United States Department of the Interior

BUREAU OF LAND MANAGEMENT

Oregon State Offi ce

P.O. Box 2965, Portland, Oregon 97208

http://www.blm.gov/or

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Dear Reader, 

The 2.5 million acres of Bureau of Land Management (BLM)-administered lands in western Oregon play 

an important role in the region’s social, ecological, and economic well-being. As stewards of these lands, 

the BLM has a responsibility to ensure that our management is meeting our legal mandates and the needs 

of the local communities. 

On April 24, 2015, we released a Draft Resource Management Plan/Environmental Impact Statement 

(Draft RMP/EIS) for the revision of the 1995 RMPs for the six BLM districts in western Oregon. During 

the four-month comment period that followed, we received approximately 4,500 comments from 

government agencies, organizations, Tribes, and members of the public. Thank you for your input; your 

participation has helped shaped our analysis and decision-making at every step of the planning process. If 

you would like to read all of the comments we received during the comment period, you can do so on our 

website at http://www.blm.gov/or/plans/rmpswesternoregon/comments.php. 

Enclosed you will find the Proposed RMP/Final EIS. We have developed the Proposed RMP in 

consultation with cooperating agencies and Tribes and with consideration of the comments that we 

received on the Draft RMP/EIS. This document explains why we are proposing a plan revision, presents 

our Proposed RMP and a full spectrum of different management alternatives, and analyzes their 

environmental effects. 

Below you will find information on the Protest Period and issuance of the Records of Decision (RODs). 

As always, we welcome your participation and involvement. Oregonians are in need of a lasting solution 

that will provide predictable outcomes and sustainable management of the BLM-administered lands in 

western Oregon. With your help, we are building an RMP that will provide sustainable solutions for the 

public lands that we are privileged to manage. 

Protest Period 

Pursuant to the BLM’s planning regulations at 43 CFR 1610.5–2, any person who participated in the 

planning process for this Proposed RMP, and has an interest which is or may be adversely affected by the 

planning decisions, may protest approval of the planning decisions within 30 days from the date the 

Environmental Protection Agency publishes the Notice of Availability in the Federal Register. Protests 

must comply with the requirements described in the BLM’s planning regulations at 43 CFR 1610.5–2. 

Interested parties should take care to document all relevant facts. As much as possible, specific planning 

documents or available planning records (e.g., meeting minutes, summaries, and correspondence) should 

be referenced or cited. 

Emailed protests will not be accepted as valid protests unless the protesting party also provides the 

original letter by either regular or overnight mail postmarked by the close of the protest period. Under 

these conditions, the BLM will consider the emailed protest as an advance copy and will afford it 

full consideration. If you wish to provide the BLM with such advance notification, please direct emailed 

protests to the attention of the BLM protest coordinator at protest@blm.gov. 

All protests, including the follow-up letter (if emailing), must be in writing and mailed to one of the 

following addresses: 

Regular Mail: Overnight Delivery: 

Director (210) Director (210) 

Attn: Protest Coordinator Attn: Protest Coordinator 

P.O. Box 71383 20 M Street SE, Room 2134LM 

Washington, D.C. 20024-1383 Washington, D.C. 20003 

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Dear Reader, 

The 2.5 million acres of Bureau of Land Management (BLM)-administered lands in western Oregon play 

an important role in the region’s social, ecological, and economic well-being. As stewards of these lands, 

the BLM has a responsibility to ensure that our management is meeting our legal mandates and the needs 

of the local communities. 

On April 24, 2015, we released a Draft Resource Management Plan/Environmental Impact Statement 

(Draft RMP/EIS) for the revision of the 1995 RMPs for the six BLM districts in western Oregon. During 

the four-month comment period that followed, we received approximately 4,500 comments from 

government agencies, organizations, Tribes, and members of the public. Thank you for your input; your 

participation has helped shaped our analysis and decision-making at every step of the planning process. If 

you would like to read all of the comments we received during the comment period, you can do so on our 

website at http://www.blm.gov/or/plans/rmpswesternoregon/comments.php. 

Enclosed you will find the Proposed RMP/Final EIS. We have developed the Proposed RMP in 

consultation with cooperating agencies and Tribes and with consideration of the comments that we 

received on the Draft RMP/EIS. This document explains why we are proposing a plan revision, presents 

our Proposed RMP and a full spectrum of different management alternatives, and analyzes their 

environmental effects. 

Below you will find information on the Protest Period and issuance of the Records of Decision (RODs). 

As always, we welcome your participation and involvement. Oregonians are in need of a lasting solution 

that will provide predictable outcomes and sustainable management of the BLM-administered lands in 

western Oregon. With your help, we are building an RMP that will provide sustainable solutions for the 

public lands that we are privileged to manage. 

Protest Period 

Pursuant to the BLM’s planning regulations at 43 CFR 1610.5–2, any person who participated in the 

planning process for this Proposed RMP, and has an interest which is or may be adversely affected by the 

planning decisions, may protest approval of the planning decisions within 30 days from the date the 

Environmental Protection Agency publishes the Notice of Availability in the Federal Register. Protests 

must comply with the requirements described in the BLM’s planning regulations at 43 CFR 1610.5–2. 

Interested parties should take care to document all relevant facts. As much as possible, specific planning 

documents or available planning records (e.g., meeting minutes, summaries, and correspondence) should 

be referenced or cited. 

Emailed protests will not be accepted as valid protests unless the protesting party also provides the 

original letter by either regular or overnight mail postmarked by the close of the protest period. Under 

these conditions, the BLM will consider the emailed protest as an advance copy and will afford it 

full consideration. If you wish to provide the BLM with such advance notification, please direct emailed 

protests to the attention of the BLM protest coordinator at protest@blm.gov. 

All protests, including the follow-up letter (if emailing), must be in writing and mailed to one of the 

following addresses: 

Regular Mail:

Director (210)

Attn: Protest Coordinator

P.O. Box 71383

Washington, D.C. 20024-1383

Overnight Delivery:

Director (210)

Attn: Protest Coordinator

20 M Street SE, Room 2134LM

Washington, D.C. 20003
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Before including your address, phone number, email address, or other personal identifying information in 

your protest, be advised that your entire protest—including your personal identifying information—may 

be made publicly available at any time. While you can ask us in your protest to withhold from public 

review your personal identifying information, we cannot guarantee that we will be able to do so. 

The BLM Director will make every attempt to render a decision on each protest promptly. The protest 

decision will be in writing and will be sent to the protesting party by certified mail, return receipt 

requested. The decision of the BLM Director shall be the final decision of the Department of the Interior 

for the protest. 

Records of Decision 

Following resolution of any protests and the completion of the consistency review by the Governor of 

Oregon, the BLM anticipates issuing two Records of Decision/Resource Management Plans 

(RODs/RMPs): one ROD/RMP that would apply to the Coos Bay District, Eugene District, Salem 

District, and the Swiftwater Field Office of the Roseburg District; and another ROD/RMP that would 

apply to the Klamath Falls Field Office of the Lakeview District, the Medford District, and the South 

River Field Office of the Roseburg District. 

The RODs/RMPs will identify the decision by the State Director on the RMP revision and the rationale 

for the decision. The RODs/RMPs will constitute the decision documents for the enclosed Proposed 

RMP/Final EIS. The RODs/RMPs will also contain the approved RMPs themselves, including the land 

use allocations, management objectives, and management direction. The RODs/RMPs will describe the 

compliance with applicable laws, the alternatives evaluated and the environmentally preferable 

alternative, necessary mitigations, the process for plan monitoring and evaluation, and the guidance for 

transition from the 1995 RMPs to the approved RMPs. 

The approval of the RODs/RMPs will represent the completion of this RMP revision process. Following 

approval of the RODs/RMPs, the BLM will take only those management actions that are specifically 

provided for in the approved RMPs, or, if not specifically mentioned, actions that are clearly consistent 

with the goals, objectives, or management direction of the approved RMPs. 

The BLM will email parties when the RODs/RMPs are available online or will mail the RODs/RMPs to 

parties who have requested hard copies. 

For more information on the Protest Period, planning process, or public participation, you can visit our 

website at http://www.blm.gov/or/plans/rmpswesternoregon/index.php. Thank you for your continued 

interest and participation in this planning process. We look forward to continuing to work with you. 

Jamie Connell 

Acting State Director 

Bureau of Land Management 

Oregon/Washington 
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United States Department of the Interior

Bureau of Land Management

Proposed Resource Management Plan/Final Environmental Impact Statement

for the Resource Management Plans for Western Oregon

Coos Bay, Eugene, Medford, Roseburg, and Salem Districts,

and the Klamath Falls Field Office of the Lakeview District

Cooperating agencies:

Benton County

Clackamas County

Columbia County

Coos County

Curry County

Douglas County

Klamath County

Lane County

Lincoln County

Linn County

Marion County

Multnomah County

Polk County

Tillamook County

Washington County

Yamhill County

State of Oregon

Environmental Protection Agency

National Marine Fisheries Service

U.S. Fish and Wildlife Service

U.S. Forest Service

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians

Confederated Tribes of Grand Ronde

Confederated Tribes of Siletz Indians

Coquille Indian Tribe

Cow Creek Band of Umpqua Tribe of Indians

Klamath Tribes

Abstract: This Proposed Resource Management Plan/Final Environmental Impact Statement addresses 

revision of the 1995 Resource Management Plans for the Coos Bay, Eugene, Medford, Roseburg, and 

Salem Districts, and the Klamath Falls Field Office of the Lakeview District. The purpose of this 

Resource Management Plan revision is to provide a sustained yield of timber, contribute to the 

conservation and recovery of threatened and endangered species, provide clean water in watersheds, 

restore fire-adapted ecosystems, provide recreation opportunities, and coordinate management of lands 

surrounding the Coquille Forest with the Coquille Tribe. The BLM analyzed the Proposed RMP, the No 

Action alternative of continued implementation of the 1995 Resource Management Plans, four action 

alternatives, and two sub-alternatives.

This Proposed RMP/Final EIS is open for a 30-day protest period beginning with the date the 

Environmental Protection Agency publishes the Notice of Availability of the Proposed RMP/Final EIS in 

the Federal Register. Protests must be filed with the Director of the BLM as described in the Dear Reader 

Letter.

For further information contact:

Sarah Levy, Public Affairs Specialist

RMPs for Western Oregon

Bureau of Land Management

P.O. Box 2965

Portland, Oregon 97208

Telephone: (503) 808-6217

Email: BLM_OR_RMPs_WesternOregon@blm.gov

Website: http://www.blm.gov/or/plans/rmpswesternoregon/
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Table of Contents

TABLE OF CONTENTS.............................................................................................................................................IV

TABLE OF FIGURES ................................................................................................................................................VI

TABLE OF MAPS ..................................................................................................................................................XIII

TABLE OF TABLES ................................................................................................................................................XIV

SUMMARY ........................................................................................................................................................XXIII

CHAPTER 1 – INTRODUCTION ................................................................................................................................1

CHAPTER 2 – ALTERNATIVES ................................................................................................................................ 29

CHAPTER 3 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES............................................. 115

AREAS OF CRITICAL ENVIRONMENTAL CONCERN .............................................................................................. 131

AIR QUALITY ...................................................................................................................................................... 145

CLIMATE CHANGE .............................................................................................................................................. 165

CULTURAL AND PALEONTOLOGICAL RESOURCES............................................................................................... 213

FIRE AND FUELS ................................................................................................................................................. 223

FISHERIES........................................................................................................................................................... 277

FOREST MANAGEMENT ..................................................................................................................................... 307

HYDROLOGY ...................................................................................................................................................... 369

INVASIVE SPECIES .............................................................................................................................................. 419

LANDS AND REALTY ........................................................................................................................................... 457

LANDS WITH WILDERNESS CHARACTERISTICS.................................................................................................... 463

LIVESTOCK GRAZING.......................................................................................................................................... 475

MINERALS.......................................................................................................................................................... 487

NATIONAL TRAILS SYSTEM................................................................................................................................. 505

RARE PLANTS AND FUNGI.................................................................................................................................. 517

RECREATION AND VISITOR SERVICES ................................................................................................................. 555

