturbance from commercial thinning and fuels 

reduction treatments in areas outside the RHCA would be limited by soil resource protection 

measures (FEIS pp. 367-371). Slopes within the RHCAs are primarily gentle and soils permeable, 

reducing potential for overland flow of water and sediment (FEIS pp. 391-397). Mechanized 

equipment is not allowed on slopes greater than 30% within the RHCAs. A machinery boundary of 

75-125 feet (including trail setback) from Paulina Creek would protect water quality.

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Comment: It’s highly questionable whether these inadequate buffers would be enough to protect Paulina 

Creek water quality, riparian ecological integrity, hydrologic flows, or recreational aesthetics – we think 

they won’t. Science supports buffers of more than 100’ to avoid sedimentation of streams.

Response: Literature is cited relative to potential effects of sedimentation from commercial 

thinning activities and underburning. Lakel and others (2010) concluded that stream buffers as little 

as 25 feet were effective in limiting sedimentation after timber harvest. A buffer of 75-100 feet or 

more excluding machinery has been included under both action alternatives and greater where 

adjacent to the Peter Skene Ogden Trail (100-125 feet) because of resource protection measure #9. 

One study found that chronic sediment delivery occurred where streams were crossed by timber 

yarding practices (which would not occur under the Ogden alternatives). There is a predominance of 
Appendix F Response to Public Comment

Page 34 of 45

gentle slopes and highly permeable soils within RHCAs. Thinning and piling activities will not occur 

within riparian vegetation. The effects on streamflow are discussed on FEIS pp. 385-386. 

Hydrologic flow (streamflow) is largely affected by irrigation demands (pp. 384-385).

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Comment: What would happen to Paulina Creek’s status as a Wild and Scenic River?

Comment: Timber harvest within a 1⁄4 mile of either bank of Paulina Creek is generally not permitted as 

this area is managed in accordance with MA 17; the intent is “to limit man-caused vegetation changes 

such that they mimic ecological changes.” ...Temporary road construction in this area will violate the 

Deschutes LRMP.

Response: Paulina Creek is eligible for consideration as a Wild and Scenic River. Its suitability has 

not been determined yet, and until that is done the corridor is managed to protect the outstandingly 

remarkable values that make it eligible (LRMP 4-17). Temporary road construction is not prohibited 

within the corridor (Table 4-12 of the Forest Plan lists Paulina Creek as a Recreation River; therefore 

M17-5 standards apply). Where actions are proposed within the corridor of Paulina Creek, they will 

not have any negative impacts to the outstandingly remarkable values and will not affect the creek’s 

eligibility for consideration as a Wild and Scenic River (FEIS pp. 403-404). 

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Comment: Vegetation and fuels treatments are a huge impact to the Wild and Scenic River corridor. 

How would it not impair designation? Cumulative effects discussion is inadequate.

Response: The Outstandingly Remarkable Values (ORVs) that made Paulina Creek eligible for 

inclusion in the Wild and Scenic River system are Hydrological/Geological and Scenic, but these 

ORVs only occur within the first 0.5 mile below Paulina Lake, outside of the Ogden Project area 

(FEIS p. 403). Paulina Creek is classified as a Recreational River where harvest of trees is to be 

oriented toward enhancement of scenic, hydrologic, fisheries, recreational, and/or wildlife values. 

Over the long term the appearance of the river corridor should remain near natural with the impacts of 

project activities apparent but subordinate to the natural character of the landscape. The EIS states 

that over the long term (10-20 years) visual impacts of management will be less noticeable and more 

open views to the creek and larger highlighted trees will enhance the scenic value. The action 

alternatives would maintain and promote the development of large trees, including within the eligible 

Wild and Scenic corridor.

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SCENIC QUALITY / FOREST PLAN AMENDMENTS

Comment: The Forest Service is planning to use two amendments to existing Forest Plan standards and 

guidelines to allow them to create visible negative effects from logging and fuel reduction that would last 

for about five years and allow for burning areas larger than the less than 5 acres allowed within scenic 

view areas. Management of the Forest through Forest plan amendments defeats the purpose of the 

Forest Plan.

Response: By reducing stand density and fuels and allowing for more time and larger areas to be 

treated, the scenic views to those treated areas within the larger landscape would be improved over 

time. Reintroducing fire in these larger areas will provide long-term protection and resiliency to 

ponderosa pine that are large and have old-growth characteristics. The standards and guidelines for 

Scenic Views management areas and Forest Plan goals will be met by maintaining the natural 

character of the landscape and as the short-term impacts eventually become less visible over time. 

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Appendix F Response to Public Comments

 Page 35 of 45

Comment: The effects of the Forest Plan Amendments will not be “short term” as claimed. What are the 

long-term benefits?

Most of the public does not want artificially created scenic views of distant peaks, etc.

Most people do not appreciate the visual impacts of logging to achieve the objectives described on p.312 

(highlight large ponderosa pine by removing lodgepole pine and provide more open views of the Forest 

and larger ponderosa pine trees in units 176, 177, 199, 201).

Response: Forest Plan amendments are required because the effects to scenic views in foreground

areas will be noticeable for more than a short-term period of time (0-5 years). The long-term benefits 

would be more visibility and open views highlighting large ponderosa pine with old-growth 

characteristics. The openings created are not necessarily to scenic views of distant peaks but more 

open views through the forest that highlight large ponderosa pine and other species. One of the 

primary objectives in the Forest Plan is to highlight large ponderosa pine (LRMP 4-122). 

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Comment: Forest Plan objectives for scenic views could be met with non-commercial thinning to reduce 

fire/insect risk. The DEIS does not analyze non-commercial thinning and sporadic (< 5 acre) burning.

The public doesn’t like mortality and extensive burning; restoration should be done gradually and 

incrementally, not all at once, as shock treatment.