SOCIOECONOMICS............................................................................................................................................. 585

SOIL RESOURCES................................................................................................................................................ 745

SUSTAINABLE ENERGY ....................................................................................................................................... 769

TRAILS AND TRAVEL MANAGEMENT.................................................................................................................. 775

TRIBAL INTERESTS.............................................................................................................................................. 799

VISUAL RESOURCES MANAGEMENT .................................................................................................................. 813

WILDLIFE............................................................................................................................................................ 825

BALD EAGLE..............................................................................................................................................................825

BUREAU SENSITIVE, BUREAU STRATEGIC, SURVEY AND MANAGE SPECIES, AND LANDBIRD FOCAL SPECIES...................................830
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COLUMBIAN WHITE-TAILED DEER..................................................................................................................................853

DEER AND ELK ...........................................................................................................................................................862

FISHER .....................................................................................................................................................................870

GOLDEN EAGLE..........................................................................................................................................................881

GREATER SAGE-GROUSE ..............................................................................................................................................887

GRAY WOLF..............................................................................................................................................................890

MARBLED MURRELET .................................................................................................................................................895

NORTH OREGON COAST DISTINCT POPULATION SEGMENT OF THE RED TREE VOLE .................................................................919

NORTHERN SPOTTED OWL ...........................................................................................................................................928

NORTHERN SPOTTED OWL CRITICAL HABITAT..................................................................................................................990

OREGON SILVERSPOT BUTTERFLY ..................................................................................................................................999

OREGON SPOTTED FROG ...........................................................................................................................................1002

PACIFIC COAST DISTINCT POPULATION SEGMENT OF THE WESTERN SNOWY PLOVER.............................................................1006

WILD HORSES .................................................................................................................................................. 1019

WILD AND SCENIC RIVERS................................................................................................................................ 1023

CHAPTER 4 – CONSULTATION AND COORDINATION........................................................................................ 1041

ACRONYMS AND ABBREVIATIONS ................................................................................................................... 1059

GLOSSARY........................................................................................................................................................ 1063

INDEX .............................................................................................................................................................. 1085
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Table of Figures

FIGURE 2-1. NO ACTION ALTERNATIVE LAND USE ALLOCATIONS ................................................................................................31

FIGURE 2-2. NO ACTION ALTERNATIVE LAND USE ALLOCATIONS WITH MODIFIED HIERARCHY ...........................................................35

FIGURE 2-3. EXAMPLE OF HOW DECISION AREA ACRES ARE ASSIGNED BY LAND USE ALLOCATION/ADMINISTRATIVE DESIGNATION TYPE ....38

FIGURE 2-4. ALTERNATIVE A LAND USE ALLOCATIONS..............................................................................................................46

FIGURE 2-5. ALTERNATIVE B LAND USE ALLOCATIONS..............................................................................................................53

FIGURE 2-6. SUB-ALTERNATIVE B LAND USE ALLOCATIONS .......................................................................................................60

FIGURE 2-7. ALTERNATIVE C LAND USE ALLOCATIONS..............................................................................................................65

FIGURE 2-8. SUB-ALTERNATIVE C LAND USE ALLOCATIONS .......................................................................................................71

FIGURE 2-9. ALTERNATIVE D LAND USE ALLOCATIONS .............................................................................................................75

FIGURE 2-10. PROPOSED RMP LAND USE ALLOCATIONS..........................................................................................................81

FIGURE 2-11. PROPOSED RMP SUBWATERSHED CLASSES ........................................................................................................92

FIGURE 3-1. MAJOR OWNERSHIPS WITHIN THE PLANNING AREA ..............................................................................................116

FIGURE 3-2. PHYSIOGRAPHIC PROVINCES WITHIN THE PLANNING AREA AS DESCRIBED IN THE FEMAT REPORT (1993).......................117

FIGURE 3-3. ESTIMATED EMISSIONS FROM PRESCRIBED BURNING IN WESTERN OREGON FOR (A) PARTICULATE MATTER 10 MICRONS IN SIZE 

AND SMALLER, AND (B) PARTICULATE MATTER 2.5 MICRONS IN SIZE AND SMALLER..............................................................152

FIGURE 3-4. NUMBER OF SMOKE INTRUSIONS ATTRIBUTED TO BLM PRESCRIBED FIRES INTO SSRAS COMPARED TO ANNUAL ACRES BURNED 

FROM 2002 THROUGH 2014 IN WESTERN OREGON.....................................................................................................153

FIGURE 3-5. EXAMPLE OF IDENTIFICATION OF THE 20 PERCENT WORSE DAYS IN A GIVEN YEAR AND THE PROPORTIONAL CONTRIBUTION OF 

VARIOUS FACTORS TO REDUCED VISIBILITY ...................................................................................................................155

FIGURE 3-6. DAILY AIR QUALITY INDEX FOR MEDFORD IN 2008 ..............................................................................................156

FIGURE 3-7. AIR QUALITY INDEX FOR 2013 FOR MEDFORD....................................................................................................157

FIGURE 3-8. AIR QUALITY INDEX FOR 2013 FOR GRANTS PASS ...............................................................................................157

FIGURE 3-9. DEGRADATION OF VISIBILITY FROM BURNING VEGETATION IN 2013 AS MEASURED THROUGH LIGHT SCATTERING (INVERSE 

MEGAMETERS) AT CRATER LAKE NATIONAL PARK.........................................................................................................158

FIGURE 3-10. EXPECTED INCREASES IN PM10 EMISSIONS FROM PRESCRIBED FIRE OVER TIME AND RELATIVE TO THE ESTIMATE FOR CURRENT

PRESCRIBED FIRES...................................................................................................................................................159

FIGURE 3-11. EXPECTED INCREASES IN PM2.5 EMISSIONS FROM PRESCRIBED FIRE OVER TIME AND RELATIVE TO THE ESTIMATE FOR CURRENT

PRESCRIBED FIRES...................................................................................................................................................159

FIGURE 3-12. AVERAGE ANNUAL PM2.5 EMISSIONS FROM PRESCRIBED BURNING OVER THE 50-YEAR ANALYSIS PERIOD......................161

FIGURE 3-13. ESTIMATED CARBON STORAGE OVER TIME BY ALTERNATIVE AND THE PROPOSED RMP .............................................170

FIGURE 3-14. CHANGE IN CARBON STORAGE RELATIVE TO THE ESTIMATED TOTAL STORAGE AS OF 2013 .........................................171

FIGURE 3-15. PERCENT REDUCTION IN ABOVEGROUND CARBON STORAGE FROM TIMBER HARVEST RELATIVE TO PROJECTED CARBON 

STORAGE IN THE NO TIMBER HARVEST REFERENCE ANALYSIS WITH WILDFIRE .....................................................................172

FIGURE 3-16. PROPORTION OF ESTIMATED GREENHOUSE GAS EMISSIONS FROM LIVESTOCK GRAZING (ENTERIC FERMENTATION), TIMBER 

HARVEST OPERATIONS, PRESCRIBED FIRES, AND WILDFIRES ON BLM-ADMINISTERED LANDS WITHIN THE PLANNING AREA ...........176

FIGURE 3-17. PROPORTION OF ESTIMATED GREENHOUSE GAS EMISSIONS FROM (A) TIMBER HARVEST AND (B) PRESCRIBED BURNING BY 

DIFFERENT ENTITIES ................................................................................................................................................177

FIGURE 3-18. ESTIMATED AVERAGE ANNUAL GREENHOUSE GAS EMISSIONS FROM THE COMBINATION OF TIMBER HARVEST, GRAZING, AND 

PRESCRIBED FIRE ....................................................................................................................................................179

FIGURE 3-19. PROJECTED INCREASES IN AVERAGE ANNUAL GREENHOUSE GAS EMISSIONS FROM TIMBER HARVEST, GRAZING, AND 

PRESCRIBED BURNING RELATIVE TO AVERAGE ANNUAL EMISSIONS AS OF 2013 ...................................................................179

FIGURE 3-20. OBSERVED CHANGES IN ANNUAL AND SEASONAL PRECIPITATION BY BASIN..............................................................182

FIGURE 3-21. OBSERVED CHANGES IN (A) ANNUAL, (B) MAXIMUM, AND (C) MINIMUM TEMPERATURE IN EACH BASIN.......................184

FIGURE 3-22. AVERAGE ANNUAL NUMBER AND CAUSE OF IGNITIONS (1984–2013) WITHIN THE PLANNING AREA............................227

FIGURE 3-23. FOREST TYPE (MOIST AND DRY) DISTRIBUTION ON BLM-ADMINISTERED LANDS .......................................................232

FIGURE 3-24. DEPARTURE FROM REFERENCE CONDITIONS IN THE DOUGLAS-FIR/DRY VEGETATION TYPE BY SERAL STAGE ....................235

FIGURE 3-25. DEPARTURE FROM REFERENCE CONDITIONS IN THE DOUGLAS-FIR/MOIST VEGETATION TYPE BY SERAL STAGE FOR THE 

KLAMATH FALLS FIELD OFFICE ..................................................................................................................................237
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FIGURE 3-26. DEPARTURE FROM REFERENCE CONDITIONS IN THE DOUGLAS-FIR/MOIST VEGETATION TYPE BY SERAL STAGE FOR THE 

MEDFORD DISTRICT ...............................................................................................................................................239

FIGURE 3-27. DEPARTURE FROM REFERENCE CONDITIONS IN THE DOUGLAS-FIR/MOIST VEGETATION TYPE BY SERAL STAGE FOR THE 

ROSEBURG DISTRICT...............................................................................................................................................241

FIGURE 3-28. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE DRY FOREST IN THE INTERIOR/SOUTH FOR THE CURRENT CONDITION AND 

IN 50 YEARS..........................................................................................................................................................244

FIGURE 3-29. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE DRY FOREST IN THE MEDFORD DISTRICT FOR THE CURRENT CONDITION 

AND IN 50 YEARS ...................................................................................................................................................246

FIGURE 3-30. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE DRY FOREST IN THE ROSEBURG DISTRICT FOR THE CURRENT CONDITION 

AND IN 50 YEARS ...................................................................................................................................................246

FIGURE 3-31. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE DRY FOREST IN THE KLAMATH FALLS FIELD OFFICE FOR THE CURRENT 

CONDITION AND IN 50 YEARS ...................................................................................................................................246

FIGURE 3-32. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE LATE-SUCCESSIONAL RESERVE IN THE DRY FOREST IN THE 

INTERIOR/SOUTH FOR THE CURRENT CONDITION AND IN 50 YEARS...................................................................................248

FIGURE 3-33. STAND-LEVEL FIRE RESISTANCE CATEGORIES IN THE HARVEST LAND BASE IN THE DRY FOREST IN THE INTERIOR/SOUTH FOR 

THE CURRENT CONDITION AND IN 50 YEARS.................................................................................................................250

FIGURE 3-34. AVERAGE ANNUAL NUMBER OF HUMAN-CAUSED IGNITIONS IN PROXIMITY TO WILDLAND DEVELOPMENT AREAS, 1984–

2013 ..................................................................................................................................................................254

FIGURE 3-35. STAND-LEVEL FIRE HAZARD FOR ALL BLM-ADMINISTERED LANDS IN THE COASTAL/NORTH WITHIN THE WUI BY CURRENT 

CONDITION AND IN 2063 ........................................................................................................................................259

FIGURE 3-36. STAND-LEVEL FIRE HAZARD FOR ALL BLM-ADMINISTERED LANDS IN THE INTERIOR/SOUTH WITHIN THE WUI, BY CURRENT 

CONDITION AND IN 2063 ........................................................................................................................................259

FIGURE 3-37. STAND-LEVEL FIRE HAZARD FOR THE HARVEST LAND BASE IN THE COASTAL/NORTH WITHIN THE WUI BY CURRENT 

CONDITION AND IN 2063 ........................................................................................................................................261

FIGURE 3-38. STAND-LEVEL FIRE HAZARD FOR THE HARVEST LAND BASE IN THE INTERIOR/SOUTH WITHIN THE WUI BY CURRENT 

CONDITION AND IN 2063 ........................................................................................................................................263

FIGURE 3-39. WILDLAND FIRE POTENTIAL FOR BLM-ADMINISTERED LANDS IN THE PLANNING AREA ..............................................265

FIGURE 3-40. ACTIVITY FUEL RISK CATEGORIES FOR BLM-ADMINISTERED LANDS IN THE COASTAL/NORTH, DECADAL AVERAGE 2013–2063

..........................................................................................................................................................................268

FIGURE 3-41. ACTIVITY FUEL RISK CATEGORIES FOR BLM-ADMINISTERED LANDS IN THE INTERIOR/SOUTH, DECADAL AVERAGE 2013–2063

..........................................................................................................................................................................268

FIGURE 3-42. STAND CONDITIONS WITHIN ONE SITE-POTENTIAL TREE HEIGHT FOR THE CURRENT CONDITION, THE NO ACTION ALTERNATIVE 

IN 2113, AND THE NO TIMBER HARVEST REFERENCE ANALYSIS IN 2113...........................................................................286

FIGURE 3-43. RELATIVE PROPORTION OF STRUCTURAL STAGE ACRES UNDER THE CURRENT CONDITION, THE ALTERNATIVES, THE PROPOSED 

RMP, AND THE NO TIMBER HARVEST REFERENCE ANALYSIS IN 2113 FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT FROM 

ALL STREAMS.........................................................................................................................................................288

FIGURE 3-44. TREES PER ACRE GREATER THAN 20” DBH WITHIN ONE SITE-POTENTIAL TREE HEIGHT OVER TIME FOR ALL ALTERNATIVES, THE 

PROPOSED RMP, AND THE NO TIMBER HARVEST REFERENCE ANALYSIS............................................................................290

FIGURE 3-45. TREES PER ACRE GREATER THAN 20” DBH FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT OF STREAMS FOR THE

CURRENT CONDITION IN 2013, AND THE ALTERNATIVES, THE PROPOSED RMP, AND THE NO TIMBER HARVEST REFERENCE ANALYSIS 

IN 2113...............................................................................................................................................................290

FIGURE 3-46. PERCENT HARDWOOD CANOPY COVER FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT OF STREAMS FOR THE

CURRENT CONDITIONS IN 2013 AND IN 2113 .............................................................................................................291

FIGURE 3-47. QUADRATIC MEAN DIAMETER (QMD) OF CONIFERS FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT OF STREAMS FOR 

THE CURRENT CONDITION IN 2013, AND IN 2113 ........................................................................................................292

FIGURE 3-48. TOTAL TREES PER ACRE FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT OF STREAMS FOR THE CURRENT CONDITION IN

2013, AND IN 2113 ..............................................................................................................................................293

FIGURE 3-49. THINNING WITHIN THE RIPARIAN RESERVE BY DECADE........................................................................................296

FIGURE 3-50. BLM HISTORICAL TIMBER SALES; 1942–1961 DATA REPRESENTS VOLUME SOLD WHILE 1962–2012 DATA REPRESENTS 

VOLUME HARVESTED...............................................................................................................................................309

FIGURE 3-51. WESTERN OREGON TIMBER HARVESTS BY LANDOWNER, 1962–2011 (TUCHMAN AND DAVIS 2013) ........................309

FIGURE 3-52. 2013 AGE CLASS DISTRIBUTION FOR FORESTED ACRES WITHIN THE DECISION AREA (10-YEAR INCREMENTS)..................310
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FIGURE 3-53. 2013 AGE CLASS DISTRIBUTION BY AGE CLASS GROUPING AND BY THE HARVEST LAND BASE AND THE RESERVES (10-YEAR 

INCREMENTS)........................................................................................................................................................313

FIGURE 3-54. 2113 AGE CLASS DISTRIBUTION BY AGE CLASS GROUPING, AND BROKEN OUT BY THE HARVEST LAND BASE AND THE RESERVES

(10-YEAR INCREMENTS)..........................................................................................................................................316

FIGURE 3-55. CURRENT STRUCTURAL STAGE DISTRIBUTION FOR THE DECISION AREA....................................................................319

FIGURE 3-56. STRUCTURAL STAGE PROGRESSION OVER 200 YEARS IN THE HARVEST LAND BASE AND RESERVES ...............................324

FIGURE 3-57. PROPORTION OF THE HARVEST LAND BASE AS MATURE MULTI-LAYERED CANOPY OR STRUCTURALLY-COMPLEX THROUGH 

TIME....................................................................................................................................................................326

FIGURE 3-58. PROPORTION OF THE HARVEST LAND BASE SUB-ALLOCATIONS WITH STRUCTURAL LEGACIES OR MULTIPLE LAYERS THROUGH 

TIME....................................................................................................................................................................327

FIGURE 3-59. STRUCTURAL COMPLEXITY AND ABUNDANCE OF THE EARLY SUCCESSIONAL STRUCTURAL STAGE IN 2063......................328

FIGURE 3-60. ACREAGE OF FUNCTIONAL CREATED CANOPY OPENINGS > 0.25 ACRES IN 2043 BY ALTERNATIVE AND LAND USE ALLOCATION

..........................................................................................................................................................................330

FIGURE 3-61. PROPORTIONS OF OWL HABITAT MANAGEMENT LAND USE ALLOCATIONS IN MATURE MULTI-LAYERED CANOPY OR 

STRUCTURALLY-COMPLEX STRUCTURAL STAGES IN 2013 AND 2223 ................................................................................331

FIGURE 3-62. PROPORTIONS OF LAND USE ALLOCATIONS IN MATURE MULTI-LAYERED CANOPY OR STRUCTURALLY-COMPLEX STRUCTURAL 

STAGES THROUGH TIME ...........................................................................................................................................332

FIGURE 3-63. 2013 AND 2113 NET INVENTORY BROKEN OUT BETWEEN THE HARVEST LAND BASE AND RESERVES IN THE DECISION AREA

..........................................................................................................................................................................335

FIGURE 3-64. ASSUMED VS. IMPLEMENTED ANNUAL AVERAGE SOLD TIMBER VOLUME LEVELS AND MIX OF HARVEST TYPES, 1995 THROUGH 

2012, IN THE HARVEST LAND BASE (HLB) AND RESERVES IN THE DECISION AREA...............................................................340

FIGURE 3-65. TIMBER PRODUCTION RATES BY MANAGEMENT INTENSITY (BOARD FEET PER ACRE PER YEAR), BROKEN OUT BETWEEN 

COASTAL/NORTH AND INTERIOR/SOUTH AREAS ............................................................................................................343

FIGURE 3-66. TOTAL ASQ VS. NON-ASQ TIMBER VOLUME SOLD IN THE DECISION AREA BETWEEN 1995 AND 2012 ........................351

FIGURE 3-67. TOTAL ANNUAL TIMBER HARVEST IN THE DECISION AREA FOR THE FIRST DECADE COMPARED TO THE 1995–2012 SOLD 

TIMBER SALE AVERAGE, BROKEN OUT BETWEEN ASQ AND NON-ASQ SOURCES ..................................................................352

FIGURE 3-68. HARVEST ACRES PER DECADE BY HARVEST TYPE BASED ON AN AVERAGE OF THE FIRST TWO DECADES............................359

FIGURE 3-69. HARVESTED TIMBER VOLUME PER DECADE BY HARVEST TYPE BASED ON AN AVERAGE OF THE FIRST TWO DECADES ..........360

FIGURE 3-70. TOTAL TIMBER HARVEST ACREAGE PER YEAR BASED ON AN AVERAGE OF THE FIRST TWO DECADES, BROKEN OUT BETWEEN 

COASTAL/NORTH AND INTERIOR/SOUTH AREAS ............................................................................................................361

FIGURE 3-71. TOTAL TIMBER HARVEST VOLUME PER YEAR BASED ON AN AVERAGE OF THE FIRST TWO DECADES, BROKEN OUT BETWEEN 

COASTAL/NORTH AND INTERIOR/SOUTH AREAS ............................................................................................................361

FIGURE 3-72. PERCENTAGE OF FORESTED ACRES AVAILABLE FOR THE COLLECTION OF CATEGORY I SPECIAL FOREST PRODUCTS;

COASTAL/NORTH AREA............................................................................................................................................365

FIGURE 3-73. PERCENTAGE OF FORESTED ACRES AVAILABLE FOR THE COLLECTION OF CATEGORY I SPECIAL FOREST PRODUCTS;

INTERIOR/SOUTH AREA............................................................................................................................................365

FIGURE 3-74. PERCENTAGE OF FORESTED ACRES AVAILABLE FOR THE COLLECTION OF CATEGORY II SPECIAL FOREST PRODUCTS;

COASTAL/NORTH AREA............................................................................................................................................367

FIGURE 3-75. PERCENTAGE OF FORESTED ACRES AVAILABLE FOR THE COLLECTION OF CATEGORY II SPECIAL FOREST PRODUCTS;

INTERIOR/SOUTH AREA............................................................................................................................................367

FIGURE 3-76. CANOPY COVER AND ANGULAR CANOPY DENSITY IN FOREST STANDS......................................................................372

FIGURE 3-77. STRUCTURAL STAGE PROPORTIONS OF THE RIPARIAN RESERVE WITHIN 100 FEET OF PERENNIAL AND FISH-BEARING STREAMS 

IN THE DECISION AREA.............................................................................................................................................376

FIGURE 3-78. STRUCTURAL STAGE PROPORTIONS OF THE CURRENT RIPARIAN RESERVE (I.E., NO ACTION ALTERNATIVE) ALONG PERENNIAL 

AND FISH-BEARING STREAMS IN THE DECISION AREA......................................................................................................377

FIGURE 3-79. SEVEN-DAY AVERAGE MAXIMUM STREAM TEMPERATURES (°F) VINCENT CREEK GAGING STATION, COOS BAY DISTRICT, FOR 

YEARS 1990–2013 ...............................................................................................................................................378

FIGURE 3-80. SEVEN-DAY AVERAGE MAXIMUM STREAM TEMPERATURES (°F) AT DEADMAN CREEK, EAST FORK STOUTS CREEK AND SOUTH 

FORK MIDDLE CREEK, ROSEBURG DISTRICT, FOR YEARS 1992–2012 ..............................................................................378

FIGURE 3-81. TOTAL ACRES OF THE CURRENT RIPARIAN RESERVE COMPARED TO ACRES OF THE RIPARIAN RESERVE ALONG PERENNIAL AND 

FISH-BEARING STREAMS...........................................................................................................................................379

FIGURE 3-82. PERENNIAL AND FISH-BEARING STREAM MILES EXCEEDING 3 PERCENT SHADE LOSS...................................................382
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FIGURE 3-83. PERENNIAL AND FISH-BEARING STREAM MILES IN THE DECISION AREA COMPARED TO PERENNIAL AND FISH-BEARING STREAM 

MILES EXCEEDING 3 PERCENT SHADE LOSS ...................................................................................................................383

FIGURE 3-84. HYDROREGIONS WITHIN THE PLANNING AREA...................................................................................................386

FIGURE 3-85. SITE CONDITIONS AND TREATMENTS FOR RISK OF PEAK FLOW INCREASE..................................................................389

FIGURE 3-86. PROPORTIONS OF HYDROREGIONS IN THE PLANNING AREA ..................................................................................389

FIGURE 3-87. SEDIMENT TRANSPORT BY RETURN PERIOD AND STREAM TYPE..............................................................................390

FIGURE 3-88. RAIN-ON-SNOW DOMINATED SUBWATERSHEDS AND SUBWATERSHEDS CURRENTLY SUSCEPTIBLE TO A PEAK FLOW INCREASE

..........................................................................................................................................................................391

FIGURE 3-89. SUBWATERSHED AREA (ACRES) ON BLM-ADMINISTERED LANDS SUSCEPTIBLE TO PEAK FLOW INCREASES BY DECADE .......393

FIGURE 3-90. SUBWATERSHED AREA (ACRES) FOR ALL LANDS SUSCEPTIBLE TO PEAK FLOW INCREASES .............................................393

FIGURE 3-91. PROPORTION OF THE HARVEST LAND BASE WITH STEEP SLOPES > 75 PERCENT........................................................397