Response: Small-scale treatments may work for short-term scenic view enhancements but may be 

ineffective for larger landscapes over a longer period of time. Treating a larger landscape area allows 

for more success in allowing negative visual elements from proposed activities to be rehabilitated 

immediately and to recover and be restored over time. 

Comment: It’s unnecessary to use so much prescribed fire [in Scenic Views Corridor] at once to achieve 

the [fuels] objectives. Small tree thinning could also be interspersed to achieve the same results.

Response: The approach taken by this project is to treat fuels and allow harvest cleanup to occur as 

soon as possible and to allow visible impacts (blackened, scorched vegetation and tree trunks) 

especially along travel corridors to subside and become less visible within a 5 year window of time.

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Comment: Section 3.9 Scenic Resource: No key viewpoints have been identified or analyzed in the

DEIS as we thought was generally required, especially for such landscape altering projects.

Response: This project will not create any large openings that could alter the scenic views of the 

area, either foreground or distant. Key viewpoints are often required for introduction of elements (i.e. 

smoke plumes or drilling equipment) that would be visible above the tree canopy.

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Comment: Most would agree that the outstanding scenic values of Paulina Creek extend well below 

Paulina Creek Falls and the Monument.

Response: The treatments occurring along the banks of Paulina Creek below Paulina Creek Falls and 

the Monument would not negatively impact scenic views because of the Riparian Habitat 

conservation Area project design features that designate protection zones within this area. No 

landings or temporary roads will be located here and care is taken to maintain as natural appearance 

as possible through hand piling, hand thinning, and a setback for machinery which goes to the outer 

limit of the RHCA, which is 300 feet slope distance from the stream. 

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FOREST PLAN
Appendix F Response to Public Comment

Page 36 of 45

Comment: ... AFRC is concerned that the project does not faithfully follow the General Forest 

management direction of the Forest Plan and an old forest objective is being superimposed on the

General Forest acres.

Response: In understanding the goal of General Forest (MA-7), the emphasis is timber 

production. The goal is to also provide for forage production, visual quality, wildlife habitat 

and recreational opportunities for public use and enjoyment (LRMP, page 4-117). The project 

will remove fiber for economics and thin for future opportunities. Thinning will also take into 

account the intrinsic values of wildlife, recreation, fisheries, and visual quality. This does allow 

for an increase in larger diameter trees that are not present across the landscape to move 

towards the historical range of variability (HRV) which is consistent with direction in the 

Eastside Screens. The Eastside Screens is an amendment to the Forest Plan and so essentially 

is superimposed on the General Forest management area. 

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CUMULATIVE EFFECTS

Comment: Throughout the Draft EIS, the Forest Service cites the cumulative effects of the neighboring 

Lava Cast project and others. However, it is not clear that the Forest Service has done a significant 

analysis of the impacts of Lava Cast post-logging to assess whether there were any ‘lessons learned’ that 

could be used to shape the Ogden project. Typically, Lava Cast is spoken of positively in the DEIS in the 

sense that the completion of Ogden will build on the work completed at Lava Cast. However, in field 

tours of Lava Cast post-logging conducted by the Sierra Club, we found significant harm to soils from 

ground based logging and mechanical entry, excessively large slash piles and drier forest conditions that 

contribute to increased fire risk, and the removal of fire resistant trees. We believe that some of these 

impacts will be visible to the casual observer for longer than five years. Despite adopting a number of 

protective provisions in the Lava Cast decision, including a maximum cutting limit of 18” in most all 

units, and 16” in others, and dropping some mixed conifer units for wildlife, Lava Cast logging resulted 

in considerable environmental harm. However, the discussion of ‘residual effects’ of Lava Cast in the 

Ogden DEIS is summed up in to two sentences (Table 12, pg 56) with little supporting analysis provided.

Response: The information in Table 12 of the FEIS includes a brief summary of the Lava Cast 

project to be considered for the Ogden cumulative effects analysis. Although impacts to the soil 

resource were observed from the Lava Cast project, the Forest does not agree that it resulted in 

“significant harm to soils.” The Forest conducted monitoring in three timber sales during the summer 

of 2010 as a means for evaluating the implementation and effectiveness of the soil protection 

measures prescribed in the Lava Cast EA (Deschutes National Forest 2010). In all cases, soil 

protection measures were observed to have minimized detrimental soil disturbance and helped 

maintain site productivity at acceptable levels within the Lava Cast timber sales. While observed 

levels of visual soil disturbance in monitored units ranged from 34 to 54 percent of the unit area, the 

amount of detrimental disturbance attributable to changes in soil strength or displacement ranged 

from 7 to 19 percent of the unit area. Monitoring of changes in soil strength and pore size distribution 

in similar ash soils on the Forest has shown that not all visible areas of compaction or displacement 

from mechanical logging operations result in physical conditions that are detrimental to site 

productivity. As a result, the Forest has maintained the use of similar soil protection measures under 

the Ogden project. 

The Forest also does not agree reductions in stand density associated with the Lava Cast timber sales 

have resulted in “considerable environmental harm.” In 2010, an independent review of post-harvest 

conditions (stocking levels in particular) was conducted within a sampling of units from the Dice 

Timber Sale (Stone 2010). Following the Dice Timber Sale, a member of the public expressed a 

concern that more trees were removed than were analyzed for, leaving areas with insufficient trees to 

meet long-term objectives. The review found that average basal area of all sample units met the 
Appendix F Response to Public Comments

 Page 37 of 45

target basal area, however some individual units fell above and some fell below. Additionally, within 

some units, the size and extent of openings were exceeded. In these cases it was found that 1) large 

patches of lodgepole pine or white fir had been present and the thinning treatment called for removal 

of those species, or 2) large patches of ponderosa pine had been killed by bark beetles. Even with 

these findings, the independent review concluded the intent of the Lava Cast project, as defined in the 

associated EA and Decision Notice, has been met. The post-harvest condition, including the range of 

basal areas and the size and extent of created openings, was considered to provide desired conditions 

described in the Lava Cast EA. Post-harvest conditions were considered suitable for promoting the 

desired growth of large ponderosa pine and providing desired conditions including gaps, dense 

patches, lightly thinned, moderately thinned, and heavily thinned patches in every stand. The postharvest basal areas and the size and extent of created openings were considered to have minimal 

impacts to the long-term vegetative conditions. 