FIGURE 3-92. CUMULATIVE AREA OF NATURALLY OCCURRING MODELED LANDSLIDE DENSITY WITHIN THE HARVEST LAND BASE,

NUMBER/SQUARE MILE ...........................................................................................................................................398

FIGURE 3-93. RELATIVE LANDSLIDE DENSITY IN THE HARVEST LAND BASE COMPARED TO INTRINSIC POTENTIAL AT 2013....................399

FIGURE 3-94. REGENERATION HARVEST AREA WITH DEBRIS FLOW SUSCEPTIBILITY, ACRES PER DECADE ............................................400

FIGURE 3-95. POTENTIAL FINE SEDIMENT DELIVERY,* TO STREAMS FROM NEW ROADS BY 2023....................................................406

FIGURE 3-96. PROJECTED NEWLY CONSTRUCTED ROADS WITHIN A SEDIMENT DELIVERY DISTANCE COMPARED TO NEWLY CONSTRUCTED 

ROADS OUTSIDE A SEDIMENT DELIVERY DISTANCE BY 2023*...........................................................................................407

FIGURE 3-97. REPORTED INFESTATIONS OF REPRESENTATIVE INVASIVE PLANT SPECIES WITHIN THE PLANNING AREA...........................422

FIGURE 3-98. DISTRIBUTION CATEGORIES OF INVASIVE PLANT SPECIES FOR THE WATERSHEDS WITHIN THE PLANNING AREA.................427

FIGURE 3-99. SUSCEPTIBILITY TO THE INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES INTO RIPARIAN HABITATS ASSOCIATED WITH 

TIMBER HARVEST ADJACENT TO THE RIPARIAN RESERVE OVER THE NEXT 10 YEARS ..............................................................430

FIGURE 3-100. REPORTED INFESTATIONS OF REPRESENTATIVE INVASIVE AQUATIC SPECIES WITHIN THE PLANNING AREA .....................440

FIGURE 3-101. DISTRIBUTION CATEGORIES OF INVASIVE AQUATIC SPECIES BY SUBBASINS WITHIN THE PLANNING AREA.......................446

FIGURE 3-102. SUDDEN OAK DEATH INFESTATION ZONES AS OF 2013 AND EXPECTED EXPANSION ZONES BY 2023 AND 2033............453

FIGURE 3-103. UTILITY CORRIDORS ...................................................................................................................................461

FIGURE 3-104. ACRES OF INVENTORIED LANDS WITH WILDERNESS CHARACTERISTICS ALLOCATED TO THE DISTRICT-DESIGNATED RESERVE –

LANDS MANAGED FOR THEIR WILDERNESS CHARACTERISTICS .........................................................................................469

FIGURE 3-105. ALLOTMENTS AVAILABLE FOR LIVESTOCK GRAZING ...........................................................................................480

FIGURE 3-106. ACRES AVAILABLE FOR LIVESTOCK GRAZING ....................................................................................................480

FIGURE 3-107. ALLOCATED LIVESTOCK GRAZING AUMS........................................................................................................480

FIGURE 3-108. LIVESTOCK GRAZING ALLOTMENTS ON BLM-ADMINISTERED LANDS BY LIVESTOCK GRAZING AVAILABILITY UNDER THE 

PROPOSED RMP ...................................................................................................................................................482

FIGURE 3-109. PHYSIOGRAPHIC REGIONS IN OREGON...........................................................................................................488

FIGURE 3-110. NUMBER OF SALES OR PERMITS FOR MINERAL MATERIAL BY YEAR IN THE DECISION AREA .........................................491

FIGURE 3-111. SALES VOLUME OF MINERAL MATERIAL PRODUCED BY YEARS 2007–2013 IN THE DECISION AREA.............................491

FIGURE 3-112. DEVELOPED QUARRY SITES IN THE DECISION AREA FROM 2014 DISTRICT INVENTORIES............................................492

FIGURE 3-113. ACRES CLOSED TO SALABLE MINERAL MATERIAL DISPOSAL IN THE DECISION AREA ...................................................494

FIGURE 3-114. MINING CLAIMS IN THE DECISION AREA IN 2015.............................................................................................498

FIGURE 3-115. ACRES THAT THE BLM WOULD RECOMMEND FOR WITHDRAWAL FROM LOCATABLE MINERAL ENTRY AND PREVIOUSLY 

WITHDRAWN ACRES IN THE DECISION AREA..................................................................................................................500

FIGURE 3-116. ACRES THAT THE BLM WOULD RECOMMEND FOR WITHDRAWAL, WITH MINERAL RANKING OF ESTIMATED PROSPECTIVE 

MINERAL OCCURRENCE OR DEVELOPMENT FOR EACH LAND CATEGORY (INCLUDES PREVIOUSLY WITHDRAWN ACRES) ..................501

FIGURE 3-117. PACIFIC CREST NATIONAL SCENIC TRAIL ROUTE ON BLM-ADMINISTERED LANDS WITHIN THE PLANNING AREA.............509

FIGURE 3-118. BLM-ADMINISTERED LANDS VISIBLE WITHIN THE 5-MILE PACIFIC CREST TRAIL VIEWSHED OF TRAIL PORTIONS WITHIN THE 

PLANNING AREA.....................................................................................................................................................510

FIGURE 3-119. APPLEGATE TRAIL ROUTE ON BLM-ADMINISTERED LANDS IN THE PLANNING AREA.................................................511

FIGURE 3-120. RECREATION OPPORTUNITY SPECTRUM CLASSES ..............................................................................................556

FIGURE 3-121. STAND VISUALIZATIONS FOR RECREATIONAL SETTING CLASSIFICATIONS.................................................................558

FIGURE 3-122. PROJECTED LEVELS OF CHANGE BY RECREATION ACTIVITY WITHIN THE PLANNING AREA FROM 2012–2060 ................572

FIGURE 3-123. POPULATION CENTERS WITHIN THE PLANNING AREA.........................................................................................573

FIGURE 3-124. THIRTY- AND SIXTY-MINUTE DRIVING TIMES FROM THE 12 WESTERN OREGON STUDY COMMUNITIES AND POPULATION 

CENTER SIZE ..........................................................................................................................................................575
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FIGURE 3-125. WESTERN OREGON POPULATION DENSITY .....................................................................................................576

FIGURE 3-126. WESTERN OREGON HISTORICAL TIMBER HARVEST, BLM AND TOTAL ...................................................................602

FIGURE 3-127. WESTERN OREGON HISTORICAL STUMPAGE PRICES, BLM AND STATE/PRIVATE.....................................................602

FIGURE 3-128. TOTAL HARVEST VALUE BY BLM DISTRICT, 2000–2014...................................................................................605

FIGURE 3-129. AVERAGE VALUE PER MBF HARVESTED BY BLM DISTRICT, 2000–2014 ..............................................................605

FIGURE 3-130. TIMBER GROSS REVENUE OVER TIME .............................................................................................................631

FIGURE 3-131. GROSS REVENUE, TOTAL COSTS, AND NET REVENUE, 2014–2023......................................................................631

FIGURE 3-132. NET PRESENT VALUE OVER 50 YEARS (2014–2063) BY DISTRICT .......................................................................634

FIGURE 3-133. COST PER VOLUME BY DISTRICT, 2014–2023 (2012 DOLLARS) ........................................................................636

FIGURE 3-134. STUMPAGE PRICE BY DISTRICT, 2014–2023 (2012 DOLLARS) ..........................................................................638

FIGURE 3-135. RMA ACREAGE BY DRIVING DISTANCE OF WESTERN POPULATION CENTERS, 30 AND 60 MINUTES .............................645

FIGURE 3-136. OUTDOOR RECREATION VISITS OVER PHASING TIMEFRAMES...............................................................................647

FIGURE 3-137. OUTDOOR RECREATION VISITS AT END OF PHASING TIMEFRAMES........................................................................648

FIGURE 3-138. CAPACITY AND RESILIENCY AFFECTED ENVIRONMENT SUMMARY .........................................................................718

FIGURE 3-139. DETRIMENTAL SOIL DISTURBANCE FROM TIMBER HARVEST BY YARDING SYSTEM, 1990–2012.................................749

FIGURE 3-140. DETRIMENTAL SOIL DISTURBANCE FROM TIMBER HARVEST BY YARDING SYSTEM DURING THE FIRST DECADE.................750

FIGURE 3-141. DETRIMENTAL SOIL DISTURBANCE FROM ROAD CONSTRUCTION DURING THE FIRST DECADE......................................754

FIGURE 3-142. DETRIMENTAL SOIL DISTURBANCE FROM FUEL TREATMENTS DURING THE FIRST DECADE ..........................................761

FIGURE 3-143. VISUAL RESOURCE INVENTORY CLASS DISTRIBUTION FOR THE PROPOSED RMP† WITHIN THE DECISION AREA...............817

FIGURE 3-144. BALD EAGLE HABITAT IN THE DECISION AREA–CURRENT CONDITION AND IN 50 YEARS.............................................827

FIGURE 3-145. BALD EAGLE HABITAT IN THE PLANNING AREA–CURRENT CONDITION AND IN 50 YEARS ...........................................827

FIGURE 3-146. STRUCTURAL STAGE DEVELOPMENT IN THE DECISION AREA COMPARED WITH AVERAGE HISTORIC CONDITION...............838

FIGURE 3-147. STRUCTURAL STAGE DEVELOPMENT IN THE PLANNING AREA COMPARED WITH AVERAGE HISTORIC CONDITION .............839

FIGURE 3-148. EARLY SUCCESSIONAL, STAND ESTABLISHMENT, AND YOUNG STANDS WITH STRUCTURAL LEGACIES IN THE DECISION AREA

..........................................................................................................................................................................844

FIGURE 3-149. MATURE AND STRUCTURALLY-COMPLEX STANDS WITH STRUCTURAL LEGACIES WITHIN THE DECISION AREA ................844

FIGURE 3-150. MATURE AND STRUCTURALLY-COMPLEX HABITAT DEVELOPMENT IN THE DECISION AREA.........................................849

FIGURE 3-151. RANGE OF THE COLUMBIAN WHITE-TAILED DEER.............................................................................................855

FIGURE 3-152. COLUMBIAN WHITE-TAILED DEER HIGH-QUALITY EARLY SUCCESSIONAL FORAGE HABITAT FOR THE LOWER COLUMBIA RIVER 

POPULATION ON BLM-ADMINISTERED LANDS..............................................................................................................857

FIGURE 3-153. COLUMBIAN WHITE-TAILED DEER HIGH-QUALITY EARLY SUCCESSIONAL FORAGE HABITAT FOR THE LOWER COLUMBIA RIVER 

POPULATION ACROSS ALL LAND OWNERSHIPS...............................................................................................................857

FIGURE 3-154. COLUMBIAN WHITE-TAILED DEER HIGH-QUALITY EARLY SUCCESSIONAL FORAGE HABITAT FOR THE DOUGLAS COUNTY 

POPULATION ON BLM-ADMINISTERED LANDS..............................................................................................................859

FIGURE 3-155. COLUMBIAN WHITE-TAILED DEER HIGH-QUALITY EARLY SUCCESSIONAL FORAGE HABITAT FOR THE DOUGLAS COUNTY 

POPULATION ACROSS ALL OWNERSHIPS.......................................................................................................................859

FIGURE 3-156. DEER AND ELK HIGH-QUALITY FORAGE HABITAT IN THE DECISION AREA.................................................................865

FIGURE 3-157. DEER AND ELK HIGH-QUALITY FORAGE HABITAT IN THE PLANNING AREA ...............................................................865

FIGURE 3-158. DEER AND ELK MANAGEMENT AREAS ............................................................................................................868

FIGURE 3-159. RANGE OF THE FISHER................................................................................................................................872

FIGURE 3-160. FISHER HABITAT IN THE DECISION AREA..........................................................................................................875

FIGURE 3-161. FISHER HABITAT ON BLM-ADMINISTERED LANDS AND ACROSS ALL OWNERSHIPS FOR FORAGING, RESTING, AND DENNING

..........................................................................................................................................................................878

FIGURE 3-162. FISHER HABITAT IN THE PLANNING AREA ........................................................................................................880

FIGURE 3-163. GOLDEN EAGLE NESTING HABITAT IN THE DECISION AREA ..................................................................................884

FIGURE 3-164. GOLDEN EAGLE NESTING HABITAT IN THE PLANNING AREA.................................................................................884

FIGURE 3-165. KNOWN AREAS OF WOLF ACTIVITY IN THE PLANNING AREA ................................................................................891

FIGURE 3-166. RANGE AND MANAGEMENT ZONES OF THE MARBLED MURRELET ........................................................................898

FIGURE 3-167. MARBLED MURRELET NESTING HABITAT IN THE DECISION AREA ..........................................................................902

FIGURE 3-168. MARBLED MURRELET NESTING HABITAT TRENDS IN THE DECISION AREA ...............................................................903

FIGURE 3-169. MARBLED MURRELET HIGH-QUALITY NESTING HABITAT TRENDS IN THE DECISION AREA ...........................................904

FIGURE 3-170. MARBLED MURRELET HIGH-QUALITY NESTING HABITAT IN THE PLANNING AREA .....................................................906

FIGURE 3-171. MARBLED MURRELET NESTING HABITAT IN CRITICAL HABITAT IN THE DECISION AREA...............................................907
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FIGURE 3-172. HIGH-QUALITY MARBLED MURRELET NESTING HABITAT IN DESIGNATED CRITICAL HABITAT IN THE PLANNING AREA ........908

FIGURE 3-173. MARBLED MURRELET OCCUPANCY DETECTION RATES .......................................................................................909

FIGURE 3-174. KNOWN, OCCUPIED MARBLED MURRELET SITES IN THE DECISION AREA.................................................................913

FIGURE 3-175. FORECAST OF THE NUMBER OF OCCUPIED MARBLED MURRELET SITES IN THE DECISION AREA ....................................917

FIGURE 3-176. RANGE OF THE NORTH OREGON COAST DPS OF THE RED TREE VOLE...................................................................920

FIGURE 3-177. RED TREE VOLE HABITAT WITHIN THE NORTH OREGON COAST DPS IN THE DECISION AREA......................................922

FIGURE 3-178. RED TREE VOLE HABITAT WITHIN THE NORTH OREGON COAST DPS IN THE PLANNING AREA.....................................922

FIGURE 3-179. THE CURRENT (2013) POSITIONS OF NORTHERN SPOTTED OWL HABITAT BLOCKS IN WESTERN OREGON .....................937

FIGURE 3-180. THE POTENTIAL CONTRIBUTIONS OF BLM-ADMINISTERED LANDS IN WESTERN OREGON TO HABITAT BLOCKS IN 2043 AND 

2063 ACCORDING TO THE NO TIMBER HARVEST REFERENCE ANALYSIS .............................................................................938

FIGURE 3-181. NORTHERN SPOTTED OWL HABITAT BLOCK LOCATIONS IN 2043 AND 2063 UNDER ALTERNATIVE C ..........................939

FIGURE 3-182. NORTHERN SPOTTED OWL HABITAT BLOCK LOCATIONS IN 2043 AND 2063 UNDER THE PROPOSED RMP ..................940

FIGURE 3-183. THE NORTHERN SPOTTED OWL DISPERSAL-CAPABLE LANDSCAPE (STIPPLED AREAS) IN 2013, ACCORDING TO THE NO 

TIMBER HARVEST REFERENCE ANALYSIS ......................................................................................................................943

FIGURE 3-184. THE NORTHERN SPOTTED OWL DISPERSAL-CAPABLE LANDSCAPE (STIPPLED AREAS) IN 2043 AND 2063, ACCORDING TO THE 

NO TIMBER HARVEST REFERENCE ANALYSIS.................................................................................................................944

FIGURE 3-185. DISPERSAL-CAPABLE LANDS (STIPPLED AREAS), AS THEY WOULD EXIST IN 2043 AND 2063, UNDER ALTERNATIVE C .....945

FIGURE 3-186. DISPERSAL-CAPABLE LANDS (STIPPLED AREAS), AS THEY WOULD EXIST IN 2043 AND 2063, UNDER THE PROPOSED RMP

..........................................................................................................................................................................946

FIGURE 3-187. U.S. FISH AND WILDLIFE SERVICE MODELING REGIONS.....................................................................................950

FIGURE 3-188. SIMULATED NORTHERN SPOTTED OWL POPULATIONS (MEAN NUMBERS OF FEMALES FROM 500 REPLICATE NONSTOCHASTIC SIMULATIONS) FOR EACH WESTERN OREGON MODELING REGION, BY DECADE, UNDER ALTERNATIVE C AND THE 

PROPOSED RMP, AND ACCORDING TO THE NO TIMBER HARVEST REFERENCE ANALYSIS.......................................................959

FIGURE 3-189. SIMULATED NORTHERN SPOTTED OWL POPULATIONS (MEAN NUMBERS OF FEMALES FROM 500 REPLICATE NONSTOCHASTIC SIMULATIONS) FOR EACH WESTERN OREGON PHYSIOGRAPHIC PROVINCE, BY DECADE, UNDER ALTERNATIVE C AND THE 

PROPOSED RMP, AND ACCORDING TO THE NO TIMBER HARVEST REFERENCE ANALYSIS.......................................................960

FIGURE 3-190. NO TIMBER HARVEST REFERENCE ANALYSIS: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL 

OF 250 FEMALES IN EACH MODELING REGION..............................................................................................................963

FIGURE 3-191. NO TIMBER HARVEST REFERENCE ANALYSIS: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL 

OF 100 FEMALES IN EACH MODELING REGION..............................................................................................................965

FIGURE 3-192. ALTERNATIVE C: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL OF 250 FEMALES IN EACH 

MODELING REGION.................................................................................................................................................967

FIGURE 3-193. ALTERNATIVE C: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL OF 100 FEMALES IN EACH 

MODELING REGION.................................................................................................................................................968

FIGURE 3-194. PROPOSED RMP: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL OF 250 FEMALES IN EACH 

MODELING REGION.................................................................................................................................................969

FIGURE 3-195. PROPOSED RMP: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION LEVEL OF 100 FEMALES IN EACH 

MODELING REGION.................................................................................................................................................970

FIGURE 3-196. PROPOSED RMP WITH BARRED OWL CONTROL: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION 

LEVEL OF 250 FEMALES IN EACH MODELING REGION......................................................................................................971

FIGURE 3-197. PROPOSED RMP WITH BARRED OWL CONTROL: EXTINCTION RISK AS A FUNCTION OF TIME, USING A QUASI-EXTINCTION 

LEVEL OF 100 FEMALES IN EACH MODELING REGION......................................................................................................972

FIGURE 3-198. FORECASTED CHANGE IN THE ACRES OF THE FORESTED LANDSCAPE THAT WOULD BE STRONGLY AVOIDED BY NORTHERN 

SPOTTED OWLS (I.E., NON-HABITAT) OF RESERVE LAND USE ALLOCATIONS .........................................................................976

FIGURE 3-199. FORECASTED CHANGE IN THE ACRES OF THE FORESTED LANDSCAPE THAT WOULD BE STRONGLY AVOIDED BY NORTHERN 

SPOTTED OWLS (I.E., NON-HABITAT) IN CRITICAL HABITAT UNITS ON BLM-ADMINISTERED LANDS...........................................977

FIGURE 3-200. NUMBER OF NORTHERN SPOTTED OWL SITES THAT WOULD BE AT OR ABOVE RECOVERY ACTION 10 HABITAT THRESHOLDS 

DURING EACH DECADE.............................................................................................................................................979

FIGURE 3-201. CHANGE IN THE ACRES OF ‘STRONGLY-SELECTED-FOR’ HABITAT ON BLM-ADMINISTERED LANDS IN WESTERN OREGON .985

FIGURE 3-202. CHANGE IN THE ACRES OF MATURE MULTIPLE-CANOPY AND STRUCTURALLY-COMPLEX FOREST ON BLM-ADMINISTERED 

LANDS IN WESTERN OREGON....................................................................................................................................986

FIGURE 3-203. NUMBER OF NORTHERN SPOTTED OWL KNOWN SITES ASSOCIATED WITH CRITICAL HABITAT ON BLM-ADMINISTERED LANDS 

THAT WOULD BE AT OR ABOVE RECOVERY ACTION 10 HABITAT THRESHOLDS DURING EACH DECADE .......................................994
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FIGURE 3-204. CHANGE IN THE ACRES OF ‘STRONGLY-SELECTED-FOR’ HABITAT IN CRITICAL HABITAT ON BLM-ADMINISTERED LANDS IN 

WESTERN OREGON.................................................................................................................................................995

FIGURE 3-205. POKEGAMA HERD CENSUS, 1972–2015.....................................................................................................1020
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Table of Maps

MAP 1-1. MAJOR OWNERSHIPS WITHIN THE PLANNING AREA .....................................................................................................2

MAP 1-2. PUBLIC DOMAIN AND ACQUIRED LANDS ..................................................................................................................16

MAP 2-1. NO ACTION ALTERNATIVE LAND USE ALLOCATIONS....................................................................................................32

MAP 2-2. ALTERNATIVE A LAND USE ALLOCATIONS.................................................................................................................48

MAP 2-3. ALTERNATIVE B LAND USE ALLOCATIONS.................................................................................................................54

MAP 2-4. SUB-ALTERNATIVE B LAND USE ALLOCATIONS ..........................................................................................................62

MAP 2-5. ALTERNATIVE C LAND USE ALLOCATIONS.................................................................................................................66

MAP 2-6. SUB-ALTERNATIVE C LAND USE ALLOCATIONS ..........................................................................................................72

MAP 2-7. ALTERNATIVE D LAND USE ALLOCATIONS ................................................................................................................76

MAP 2-8. PROPOSED RMP LAND USE ALLOCATIONS...............................................................................................................84

MAP 3-1. SMOKE SENSITIVE RECEPTOR AREAS AS DESCRIBED IN THE OREGON SMOKE MANAGEMENT PLAN...................................149

MAP 3-2. MOIST AND DRY FOREST TYPES ...........................................................................................................................230

MAP 3-3. WILDLAND DEVELOPMENT AREAS WITHIN THE PLANNING AREA ...............................................................................257

MAP 3-4. LANDS WITH WILDERNESS CHARACTERISTICS WITHIN THE DECISION AREA.....................................................................467

MAP 3-5. COUNTIES, BLM ADMINISTRATIVE BOUNDARIES, AND TRIBAL LANDS WITHIN THE PLANNING AREA...................................586

MAP 3-6. TRAVEL TIMES FROM MAJOR COMMUNITIES IN RELATION TO BLM-ADMINISTERED LANDS ..............................................608

MAP 3-7. SELECTED COMMUNITIES (CITIES AND TRIBES) USED FOR THE ANALYSIS OF CAPACITY AND RESILIENCY................................707

MAP 3-8. MINORITY POPULATIONS AND COUNTIES WITHIN THE PLANNING AREA........................................................................729

MAP 3-9. LOW-INCOME AND POVERTY POPULATIONS AND COUNTIES WITHIN THE PLANNING AREA................................................731
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Table of Tables

TABLE 2-1. NO ACTION ALTERNATIVE LAND USE ALLOCATIONS ..................................................................................................31

TABLE 2-2. NO ACTION ALTERNATIVE LAND USE ALLOCATIONS WITH MODIFIED HIERARCHY.............................................................35

TABLE 2-3. FOREST MANAGEMENT PRACTICES BY HARVEST LAND BASE SUB-ALLOCATION ..............................................................39

TABLE 2-4. ALTERNATIVE A LAND USE ALLOCATIONS ...............................................................................................................46

TABLE 2-5. ALTERNATIVE B LAND USE ALLOCATIONS ...............................................................................................................53

TABLE 2-6. SUB-ALTERNATIVE B LAND USE ALLOCATIONS .........................................................................................................60

TABLE 2-7. ALTERNATIVE C LAND USE ALLOCATIONS ...............................................................................................................65

TABLE 2-8. SUB-ALTERNATIVE C LAND USE ALLOCATIONS .........................................................................................................71