Key Issue #2 described in Chapter 1 of the Ogden FEIS addresses thinning level and describes a 

concern similar to that raised following the harvest of the Dice Timber Sale. Alternative 3 was 

developed to respond to this issue, varying thinning treatment within some units with a mix of 

species. With this treatment, trees would be thinned to the lower management zone, regardless of 

species composition. This compares with Alternative 2 which also thins to the lower management 

zone but in contrast retains lodgepole pine and in some cases white fir if needed to stay at minimum 

stocking level. These alternatives allow for a comparison of the effects two thinning treatments have 

on various resources. Section 3.3.8 of the FEIS documents how the thinning treatments in 

combination with proposed underburning would affect stand density. 

---------------------------------------------------------------------------------------------------------------------

Comment: While some smaller diameter thinning may be reasonable, we worry about the cumulative 

sterilizing effect of opening such a large area of forest up so much all at once on top of the impacts of 

much past logging there. The perceived lack of optimum growth in trees may be due to soil compaction 

and loss of mycorrhizal fungi communities from past logging, indicating the need for time for the area to 

recover.

Response: Existing soil impacts were not observed to be a detriment to the productivity of 

vegetation on site and the cumulative impacts of past logging and proposed activities are expected to 

be within acceptable levels for maintaining soil productivity (see EIS Soils Effects Analysis section 

3.7). In general, the Ogden project proposes broader landscape scale treatments to increase the 

resilience of stands to insect and disease mechanisms and fire hazard (see EIS Purpose and Need). 

Vigor of trees is suppressed when the density is too high; thinning will improve vigor of the residual 

trees and will also maintain soil productivity.

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Comment: The cumulative impacts of the Ogden timber sale and geothermal well testing and drilling are 

of concern regarding a large-scale transformation of the character of the place, greatly increased human 

disturbance of wildlife, and overall reduced biodiversity due to the homogenization of the forest to a more 

uniformly open and unnaturally-altered state across a large area. 

Response: The Ogden project does not intend to homogenize the forest or make it uniformly open 

across a large area. Geothermal exploration activities have been addressed where there may be 

cumulative effects. 

-----------------------------------------------------------------------------------------------------------------------

Comment: What are the cumulative impacts of removing hazard trees, all the other planned actions, 

geothermal development, recreational wildlife disturbance, and other projects ongoing or planned?

Response: The cumulative effects are displayed for each resource in Chapter 3. The cumulative 

effects analysis is specific to each resource and the scale can vary (for example, the geothermal 

exploration activities do not have effects to Paulina Creek, so they are not discussed in the water 
Appendix F Response to Public Comment

Page 38 of 45

quality cumulative effects analysis). Where ongoing impacts and foreseeable future impacts overlap 

in time and space with the effects of the Ogden project, they have been analyzed and disclosed.

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ECONOMICS

Comment: As stated earlier the mill in Gilchrist is not operating at its capacity which is due in large 

part to the lack of adequate sawlogs offered for sale by the Forest Service in Central Oregon. With an 

additional, predictable, and sustainable level of harvest, Gilchrist could add jobs in an area that 

desperately needs them.

Response: The FEIS estimates that 174 jobs in the timber and wood product industry could be 

maintained or created from Alternative 2; 170 jobs from Alternative 3. This estimate is based on a 

coefficient in the Deschutes LRMP.

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Comment: Specific to the Ogden project, we want to see a project that meets the Purpose and Need for 

Action, provides for all the valuable resources, and does so in an economically viable manner. This 

would include silvicultural prescriptions that are easily understood, properly marked on the ground, and 

provides a level of output that would make for an economically viable project.

Response: Both action alternatives are designed to meet the purpose and need for the project. 

Treatment costs are outlined in Chapter 3.16. There are also costs involved with some of the project 

design intended to protect resources and the public, such as washing equipment prior to entry onto 

National Forest or marking sensitive areas to avoid. The economic analysis shows that both 

alternatives would produce financially feasible timber sales. Implementation planning will ensure that 

objectives in the Decision, such as the silvicultural prescriptions, are carried out on the ground.

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Comment: ..... today there is one mill remaining in Central Oregon and that’s Gilchrist. The Gilchrist 

mill is a pine mill that utilizes both ponderosa and lodgepole pine. The products we produce may vary by 

these two species but the jobs don’t. 

So unless there are other factors that drive the jobs figures, I would ask that you modify your coefficients 

to be the same regardless of the species harvested. This would lead to less confusion about the numbers 

and provide a more accurate representation of the local infrastructure. 

Response: The analysis in the FEIS has been updated to show job creation using the same coefficient 

for both tree species.

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Comment: The Forest Service has cited a need for timber and other wood fiber projects to support jobs 

and the local and regional economy. Yet the Forest Service has provided little evidence that such a need 

exists. Further, the Forest Service has failed to explain how the current timber and housing markets may 

affect the price they ultimately receive for the rights to log the Ogden project, and how this price may 

affect their ability to conduct post-logging fuel reduction and restoration activities.