TABLE 2-9. ALTERNATIVE D LAND USE ALLOCATIONS ...............................................................................................................75

TABLE 2-10. PROPOSED RMP LAND USE ALLOCATIONS AND SUBALLOCATIONS.............................................................................82

TABLE 2-11. KEY FEATURES OF THE ALTERNATIVES AND THE PROPOSED RMP............................................................................109

TABLE 2-12. KEY EFFECTS OF THE ALTERNATIVES AND THE PROPOSED RMP ..............................................................................112

TABLE 3-1. LAND STATUS OF THE DECISION AREA..................................................................................................................118

TABLE 3-2. VALUE CATEGORIES FOR DESIGNATED AND PREVIOUSLY NOMINATED POTENTIAL ACECS...............................................133

TABLE 3-3. DESIGNATED AND PREVIOUSLY NOMINATED POTENTIAL ACECS AND CORRESPONDING RNA OR ONA IF APPLICABLE .........137

TABLE 3-4. NEW POTENTIAL ACECS AND CORRESPONDING RNA OR ONA IF APPLICABLE ............................................................137

TABLE 3-5. VALUE CATEGORIES FOR POTENTIAL ACECS EVALUATED IN THIS ANALYSIS..................................................................138

TABLE 3-6. ALL POTENTIAL ACECS DESIGNATIONS................................................................................................................139

TABLE 3-7. POTENTIAL ACECS NOT DESIGNATED UNDER THE ACTION ALTERNATIVES OR THE PROPOSED RMP .................................140

TABLE 3-8. RELEVANT AND IMPORTANT VALUE CATEGORIES THAT WOULD NOT RECEIVE SPECIAL MANAGEMENT ATTENTION................141

TABLE 3-9. REASONS FOR NOT DESIGNATING POTENTIAL ACECS .............................................................................................141

TABLE 3-10. CRITERIA POLLUTANTS REGULATED UNDER THE CLEAN AIR ACT AND THE CURRENT NAAQS FOR EACH..........................148

TABLE 3-11. AIR QUALITY INDEX WITH HEALTH ADVISORIES ...................................................................................................150

TABLE 3-12. VISIBILITY CONDITIONS AND TRENDS AT FOUR MANDATORY CLASS 1 AREAS WITHIN OR ADJACENT TO THE PLANNING AREA 

FROM 2003 THROUGH 2012 AND THE STATISTICAL TREND ............................................................................................154

TABLE 3-13. ESTIMATED CURRENT TOTAL CARBON STORED IN VEGETATION AND SOIL AND CARBON DENSITY ....................................169

TABLE 3-14. ESTIMATED CARBON STORAGE AND CARBON DENSITY FOR THE MAJOR LAND OWNERSHIPS IN WESTERN OREGON.............173

TABLE 3-15. CLIMATE CHANGE VULNERABILITY SCORES FOR DIFFERENT TREE SPECIES IN WESTERN OREGON.....................................187

TABLE 3-16. EXPECTED CHANGES IN MEAN ANNUAL AND SEASONAL TEMPERATURE AND PRECIPITATION BY 2041–2070 AS COMPARED TO 

MEANS IN THE 1950–1999 FOR RCP 4.5 AND RCP 8.5 ..............................................................................................191

TABLE 3-17. VALUES FOR SLOPE AND DISTANCE TO WATER BREAK POINTS .................................................................................214

TABLE 3-18. TOTAL VALUE SCORES AND CORRESPONDING PROBABILITY ....................................................................................214

TABLE 3-19. DISTRIBUTION OF ALL ACRES WITHIN THE DECISION AREA BY PROBABILITY ZONE ........................................................214

TABLE 3-20. SUMMARY OF ACRES OF CULTURAL RESOURCE INVENTORIES ON BLM-ADMINISTERED LANDS ......................................216

TABLE 3-21. SUMMARY OF ACRES OF CULTURAL RESOURCE INVENTORIES AND RECORDED SITES BY PROBABILITY ZONE .......................217

TABLE 3-22. DISTRIBUTION OF SITE TYPES...........................................................................................................................218

TABLE 3-23. CONDITIONS OF RECORDED SITES WITHIN THE DECISION AREA................................................................................218

TABLE 3-24. ACREAGE OF TIMBER HARVEST FOR THE FIRST DECADE IN EACH PROBABILITY ZONE.....................................................219

TABLE 3-25. TOTAL MILEAGE OF NEW ROAD CONSTRUCTION ..................................................................................................219

TABLE 3-26. NUMBER OF AVAILABLE AUTHORIZED LIVESTOCK GRAZING ALLOTMENTS, ACRES, AND ACTIVE USE.................................220

TABLE 3-27. NUMBER OF REPORTED PALEONTOLOGICAL LOCALITIES ........................................................................................222

TABLE 3-28. FIRE REGIME GROUPS AND DESCRIPTIONS USED IN CURRENT LANDFIRE FIRE REGIME CONDITION CLASS GUIDEBOOK 

VERSION 3............................................................................................................................................................224

TABLE 3-29. FIRE RETURN INTERVALS (FRI) BY HISTORIC FIRE REGIME GROUPS ACROSS THE PLANNING AREA..................................225

TABLE 3-30. WILDFIRE IGNITIONS WITHIN THE PLANNING AREA BY ACRE SIZE CLASS CATEGORIES, 1984–2013................................227

TABLE 3-31. AMOUNT OF DRY FORESTED VEGETATION TYPES IN THE INTERIOR/SOUTH PORTION OF THE PLANNING AREA INCLUDED IN 

DEPARTURE ANALYSIS..............................................................................................................................................233

TABLE 3-32. RESISTANCE TO STAND-REPLACEMENT FIRE BY STRUCTURAL STAGE .........................................................................243

TABLE 3-33. HARVEST LAND BASE ALLOCATIONS IN THE DRY FOREST IN THE INTERIOR/SOUTH.......................................................251
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TABLE 3-34. STAND-LEVEL FIRE HAZARD RATINGS BY STRUCTURAL STAGE ..................................................................................254

TABLE 3-35. TOTAL ACRES BURNED BY WILDFIRES WITHIN THE PLANNING AREA, 1984–2013 ......................................................258

TABLE 3-36. WILDLAND FIRE POTENTIAL ACRES FOR BLM-ADMINISTERED LANDS IN THE PLANNING AREA.......................................265

TABLE 3-37. RELATIVE WEIGHTING OF RESIDUAL SURFACE FUEL LOADING BY TIMBER MANAGEMENT TYPE AND INTENSITY...................266

TABLE 3-38. RISK CATEGORY BASED ON PREDICTED RESIDUAL ACTIVITY FUEL FOLLOWING HARVEST, PROXIMAL LOCATION TO WILDLAND 

DEVELOPMENT AREAS, AND WILDLAND FIRE POTENTIAL ...............................................................................................267

TABLE 3-39. CURRENT FIRE RISK CATEGORIES FOR BLM-ADMINISTERED LANDS..........................................................................267

TABLE 3-40. NON-COMMERCIAL NATURAL HAZARDOUS FUELS TREATMENT ACRES BY TREATMENT TYPE, 2003–2012 ......................270

TABLE 3-41. FEDERAL REGISTER NOTICES FOR LISTING STATUS, CRITICAL HABITAT DESIGNATION, AND ESA PROTECTIVE REGULATION FOR 

ESA-LISTED ANADROMOUS FISH IN THE PLANNING AREA................................................................................................278

TABLE 3-42. ESA-LISTED FISH SPECIES (OTHER THAN ANADROMOUS SALMONIDS) WITH MILES AND PERCENT OF CRITICAL HABITAT ON 

BLM-ADMINISTERED LANDS.....................................................................................................................................279

TABLE 3-43. DIAMETER OF FUNCTIONAL WOOD PIECE AS IT RELATES TO WIDTH OF ACTIVE STREAM CHANNEL...................................284

TABLE 3-44. ACRES IN EACH STRUCTURAL STAGE FOR STANDS WITHIN ONE SITE-POTENTIAL TREE HEIGHT FROM ALL STREAMS FOR THE 

CURRENT CONDITION AND IN 2113 ...........................................................................................................................287

TABLE 3-45. THINNING WITHIN THE RIPARIAN RESERVE BY DECADE .........................................................................................296

TABLE 3-46. STATE OF OREGON COLD-WATER PROTECTION CRITERIA FOR TROUT AND SALMON SPECIES..........................................300

TABLE 3-47. 2013 AGE CLASS DISTRIBUTION (10-YEAR INCREMENTS); FORESTED ACRES AND PERCENT...........................................310

TABLE 3-48. AVERAGE REGENERATION HARVEST AGE IN YEARS BY DECADE IN THE DECISION AREA ..................................................317

TABLE 3-49. PERCENTAGE OF HARVEST LAND BASE IN EACH LAND USE ALLOCATION CATEGORY.....................................................317

TABLE 3-50. STRUCTURAL STAGE CLASSIFICATION GENERALIZED DEFINITIONS.............................................................................318

TABLE 3-51. THE STANDING NET TIMBER INVENTORY AT EACH MEASUREMENT PERIOD ................................................................333

TABLE 3-52. 2006 AND 2013 SCRIBNER 16’ SCALE NET STANDING TIMBER VOLUME MMBF INVENTORY ESTIMATES ........................334

TABLE 3-53. PERCENT CHANGE IN INVENTORY BETWEEN 2013 AND 2113 BROKEN OUT BETWEEN THE HARVEST LAND BASE AND 

RESERVES IN THE DECISION AREA ...............................................................................................................................336

TABLE 3-54. REFERENCE ANALYSIS: “MANAGE MOST COMMERCIAL LANDS FOR MAXIMIZING TIMBER PRODUCTION” AND 1995 RMP

DECLARED ASQ.....................................................................................................................................................341

TABLE 3-55. FIRST DECADE ANNUAL ASQ* TIMBER HARVEST (MMBF/YEAR SCRIBNER 16’ SCALE) ...............................................341

TABLE 3-56. ESTIMATED REDUCTIONS TO ANNUAL ASQ FROM WILDLIFE SURVEYS AND SITE PROTECTION........................................346

TABLE 3-57. COMPATIBILITY OF SUSTAINED-YIELD MANAGEMENT REGIMES WITH VRM CLASSIFICATIONS........................................349

TABLE 3-58. TOTAL ANNUAL TIMBER HARVEST VOLUME FOR THE FIRST DECADE BY ASQ AND NON-ASQ SOURCES............................353

TABLE 3-59. ANNUAL NON-ASQ TIMBER HARVEST BY DECADE: COASTAL/NORTH VS. INTERIOR/SOUTH ..........................................355

TABLE 3-60. LOG SIZE GROUPS BY SMALL END DIAMETER INSIDE BARK DIAMETER CLASS ...............................................................356

TABLE 3-61. PERCENTAGE OF TOTAL TIMBER HARVEST VOLUME IN THE DECISION AREA BY LOG SIZE GROUP; FIRST 5 DECADES .............356

TABLE 3-62. AVERAGE DECADAL SILVICULTURAL TREATMENT ACCOMPLISHMENT ACRES IN THE DECISION AREA, 1996–2012 .............358

TABLE 3-63. SILVICULTURAL TREATMENT ACREAGES PER DECADE BASED ON AN AVERAGE OF THE FIRST TWO DECADES .......................362

TABLE 3-64. MODELED SHADE LOSS* FOR A 150-FOOT-WIDE RIPARIAN RESERVE, WITH A 60-FOOT INNER NO HARVEST ZONE, AT VARIOUS 

THINNING INTENSITIES AND INITIAL CANOPY CONDITIONS ...............................................................................................373

TABLE 3-65. MILES OF STREAMS WITH BLM OWNERSHIP WITHIN THE PLANNING AREA ...............................................................374

TABLE 3-66. POTENTIAL FINE SEDIMENT DELIVERY FROM EXISTING ROADS.................................................................................403

TABLE 3-67. BEST MANAGEMENT PRACTICES FOR ROAD AND LANDING CONSTRUCTION*..............................................................404

TABLE 3-68. PROPOSED RMP KEY MANAGEMENT DIRECTION FOR ROAD AND LANDING CONSTRUCTION AND MAINTENANCE*.............405

TABLE 3-69. SOURCE WATER PROTECTION..........................................................................................................................412