Response: Comments on this project and other ongoing projects received from the local industry 

representatives demonstrate that there is a need for timber and other wood fiber products in central 

Oregon. The EIS provides a relative comparison of the action alternatives’ cost to government, 

revenue, and potential to maintain or create jobs. The EIS acknowledges that market conditions 

fluctuate and so the accuracy of estimates may change throughout the planning of the project. 

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Comment: It is our belief that even a modest restriction on the flow of raw lumber from private lands to 

Asia could more than meet the domestic need for timber cited in the Ogden DEIS. While the Forest 
Appendix F Response to Public Comments

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Service obviously has no control over export policy on private lands, we believe a more robust discussion 

of regional timber industry economics based on current data is warranted if one of the two primary 

purposes and needs of the project is to produce timber to support jobs. 

Response: The Deschutes LRMP recognizes the importance of the National Forest System lands as a 

supplier of wood products; and the majority of the Ogden project area is allocated to General Forest 

management where timber production is to be emphasized (FEIS pp. 5, 10). Timber from the Bend/Ft. 

Rock Ranger District has not been an export product (Fitzer, personal communication) and would 

typically go to sawmills or other processors in the area (such as at Gilchrist, LaPine, Prairie City, or 

John Day). The FEIS includes additional information on the timber outputs from Oregon and 

Deschutes County by landowner (Table 170). 

---------------------------------------------------------------------------------------------------------------------------------

Comment: The Forest Service contributes to the myth that jobs-per-million-board-feet is the only 

measure of job creation from forest projects. The University of Oregon’s Ecosystem Workforce Program 

has done extensive research on job creation from a variety of restoration activities beyond merely those 

associated with commercial harvest. A restoration focused project with far less of a commercial timber 

produced could also create substantial job opportunities locally, but the Forest Service appears to have 

not considered this in the Ogden DEIS.

Comment: We would suggest that the Forest Service provide a more detailed breakdown of the types of 

jobs it expects will be created by the project, including those related to non-commercial timber activities, 

and discuss the duration of those jobs (i.e. seasonal, multi-year, etc).

Response: The estimated timber industry jobs maintained or created by alternative in the FEIS 

includes logging, sawmills, and secondary processing. Other work that could be completed by contract 

includes small tree thinning, grapple or hand piling of fuels, shrub mowing, soil restoration, and road 

decommissioning. Some additional information on this has been added to the FEIS.

---------------------------------------------------------------------------------------------------------------------------------

Comment: We believe the Forest Service has not made the case that there is a legitimate need for the 

timber produced as part of this project or that selling the timber from sales stemming from the Ogden EIS 

will provide the resources necessary to complete post-logging restoration and burning activities.

Response: Based on comments received during scoping and the public comment period, there 

is evidence of a need for timber products in central Oregon. Estimated non-timber project 

treatment costs are displayed in Table 171 (FEIS p. 450) and overall cost efficiency of the 

project is displayed in Tables 172 and 173 (FEIS pp. 451-454). Revenue from the timber is not 

enough to cover all project costs when considering non-timber costs such as planning and 

preparation of this FEIS.

---------------------------------------------------------------------------------------------------------------------------------

Comment: The economic analysis for the Ogden Project estimates that Alternative 2 would create

or maintain 154 jobs while Alternative 3 would create or maintain 160 jobs even though there

would be 3 mmbf less fiber removed. The economic analysis, which was based on direction in the

forest plan, determined that the additional ponderosa pine volume (2 mmbf) that would be provided

under Alternative 3 actually would created more jobs than Alternative 2 even though there is less

overall volume. AFRC questions this result as green lodgepole pine is a very marketable species.

Comment: The DEIS cites the numbers of jobs that would be created if Alternatives 2 and 3 were 

adopted, and appears to rely solely on data from 1990 indicating the number of jobs each million board 

feet harvest creates (DEIS, pg 343). However, more updated information should be used, especially in the 

context of the larger regional timber market, including export related mill closures, and increased 

mechanization in mills since 1990.
Appendix F Response to Public Comment

Page 40 of 45

Response: Some additional work has been done on the economic analysis. A more recent 

source for the jobs created per million board foot is also presented in the analysis. FEIS pp. 

448-454.

--------------------------------------------------------------------------------------------------------------------------------------

Comment: The forest plan is in excess of 20 years old and the wood products industry has changed

dramatically since this document was prepared leaving the results of the economic analysis in

question.

Response: The economic analysis was completed using a more recent approach.

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EXECUTIVE SUMMARY

Comment: Executive Summary, pg. ES-2, Paragraph 1, and DEIS, Section 1.6.1, pg. 8, paragraph 1: 

The DEIS states that “[t]he stands of the PFA are not sustainable in their current condition as goshawk

habitat for the long term,” however, it is not clear why this is the case. This sentence should be explained 

in the FEIS.

Response: The information on the condition of the PFAs is located on page 235 of the FEIS. 

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Comment: Executive Summary Tables ES-2 and ES-3. It appears that these tables are intended to

represent Tables 10 and 11 from Section 2.6.2 Comparison of how each Alternative Meets the Purpose

and Need and Key Issues; however, these two tables are identical except for the titles. This should be

corrected in the FEIS.

Response: This has been corrected in the FEIS. 

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MISCELLANEUS

Comment: The DEIS is confusing because it uses the terms “seed tree harvest” and seed tree removal” 

which sound very similar but seem to refer to two very different treatments.

Response: These terms are clarified in the document. Both treatment types are considered as 

regeneration harvest methods. Seed tree harvest is a clearcut where seed trees are reserved (in 

order to regenerate a new stand of trees); and seed tree removal is an action in a previously 

clearcut stand where the new stand has been regenerated and now the seed trees are being 

removed. 

-----------------------------------------------------------------------------------------------------------------

Comment: The effects described under climate change are cumulative and serious and require 

quantification and avoidance or minimizing.

Response: As the EIS points out, the project is not a main contributor of greenhouse gas 

emissions and forested land will remain in a forested condition. The scale of the project and its 

cumulative effects on greenhouse gasses and climate change are negligible and to attempt to 

quantify them would be futile. The climate change analysis completed for the Ogden FEIS 

follows current Forest Service guidance from January 2009.

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Comment: Such a long list of mitigations implies a long list of foreseeable impacts that should be 

avoided. The longer and more complex the mitigation list, the more likely they are to fail.
Appendix F Response to Public Comments

 Page 41 of 45

Response: The resource protection measures listed in Chapter 2 (FEIS pp. 37-49) guide 

design and implementation to reduce or minimize unwanted impacts. Most project design 

elements and mitigation measures have been used in the past and are expected to effective.

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Comment: DEIS, Page 15: The title for Figure 2 reads “Land and Resource Management Plan. The 

Ogden Project area is primarily with the General Forest management area.” It appears that the correct

language should read “The Ogden Project area is primarily within the General Forest management

area.”

Response: This is corrected in the FEIS.

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Comment: These [Project Design Features] assume that recreationists don’t wander off the trail, out of 

campgrounds, etc. Why shouldn’t we be able to do that without being distressed by logging, etc.?

Response: During implementation, there will be warning signs and public notices posted to 

provide awareness and to ensure public safety (DEIS p. 37). The EIS discloses that there will 

be noise disturbance during operations.

POTENTIAL WILDERNESS

Comment: We want the Forest Service to drop the 278 acres of potential wilderness area proposed for 

logging and other management and the 717 acres of forest that shows no evidence of past logging or road 

construction identified within the lodgepole pine forest type within the higher elevations of the Ogden 

project area.

Comment: Drop all the logging, mowing, and burning planned for potential wilderness area in units 83, 

116, 113.

Response: With Alternative 2, only 25 acres of timber harvest will occur within the area identified as 

meeting the criteria for potential wilderness. Alternative 3 drops all treatment within areas identified 

as meeting the criteria for potential wilderness. (DEIS p. 440). The other areas lacking records of 

past harvest were likely harvested in the past and are in small patches scattered throughout the area, 

and fall primarily within the General Forest Management Area. Proposed treatments are consistent 

with all management direction. 

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OPINION / POSITION STATEMENT / ALTERNATIVE PREFERENCE

The following comments were considered by the IDT and Responsible Officials, but do not require a 

response: 

Comment: I believe that there are parts of both Alternatives 2 and 3 that are complementary and 

together would result in a better final decision to meet the Purpose and Need for Action.

Comment: Alternative 2 would maintain more acres and reduce resistance to fire suppression

efforts and the potential for crown fire initiation in Condition Class 1; would change potential fire

behavior on an additional 2917 acres (68% compared to No Action Alternative v. 57% for

Alternative 3);would reduce beetle influence for the next 20-50 years on 651 more acres than

Alternative 3, all of which AFRC supports since this is both a proactive and economically feasible

approach as well as meeting the Purpose and Need....

Comment: Alternative 2 has an estimated Net Present Value of $783,789 compared to $759,621 for 

Alternative 3 better meeting the Purpose and Need.
Appendix F Response to Public Comment

Page 42 of 45

Comment: Given the presence of three active northern goshawk territories in the project area, we favor 

the approach in Alternative 2 of avoiding management activities in the Post Fledgling Areas (PFA’s). The 

DEIS acknowledges that the approach to PFA’s in Alternative 3 will ‘more directly and negatively impact 

nesting and fledging than Alternative 2.’ (DEIS, pg 199).

Comment: We favor the greater protections from damage associated with mechanical entry into the 

Paulina RHCA, the Old Growth Management Area, and unroaded areas provided in Alternative 3, with 

the caveat that we believe the Forest Service can do better and should protect all unroaded areas 

contiguous with Newberry Crater National Monument and other larger wilderness quality tracts of forest 

in the project area from mechanical entry and commercial logging. Of the two alternatives, we favor 

Alternative 2’s more conservative approach to managing northern goshawk PFAs. However, we believe 

both alternatives cause too much harm to habitat for the Pacific fisher.

Comment: ...almost the entire area would be opened up, reducing biodiversity; degrading naturally 

moister, denser habitat; impairing goshawk viability; and greatly degrading the areas’ recreational 

experience and scenic views. 

Comment: We are concerned about proposed logging into the North Paulina inventoried roadless area, 

commercial logging along the Peter Skene Ogden National Scenic Trail, and Paulina Creek around the 

McKay Campground, and within goshawk habitat.

Comment: We want the Forest Service to cancel the sale units in the Old Growth Management Area, the 

Riparian Habitat Conservation Area, and in an area identified as having unroaded character.

Comment: We can’t support either alternative 2 or 3 due to all of [our] concerns.

Comment: We favor the Alternative 3 approach of thinning mixed ponderosa and lodgepole to a higher 

basal area than the LMZ and not burning areas with a lot of lodgepole.

Comment: We want more of the units along Paulina Creek and in the OGMA dropped than in 

Alternative 3.

Comment: We don’t want any commercial size logging or opening of canopy in the goshawk PFAs, 

contrary to Alternative 3.

Nix logging in: old growth forest, high elevation subalpine forest, popular recreation areas & roadless 

areas! Clearcutting/ 'regeneration cutting' to get the largest/oldest/most fire resistant trees- is the most 

ignorant/destructive to the biodiversity/ecosystem. Stop the logging carnage/rampage that's sterilizing 

huge wilderness areas & proposed wild/scenic rivers! Cancel sale units in the Old Growth Management 

And the Riparian Habitat Conservation Areas! Lack of optimum growth in areas are due to past logging 

that caused destructive soil compaction & loss of mycorrhizal fungi communities, indicating more time is 

needed for these areas to recover. Also past logging has damaged creeks- causing higher temps- aquatic 

life/fish to disappear. There is no risk for pine bark beetle epidemic until 2040! Leave the Roadless Areas 

alone! Many endangered species are at danger already. NIX Alternative 2 And 3! This is Not a sacrifice 

area! Keep it Wild.