TABLE 3-70. NUMBER OF WATERSHEDS PER DISTRICT IN EACH SPECIES DISTRIBUTION CATEGORY ...................................................427

TABLE 3-71. RISK OF INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES ASSOCIATED WITH TIMBER HARVEST OVER THE NEXT 10

YEARS ..................................................................................................................................................................428

TABLE 3-72. RISK OF INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES INTO RIPARIAN HABITATS ASSOCIATED WITH TIMBER 

HARVEST ADJACENT TO THE RIPARIAN RESERVE OVER THE NEXT 10 YEARS .........................................................................431

TABLE 3-73. RISK OF INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES ASSOCIATED WITH NEW ROAD CONSTRUCTION OVER THE 

NEXT 10 YEARS......................................................................................................................................................433

TABLE 3-74. RISK OF INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES ASSOCIATED WITH PUBLIC MOTORIZED ACCESS

DESIGNATIONS.......................................................................................................................................................434

TABLE 3-75. RELATIVE RISK OF INTRODUCTION AND SPREAD OF INVASIVE PLANT SPECIES BY ANALYSIS FACTOR AND OVERALL...............438
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TABLE 3-76. RISK OF INTRODUCTION AND SPREAD OF INVASIVE AQUATIC SPECIES ASSOCIATED WITH NEW ROAD CONSTRUCTION BY 

SUBBASINS OVER THE NEXT 10 YEARS.........................................................................................................................447

TABLE 3-77. RISK OF INTRODUCTION AND SPREAD OF INVASIVE AQUATIC SPECIES ASSOCIATED WITH RMA DESIGNATIONS .................448

TABLE 3-78. RELATIVE RISK OF INTRODUCTION AND SPREAD OF INVASIVE AQUATIC SPECIES BY ANALYSIS FACTOR AND OVERALL ...........449

TABLE 3-79. SUDDEN OAK DEATH INFESTATIONS LEVELS BY INFESTATION ZONE OVER THE NEXT 10 AND 20 YEARS ............................454

TABLE 3-80. INITIAL SUDDEN OAK DEATH TREATMENT LEVELS OVER THE NEXT 10 AND 20 YEARS ...................................................455

TABLE 3-81. LAND TENURE ZONE WITHIN THE DECISION AREA BY ALTERNATIVE AND THE PROPOSED RMP ......................................459

TABLE 3-82. RIGHT-OF-WAY AVOIDANCE AND EXCLUSION AREAS IN THE DECISION AREA .............................................................462

TABLE 3-83. BLM-ADMINISTERED LANDS WITH WILDERNESS CHARACTERISTICS IN THE DECISION AREA ...........................................466

TABLE 3-84. INVENTORIED LANDS WITH WILDERNESS CHARACTERISTICS WITHIN THE DECISION AREA ALLOCATED TO THE DISTRICTDESIGNATED RESERVE – LANDS MANAGED FOR THEIR WILDERNESS CHARACTERISTICS ........................................................468

TABLE 3-85. INVENTORIED BLM-ADMINISTERED LANDS WITH WILDERNESS CHARACTERISTICS ALLOCATED TO THE HARVEST LAND BASE471

TABLE 3-86. INVENTORIED BLM-ADMINISTERED LANDS WITH WILDERNESS CHARACTERISTICS WITH INCOMPATIBLE RECREATION 

MANAGEMENT DESIGNATIONS ..................................................................................................................................472

TABLE 3-87. BLM-ADMINISTERED LIVESTOCK GRAZING ALLOTMENTS IN THE DECISION AREA.........................................................476

TABLE 3-88. CURRENT LIVESTOCK GRAZING LEVELS COMPARED TO 1995 RMP LEVELS................................................................477

TABLE 3-89. BLM-ADMINISTERED LIVESTOCK GRAZING ALLOTMENTS IN THE DECISION AREA THAT OVERLAP THE CASCADE SISKIYOU 

NATIONAL MONUMENT (CSNM).............................................................................................................................478

TABLE 3-90. LIVESTOCK GRAZING AVAILABILITY FOR THE COOS BAY DISTRICT, KLAMATH FALLS FIELD OFFICE, AND MEDFORD DISTRICT479

TABLE 3-91. ACRES OF SRMAS WITHIN AVAILABLE ALLOTMENTS WITHIN THE PLANNING AREA .....................................................483

TABLE 3-92. ACRES OF ACECS WITHIN AUTHORIZED ALLOTMENTS FOR EACH ALTERNATIVE AND THE PROPOSED RMP WITHIN THE 

PLANNING AREA.....................................................................................................................................................483

TABLE 3-93. RANGELAND HEALTH STANDARDS ASSESSMENTS FOR THE COOS BAY DISTRICT, KLAMATH FALLS FIELD OFFICE, AND 

MEDFORD DISTRICT ...............................................................................................................................................485

TABLE 3-94. ACRES OF SURFACE AND MINERAL ESTATE WITHIN THE DECISION AREA ....................................................................488

TABLE 3-95. ROCK QUARRY SITES IN THE DECISION AREA........................................................................................................493

TABLE 3-96. ACRES OF LANDS CURRENTLY CLOSED TO SALABLE MINERAL MATERIAL DISPOSAL (I.E., THE NO ACTION ALTERNATIVE) ......493

TABLE 3-97. ACRES CLOSED TO SALABLE MINERAL MATERIAL DISPOSAL IN THE DECISION AREA.......................................................494

TABLE 3-98. MINING CLAIMS, NOTICES, AND PENDING OR AUTHORIZED PLANS OF OPERATION IN THE DECISION AREA AS OF 2015......498

TABLE 3-99. ACRES OF LANDS PREVIOUSLY WITHDRAWN FROM LOCATABLE MINERAL ENTRY IN THE DECISION AREA...........................499

TABLE 3-100. ACRES THE BLM WOULD RECOMMEND FOR WITHDRAWAL FROM LOCATABLE MINERAL ENTRY AND PREVIOUSLY WITHDRAWN 

ACRES IN THE DECISION AREA....................................................................................................................................500

TABLE 3-101. ACRES THAT WOULD HAVE LEASABLE STIPULATIONS IN THE DECISION AREA FOR ACECS, RMAS, DISTRICT-DESIGNATED 

RESERVE – LANDS MANAGED FOR THEIR WILDERNESS CHARACTERISTICS, AND ELIGIBLE WSRS.............................................502

TABLE 3-102. PACIFIC CREST TRAIL MILEAGE BY OWNERSHIP WITHIN THE DECISION AREA ............................................................507

TABLE 3-103. CALIFORNIA NATIONAL SCENIC TRAIL-APPLEGATE TRAIL ROUTE MILEAGE BREAKDOWN BY OWNERSHIP WITHIN THE 

PLANNING AREA.....................................................................................................................................................508

TABLE 3-104. PACIFIC CREST TRAIL VIEWSHED RESULTS FOR BLM-ADMINISTERED LANDS WITHIN THE 5-MILE VIEWSHED DISTANCE OF 

TRAIL PORTIONS.....................................................................................................................................................510

TABLE 3-105. ACRES OF BLM-ADMINISTERED LANDS IN THE PLANNING AREA WITHIN PACIFIC CREST TRAIL NATIONAL TRAIL 

MANAGEMENT CORRIDOR.......................................................................................................................................513

TABLE 3-106. NATIONAL RECREATION TRAILS WITHIN THE PLANNING AREA ..............................................................................516

TABLE 3-107. BUREAU SENSITIVE AND STRATEGIC PLANT AND FUNGI SITES BY STATUS AND TAXONOMIC GROUP...............................524

TABLE 3-108. BUREAU SPECIAL STATUS, STRATEGIC, AND SURVEY AND MANAGE PLANT AND FUNGI SITES DOCUMENTED BETWEEN 

JANUARY 2009 AND JULY 2013 IN THE DECISION AREA.................................................................................................524

TABLE 3-109. NUMBER OF SURVEY AND MANAGE PLANT AND FUNGI SPECIES BY TAXONOMIC GROUP AND CATEGORY FOUND WITHIN THE 

PLANNING AREA USING THE CURRENT (2003) SURVEY AND MANAGE SPECIES LIST..............................................................531

TABLE 3-110. SURVEY AND MANAGE CATEGORIES AND ASSOCIATED SURVEY STATUS BY RARITY ....................................................531

TABLE 3-111. ESA-LISTED PLANTS WITHIN THE DECISION AREA...............................................................................................532

TABLE 3-112. BUREAU SPECIAL STATUS AND BUREAU STRATEGIC PLANT AND FUNGI SITES WITHIN THE HARVEST LAND BASE .............535

TABLE 3-113. SURVEY AND MANAGE PLANT AND FUNGI SPECIES SITES WITHIN THE HARVEST LAND BASE THAT ARE NOT ALSO BUREAU 

SENSITIVE/BUREAU STRATEGIC.................................................................................................................................536
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TABLE 3-114. PERCENT OF KNOWN BLM SITES WITHIN RESERVE ALLOCATIONS UNDER THE ALTERNATIVES AND THE PROPOSED RMP FOR 

SURVEY AND MANAGE SPECIES FOUND TO HAVE UNCERTAIN OUTCOMES IN THE 2004 FSEIS ...............................................539

TABLE 3-115. TOTAL ACRES OF TIMBER HARVEST IN THE FIRST DECADE (2013–2023)................................................................541

TABLE 3-116. BUREAU SPECIAL STATUS FUNGI POTENTIAL HABITAT WITHIN THE HARVEST LAND BASE ...........................................543

TABLE 3-117. BUREAU SPECIAL STATUS VASCULAR PLANT SITES WITHIN RESERVE ALLOCATIONS ....................................................543

TABLE 3-118. BUREAU SENSITIVE PLANTS WITHIN ALLOTMENTS NOT MEETING RANGELAND HEALTH STANDARDS DUE TO LIVESTOCK 

GRAZING ..............................................................................................................................................................544

TABLE 3-119. ROAD CONSTRUCTION MILES FOR THE FIRST 10 YEARS OF IMPLEMENTATION ..........................................................547

TABLE 3-120. ACRES OF OAK-DOMINANT PLANT COMMUNITIES WITHIN THE PLANNING AND DECISION AREAS..................................550

TABLE 3-121. DISTANCE CRITERIA FOR ESTABLISHING RECREATION OPPORTUNITY SPECTRUM CLASS BY REMOTENESS.........................557

TABLE 3-122. LEVEL OF HUMAN MODIFICATION AND FOREST STRUCTURAL STAGE CLASS PROXIES BY RECREATION OPPORTUNITY SPECTRUM 

CLASS FOR NATURALNESS.........................................................................................................................................559

TABLE 3-123. CURRENT SRMA ACRES OF MANAGED AND ALLOWED, AND RESTRICTED RECREATION OPPORTUNITIES WITHIN THE DECISION

AREA ...................................................................................................................................................................561

TABLE 3-124. CURRENT ACRES OF BLM-MANAGED LANDS BY REMOTENESS AND NATURALNESS RECREATION OPPORTUNITY SPECTRUM 

CLASSES ...............................................................................................................................................................561

TABLE 3-125. ACRES OF DESIGNATED SPECIAL RECREATION MANAGEMENT AREAS ....................................................................562

TABLE 3-126. ACRES OF DESIGNATED EXTENSIVE RECREATION MANAGEMENT AREAS.................................................................563

TABLE 3-127. RMA ACRES OF MANAGED AND ALLOWED RECREATION OPPORTUNITIES WITHIN THE DECISION AREA ..........................566

TABLE 3-128. RMA ACRES OF RESTRICTED RECREATION OPPORTUNITIES WITHIN THE DECISION AREA.............................................567

TABLE 3-129. ACRES OF BLM-ADMINISTERED LANDS BY RECREATION OPPORTUNITY SPECTRUM CLASSES FOR NATURALNESS ............568

TABLE 3-130. RIGHT-OF-WAY AVOIDANCE AREAS AND RIGHT-OF-WAY EXCLUSION AREAS WITHIN RMAS........................................569