Comment: Ban prescribed burning which releases mercury and fine particulate matter when vegetation 

is burned. Such fine particulate matter can travel thousands of miles across the USA and cause lung 

cancer, heart attacks, strokes, allergies, pneumonia, asthma. It is time to stop killing fellow Americans 

with burning. Such burning also kills wildlife and birds, which have no home for 5 years. Such burning 

also causes erosion when the tree roots cannot sustain holding in water. such burning also increases 

temperatures in streams so that fish die. Stop this idiocy which seems to be done so firefighters and staff 

make more money - it is all about greed and money. And besides, some of these fires go completely out of 

control and cost American taxpayers millions of dollars. We had such a one happen in NJ several times. 

This plan seems to be primarily about money and greed in a site owned by national taxpayers. Your 

connection to national taxpayers about this site has been sketchy - extremely sketchy. You seem to like to 
Appendix F Response to Public Comments

 Page 43 of 45

plan with local profiteers instead. None of our national sites will survive with those kinds of "local 

friends" looking to make a deal for their own wallets.

Response: These comments express a preference for one alternative, or general opposition to the 

project and have been considered by the IDT and responsible official. No direct response is necessary 

beyond what is already included in this Appendix and the entire FEIS.

Consideration of Additional Scientific and other References Offered with Comments (if not 

already responded to in FEIS or Response to Comments).

Referenced Document Forest Service Consideration / Response

March 16, 2010 letter to President Obama 

and Members of Congress signed by nine 

individuals.

This letter outlines for the President and members of Congress scientific data 

that the authors felt should be reflected in forest management legislation. It 

does not address the Ogden project area’s purpose and need or the effects 

analysis presented in the Draft EIS, which uses the best available science.

Lindenmayer, David et al. 2009. Effects 

of logging on fire regimes in moist forests. 

Conservation Letters 2 (2009) 271-277

This paper addresses the changes that industrial logging practices in native 

forests may have on fire regimes and how that may affect biodiversity. The 

authors distinguish this relationship in moist forest from dry forest such as 

ponderosa pine forests. 

As the paper points out, the environmental context is an important 

consideration in the proposed actions in the Ogden project area. The project 

area is expected to move closer to the historic range of variability following 

harvest and fuels reduction under both action alternatives (both in terms of 

structural stages and in the ability to maintain structure with low intensity fire). 

Simard, Martin, William H. Romme, Jacob 

M. Griffin, Monica G. Turner. 2011. Do 

mountain pine beetle outbreaks change 

the probability of active crown fire in 

lodgepole pine forests? Ecological 

Monographs, 81(1) pp 3-24.

This paper reports on the canopy and surface fuels occurring following a 

severe mountain pine beetle outbreak. The conclusions is that mountain pine 

beetle outbreaks in Greater Yellowstone may reduce the probability of active 

crown fire in the short term by thinning lodgepole pine canopies.

The overly dense stands in the Ogden project area are subject to beetle 

outbreaks and much of the area is rated moderate to extreme for fire hazard 

because of the fuel conditions. The FEIS describes continual increases in 

fuels under the No Action and in untreated stands which would create a higher 

fire hazard whether crown fire would result or not. Neither extensive mortality 

from insects nor large-scale mortality from wildfire are desired conditions. 

“NASA Satellites Reveal Surprising 

Connection Between Beetle Attacks, 

Wildfire” 

http://www.nasa.gov/topics/earth/features/

beetles-fire.html

Article describes research at University of Wisconsin, modeling fuels on areas 

of large beetle outbreaks and comparing beetle kill areas to recent large fires. 

Preliminary analysis indicates that large fires do not appear to occur more 

often or with greater severity in forest tracks with beetle damage.

Mitchell, Stephen R., Mark E. Harmon, 

Kari E. B. O’Connell. 2009. Forest fuel 

reduction alters fire severity and long-term 

carbon storage in three Pacific Northwest 

ecosystems. Ecological Applications 

19(3). 

The paper by Mitchell, Harmon, and O’Connell is the result of simulation 

exercises with three Pacific Northwest forest types: the east Cascades 

ponderosa pine forests, the west Cascades western hemlock-Douglas-fir 

forests. And the Coast Range western hemlock-Sitka spruce forests. 

Treatments simulated for the east Cascade ponderosa pine forests were 

similar to those proposed for Lookout Mountain (understory removal, 

prescribed fire, understory removal and prescribed fire). Based on a forest 

ecosystem simulation model, the authors suggest that fuel reduction 

treatments in these ecosystems consistently reduced fire severity. For the east 

Cascade ponderosa pine forests (represented by Pringle Falls Experimental 

Forest) there was little or no trade-off incurred by managing these forests for 

both fuel reduction and carbon sequestration. The authors speculate that the 
Appendix F Response to Public Comment

Page 44 of 45

removal of highly flammable understory vegetation led to a reduction in overall 

fire severity that consequently lowered overall biomass combustion, thereby 

allowing increased overall carbon storage. See Chapter 3.17 of the FEIS for a 

discussion of carbon storage and climate change as it relates to the Ogden 

project.

Wyoming State Wildlife Action Plan, 2010. 

Pp. IV-1-3 to IV-1-5.

This is apparently an excerpt from a document with an unknown purpose. The 

pages provided offer information on the American three-toed woodpecker. 

The Ogden EIS addresses the three-toed woodpecker and discloses effects to 

its habitat in the project area.

Fredriksen, R.L. undated. Impact of forest 

management on stream water quality in 

western Oregon. Reproduced from 

“Pollution Abatement and Control in the 

Forest Products Industry, 1971-1972 

Proceedings, by the Forest Service, U.S. 

Dept. of Agriculture.

This paper considers the potential impacts to water quality from forest 

management practices, including erosion/sedimentation, nutrient 

concentration, and increased water temperature.

The Ogden EIS includes a complete assessment of the potential impacts from 

all project activities on water quality (see Chapter 3.8). The analysis is based 

on the most relevant available scientific literature. The paper provided by 

commenter does not provide any information contrary to that presented in the 

EIS.

“Draft” Key and Priority Watersheds for the 

Blue Mountains National Forests. March 

31, 2010. 

This draft document from an unknown source lists watersheds of the Malheur, 

Umatilla, and Wallowa-Whitman National Forests that that are considered key 

sub-watersheds. Document lists the process for selection of the key 

watersheds. The Ogden project area does not involve any key or priority 

watersheds.

Memo – “Guidance for Implementing 

Eastside Screens” from Linda Goodman, 

Regional Forester, to Forest Supervisors, 

June 11, 2003. Enclosure “Recent 

Science Findings and Practical 

Experience: Implications for the Eastside 

Screens”

This region-wide guidance from the Regional Forester was considered during 

project planning. The Ogden project area does not present a situation where 

the Eastside Screens standards and guidelines prevent meeting objectives for 

forest health and fuels management. The action alternatives are designed to 

comply with the Eastside Screens.

Blue Mountains Forests Revised Land and 

Resource Management Plan. March 2010. 

Malheur, Umatilla, and Wallowa-Whiteman 

National Forests. Pages 31-32.

Excerpt from the proposed action with the 

following statement highlighted: “There 

has been a loss of large (20 inches DBH 

and greater) and medium (15 to 20 inches 

DBH) trees across the landscape.”

It is recognized that in the Ogden project area, large trees are not common. 

This project does not propose removal of trees over 21” dbh.
Appendix F Response to Public Comments 

Page 45 of 45

Federal Agency Comments:

Environmental Protection Agency
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

OFFICE OF 

ECOSYSTEMS, TRIBAL AND

PUBLIC AFFAIRS

September 6, 2011

John Allen, Forest Supervisor

c/o Shane Jeffries, District Ranger

1230 N.E. 3rd St., Suite A-262

Bend, Oregon 97701

RE: Ogden Landscape Vegetation Management Project (EPA Project Number 10-004-AFS)

Dear Mr. Allen:

The U.S. Environmental Protection Agency (EPA) has reviewed the Draft Environmental Impact 

Statement (DEIS) for the proposed Ogden Landscape Vegetation Management Project on the Bend/Ft. 

Rock Ranger District of Deschutes National Forest in Deschutes County, Oregon. Our review was 

conducted in accordance with EPA responsibilities under the National Environmental Policy Act 

(NEPA) and Section 309 of the Clean Air Act (CAA).

The DEIS analyzes the Forest Service’s proposal to implement treatments that would move the proposed 

project area towards a more resilient condition and provide a diversity of habitats closer to what 

historically occurred. Proposed treatments would reduce forest density and fuels in order to promote and 

sustain late and old structured forest stands, and increase resilience to insects, disease, and standreplacing wildfire. The project units would be located within a 26,521-acre project area. The DEIS 

analyzes a no action alternative and two action alternatives. Approximately 14,182 acres would be 

treated under Alternative 2 (Proposed Action) and approximately 14,422 acres would be treated under 

Alternative 3. Alternative 3 is identified as the preferred alternative.

The EPA is supportive of the overarching goals and objectives of the proposed project, and we find the 

DEIS to be clear, well organized, and robust. We appreciate the visual representations provided in 

conjunction with the descriptions of existing and projected stand conditions (i.e. Figures 14-26). This is 

a useful synthesis for the reader. We also appreciate the level of analysis given to activities proposed 

within the Riparian Habitat Conservation Areas (RHCAs). The photographs and site specific discussion 

and prescriptions help to provide clarity about the need for treatment and desired post treatment

conditions. We are also pleased by the Forest’s responsiveness to issues raised during the scoping 

process through the development and adoption of Alternative 3 as the preferred alternative. We support 

the approach in Alternative 3 of maintaining stands at or above the lower management zone, and the 

lighter touch within the RHCA. We are also cognizant, however, of recent research demonstrating that 

intensive thinning treatments are the most effective in reducing the probability of crown fires in the dry 

forests1

. The DEIS demonstrates that Alternative 3 would increase the percent of the landscape with low 

 1 Johnson, Morris C.; Kennedy, Maureen C; Peterson, David L. 2011. Simulating fuel treatment effects in dry forests of the 

western United States: testing the principles of a fire-safe forest. Canadian Journal of Forest Research. 41(6): 1018-1030. 

http://www.treesearch.fs.fed.us/pubs/38390
flame length potential (p. 149) and reduce crown fire potential (p. 154) but we encourage the Forest to 

consider this recent research as the final selected alternative is analyzed. 

Based on our review, we are rating the DEIS as LO (Lack of Objections). We appreciate the opportunity 

to review and comment on the DEIS, and we look forward to furthering our understanding of this and 

other projects as we continue to participate on the Provincial Advisory Committee. If you have any 

questions about our review, please contact me at (206) 553-1601, or by electronic mail at 

reichgott.christine@epa.gov. Or you may contact Teresa Kubo of my staff at 503-326-2859 or by 

electronic mail at kubo.teresa@epa.gov .

Sincerely,

//s//

Christine B. Reichgott, Manager

Environmental Review and Sediment Management Unit 
 U.S. Environmental Protection Agency Rating System for

Draft Environmental Impact Statements

Definitions and Follow-Up Action*

Environmental Impact of the Action

LO – Lack of Objections

The U.S. Environmental Protection Agency (EPA) review has not identified any potential environmental impacts 

requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation 

measures that could be accomplished with no more than minor changes to the proposal.

EC – Environmental Concerns

EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. 

Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce 

these impacts.

EO – Environmental Objections

EPA review has identified significant environmental impacts that should be avoided in order to provide adequate 

protection for the environment. Corrective measures may require substantial changes to the preferred alternative or 

consideration of some other project alternative (including the no-action alternative or a new alternative). EPA intends to work 

with the lead agency to reduce these impacts.

EU – Environmentally Unsatisfactory

EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory 

from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce 

these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be 

recommended for referral to the Council on Environmental Quality (CEQ).

Adequacy of the Impact Statement

Category 1 – Adequate

EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the 

alternatives reasonably available to the project or action. No further analysis of data collection is necessary, but the reviewer 

may suggest the addition of clarifying language or information.

Category 2 – Insufficient Information

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be 

avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives 

that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the 

action. The identified additional information, data, analyses or discussion should be included in the final EIS.

Category 3 – Inadequate

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, 

or the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives 

analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA 

believes that the identified additional information, data, analyses, or discussions are of such a magnitude that they should 

have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the National 

Environmental Policy Act and or Section 309 review, and thus should be formally revised and made available for public 

comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal 

could be a candidate for referral to the CEQ.

* From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impacting the Environment. February, 

1987.
United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

620 SW Main Street, Suite 201

Portland, Oregon 97205-3026

9043.1

IN REPLY REFER TO:

ER11/627

Electronically Filed

September 6, 2011 

Beth Peer

1230 NE 3rd Street, A-262

Bend, Oregon 97701

Dear Ms. Peer:

The U.S. Department of the Interior (Department) has reviewed the Draft Environmental Impact 

Statement (DEIS) for the Ogden Vegetation Management Project and Forest Plan Amendment, Deschutes 

County, Oregon. The Department offers the following comments for use in developing the Final 

Environmental Impact Statement (FEIS) for the project. 

SPECIFIC COMMENTS

Executive Summary, pg. ES-2, Paragraph 1, and DEIS, Section 1.6.1, pg. 8, paragraph 1:

The DEIS states that “[t]he stands of the PFA are not sustainable in their current condition as goshawk 

habitat for the long term,” however, it is not clear why this is the case. This sentence should be explained

in the FEIS. 

Executive Summary Tables ES-2 and ES-3

It appears that these tables are intended to represent Tables 10 and 11 from Section 2.6.2 Comparison of 

how each Alternative Meets the Purpose and Need and Key Issues; however, these two tables are 

identical except for the titles. This should be corrected in the FEIS. 

DEIS, Page 15:

The title for Figure 2 reads “Land and Resource Management Plan. The Ogden Project area is primarily 

with the General Forest management area.” It appears that the correct language should read “The Ogden 

Project area is primarily within the General Forest management area.”

DEIS, Page 254:

The work of the USGS investigator is inaccurately captured in this section. Here, the DEIS states that 

“Hagar (2007) supports this rationale by suggesting large dead wood is difficult to provide because of 

past harvest and safety reasons;” however, in Hagar’s work she stated:

“As more information is revealed about the ecological and habitat values of decaying wood, concern 

has increased over a reduction in the current amounts of dead wood relative to historic levels 

(Ohmann and Waddell, 2002). Past management practices have tended to severely reduce amounts of 
dead wood throughout all stages of forest development (Hansen et al., 1991). The large amounts of 

legacy wood that characterize young post-disturbance forests are not realized in managed stands, 

because most of the wood volume is removed at harvest for economic and safety reasons. Midrotation thinning is used to “salvage” some mortality that might otherwise occur due to suppression, 

so fewer snags are recruited in mid-seral stages. Harvest rotations of 80 years or less truncate tree 

size in managed stands, and 

thus limit the production of large-diameter wood. As a consequence of these practices, dead wood has 

been reduced by as much as 90% after two rotations of managed Douglas-fir (Rose et al., 2001). 

Large legacy deadwood is becoming a scarce, critical habitat that will take decades to centuries to 

replace. Furthermore, management continues to have important direct and indirect effects on the 

amount and distribution of dead wood in forests. Current guidelines for managing dead wood may be 

inadequate to maintain habitat for all associated 

species because they largely focus on a single use of dead wood (nesting habitat) by a small suite of 

species (cavity-nesting birds), and may under represent the sizes and amounts of dead wood used by 

many wildlife species (Rose et al., 2001, Wilhere, 2003).”

The FEIS should reflect that Hagar suggests that the guidelines for managing dead wood may be 

inadequate. 

DEIS, Page 360:

The Department recommends that the following reference be revised to reflect the appropriate URL:

Agee, J. K., Bahro, Berni, Finney, Mark A., Omi, Philip N., Sapsis, David B., Skinner, Carl N., van 

Wagtendonk, Jan W., Weatherspoon, C. Phillip, The Use of Fuelbreaks in Landscape Fire Management. 

http://www.qlg.org/pub/miscdoc/agee.htm. 

Thank you for the opportunity to review and comment on the DEIS. If you have any questions 

concerning our comments, please contact Gary LeCain, USGS Coordinator for Environmental Document 

Reviews, at (303) 236-1475 or at gdlecain@usgs.gov. If you have any other questions, please contact me 

at (503) 326-2489.

Sincerely,

 

Allison O’Brien

Regional Environmental Officer