TABLE 3-131. CURRENT AND PROJECTED LEVELS OF PARTICIPATION BY RECREATION ACTIVITY WITHIN THE PLANNING AREA FROM 2012 TO 

2060 ..................................................................................................................................................................571

TABLE 3-132. ACTIVITY-SPECIFIC RECREATION DEMAND FOR WESTERN OREGON COMMUNITIES....................................................574

TABLE 3-133. SUPPLY AND DEMAND FOR HIKING TRAILS WITHIN A 30-MINUTE DRIVING DISTANCE FROM STUDY COMMUNITIES ..........577

TABLE 3-134. SUPPLY AND DEMAND FOR HIKING TRAILS WITHIN A 60-MINUTE DRIVING DISTANCE FROM STUDY COMMUNITIES ..........577

TABLE 3-135. SUPPLY AND DEMAND FOR MOUNTAIN BIKE TRAILS WITHIN A 30-MINUTE DRIVING DISTANCE FROM STUDY COMMUNITIES

..........................................................................................................................................................................578

TABLE 3-136. SUPPLY AND DEMAND FOR MOUNTAIN BIKE TRAILS WITHIN A 60-MINUTE DRIVING DISTANCE FROM STUDY COMMUNITIES

..........................................................................................................................................................................579

TABLE 3-137. SUPPLY AND DEMAND FOR OHV TRAILS WITHIN A 30-MINUTE DRIVING DISTANCE FROM STUDY COMMUNITIES ............580

TABLE 3-138. SUPPLY AND DEMAND FOR OHV TRAILS WITHIN A 60-MINUTE DRIVING DISTANCES FROM STUDY COMMUNITIES...........580

TABLE 3-139. POTENTIAL RMA TRAIL MILES.......................................................................................................................581

TABLE 3-140. RECREATION VISITATION ESTIMATES WITH FULL IMPLEMENTATION IN 2062...........................................................583

TABLE 3-141. PLANNING AREA POPULATION, 1990–2012 ...................................................................................................588

TABLE 3-142. GOODS AND SERVICES DERIVED FROM BLM-ADMINISTERED LANDS IN WESTERN OREGON ........................................592

TABLE 3-143. HISTORICAL TIMBER SALE VALUES AND VOLUMES, WESTERN OREGON BLM DISTRICTS, 2000–2014 .........................606

TABLE 3-144. CURRENT MANAGED RECREATION ACREAGE OF BLM-ADMINISTERED LANDS ..........................................................609

TABLE 3-145. PUBLIC LAND OWNERSHIP SHARES IN 60-MINUTE DRIVING DISTANCES FROM STUDY COMMUNITIES ............................610

TABLE 3-146. NET ECONOMIC BENEFIT (CONSUMER SURPLUS) BY ACTIVITY, PER USER DAY (2012 DOLLARS) ...................................611

TABLE 3-147. TOTAL 2013 VISITOR-DAYS, BY ACTIVITY, TO ALL WESTERN OREGON BLM DISTRICTS, AND NET BENEFIT ESTIMATES (I.E.,

CONSUMER SURPLUS) (2012 DOLLARS)......................................................................................................................612

TABLE 3-148. TOTAL 2013 VISITOR-DAYS, BY BLM DISTRICT, AND ANNUAL NET BENEFIT ESTIMATES (I.E., CONSUMER SURPLUS) (2012

DOLLARS) .............................................................................................................................................................613

TABLE 3-149. SPECIAL FOREST PRODUCTS: PERMITS, MINIMUM PRICES, MARKET VALUES, AND REVENUE TO BLM (CY 2012 FOR ALL 

DISTRICTS)............................................................................................................................................................614

TABLE 3-150. LIVESTOCK GRAZING, NUMBER OF PERMITTEES, FORAGE, MARKET VALUE, AND BLM REVENUE, 2012.........................618

TABLE 3-151. SALABLE MINERAL MATERIALS, MARKET VALUE, AND REVENUE, 2012...................................................................620

TABLE 3-152. QUANTITY OF TOTAL CARBON STORED ON BLM-ADMINISTERED LANDS, ESTIMATED ANNUAL CARBON STORED, AND 

ESTIMATED VALUE (2012 DOLLARS) ..........................................................................................................................621

TABLE 3-153. WILLINGNESS TO PAY (WTP) VALUES PER HOUSEHOLD, BY SPECIES ......................................................................624

TABLE 3-154. ANNUAL WILLINGNESS TO PAY (WTP) VALUES PER HOUSEHOLD, BY SPECIES. .........................................................625
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TABLE 3-155. ANNUAL WILLINGNESS TO PAY (WTP) VALUES PER HOUSEHOLD TO PROTECT OLD-GROWTH HABITAT..........................625

TABLE 3-156. SUMMARY OF ECONOMIC VALUE OF GOODS AND SERVICES DERIVED FROM BLM-ADMINISTERED LANDS IN WESTERN 

OREGON, 2012 ....................................................................................................................................................629

TABLE 3-157. ANNUAL TOTAL* BLM HARVEST VOLUMES (SHORT LOG SCALE) OVER TIME............................................................629

TABLE 3-158. GROSS REVENUE, TOTAL COSTS, AND NET REVENUE, 2014–2023 ($ MILLIONS)....................................................632

TABLE 3-159. TIMBER STUMPAGE PRICES OVER TIME............................................................................................................639

TABLE 3-160. TIMBER GRADE 1 PROPORTION OVER TIME......................................................................................................639

TABLE 3-161. TOTAL ANNUAL AVERAGE HARVEST VALUES (MILLIONS) FOR SELECTED DECADES BY THE ALTERNATIVES AND THE PROPOSED 

RMP, 2023–2113 (2012 DOLLARS) .......................................................................................................................640

TABLE 3-162. MARKET EFFECTS ON OTHER TIMBERLAND OWNERS BY BLM HARVEST IN 2018 (2012 DOLLARS), LONG LOG SCALE ......641

TABLE 3-163. HARVESTS AND PRICES IN SHORT LOG SCALE.....................................................................................................641

TABLE 3-164. BLM RECREATION MANAGEMENT AREA ACRES ...............................................................................................642

TABLE 3-165. RECREATION OPPORTUNITIES, ACRES RESTRICTED (ACTIVITY EXCLUDED) WITHIN THE RMAS ......................................643

TABLE 3-166. POTENTIAL TRAIL MILES IN RMAS..................................................................................................................644

TABLE 3-167. RMA ACREAGE BY DRIVING DISTANCE FROM POPULATION CENTERS IN WESTERN OREGON*......................................644

TABLE 3-168. CONSUMER SURPLUS VALUE PROJECTIONS, 2023 AND NET PRESENT VALUE 2013–2062 (MILLIONS OF 2012 DOLLARS)

..........................................................................................................................................................................650

TABLE 3-169. VALUE OF CARBON STORAGE, 2012 DOLLARS ..................................................................................................653

TABLE 3-170. SUMMARY OF EFFECTS ON ECONOMIC VALUE OF GOODS AND SERVICES DERIVED FROM BLM-ADMINISTERED LANDS IN 

WESTERN OREGON................................................................................................................................................657

TABLE 3-171. TOTAL EMPLOYMENT AND EARNINGS BY DISTRICT MODEL AREA, 2012 (JOBS, MILLIONS OF 2012 DOLLARS) ................661

TABLE 3-172. FOREST PRODUCTS INDUSTRY EMPLOYMENT BY DETAILED SECTOR BY DISTRICT MODEL AREA, 2012 (JOBS)...................664

TABLE 3-173. FOREST PRODUCTS INDUSTRY EARNINGS BY DETAILED SECTOR BY DISTRICT MODEL AREA, 2012 (MILLIONS OF 2012

DOLLARS) .............................................................................................................................................................665

TABLE 3-174. EMPLOYMENT AND EARNINGS IN TIMBER- AND RECREATION-RELATED INDUSTRIES AS A SHARE OF TOTAL EMPLOYMENT AND 

EARNINGS BY DISTRICT MODEL AREA, 2012.................................................................................................................667

TABLE 3-175. TOTAL EMPLOYMENT AND EARNINGS CONTRIBUTION OF BLM PROGRAMS TO DISTRICT MODEL AREAS, 2012...............669

TABLE 3-176. TOTAL EMPLOYMENT CONTRIBUTION OF BLM TIMBER PROGRAMS TO FOREST PRODUCTS INDUSTRY BY DISTRICT MODEL 

AREA, 2012 (JOBS) ................................................................................................................................................670

TABLE 3-177. TOTAL EARNINGS CONTRIBUTION OF BLM TIMBER PROGRAMS TO FOREST PRODUCTS INDUSTRY BY DISTRICT MODEL AREA,

2012 (MILLIONS OF 2012 DOLLARS).........................................................................................................................671

TABLE 3-178. TOTAL EMPLOYMENT AND EARNINGS CONTRIBUTION OF BLM RECREATION PROGRAMS TO RECREATION-RELATED 

INDUSTRIES BY DISTRICT MODEL AREA, 2012...............................................................................................................672

TABLE 3-179. TOTAL EMPLOYMENT AND EARNINGS IN O&C COUNTIES GENERATED BY BLM-BASED FEDERAL PAYMENTS, 2012 (JOBS,

MILLIONS OF 2012 DOLLARS)...................................................................................................................................673

TABLE 3-180. TOTAL EMPLOYMENT AND EARNINGS IN O&C COUNTIES GENERATED BY BLM-BASED FEDERAL PAYMENTS, 2012 (JOBS,

MILLIONS OF 2012 DOLLARS)...................................................................................................................................674

TABLE 3-181. TOTAL EMPLOYMENT AND EARNINGS IN THE PLANNING AREA ..............................................................................678

TABLE 3-182. BLM-BASED TOTAL EMPLOYMENT AND EARNINGS BY DISTRICT MODEL AREA ..........................................................681

TABLE 3-183. BLM-BASED TOTAL EMPLOYMENT AND EARNINGS IN TIMBER-RELATED* INDUSTRIES AND RECREATION-RELATED2INDUSTRIES 

BY DISTRICT MODEL AREA.........................................................................................................................................683

TABLE 3-184. CURRENT AND PROJECTED TOTAL EMPLOYMENT BY DISTRICT MODEL AREA (AVERAGE ANNUAL JOBS, PERCENT) .............685

TABLE 3-185. SRS PAYMENTS TO COUNTIES, 2003–2012....................................................................................................692

TABLE 3-186. SRS PAYMENTS AND COUNTY REVENUES .........................................................................................................693

TABLE 3-187. COUNTY PAYMENTS IN 2012, ACTUAL PAYMENTS, AND PAYMENTS BASED ON O&C ACT FORMULA............................694

TABLE 3-188. TOTAL PAYMENTS TO O&C COUNTIES IN 2018 AND 2028.................................................................................695

TABLE 3-189. PAYMENTS TO O&C COUNTIES BY ALTERNATIVE AND THE PROPOSED RMP FOR 2018 AND 2028 (2012 DOLLARS).....696

TABLE 3-190. GROWTH AND VOLATILITY OF EMPLOYMENT AND EARNINGS BY GEOGRAPHIC AREA AND SELECTED RESOURCE-RELATED 

INDUSTRIES OVER SIX UNITED STATES BUSINESS CYCLES, 1969–2007..............................................................................700

TABLE 3-191. SELECTED COMMUNITIES (CITIES AND TRIBES) FOR ANALYSIS OF CAPACITY AND RESILIENCY........................................706

TABLE 3-192. CAPACITY AND RESILIENCY METRICS................................................................................................................712

TABLE 3-193. CAPACITY AND RESILIENCY DATA SUMMARY .....................................................................................................717

TABLE 3-194. CHANGE IN BLM-BASED EMPLOYMENT FOR DISTRICT MODEL AREAS.....................................................................719
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TABLE 3-195. EFFECTS OF CHANGE IN BLM-BASED EMPLOYMENT BY COMMUNITY.....................................................................719

TABLE 3-196. SHARES OF COUNTY PAYMENTS BY BLM DISTRICT .............................................................................................721

TABLE 3-197. COUNTY PAYMENTS IN 2018 (2012 DOLLARS) ................................................................................................721

TABLE 3-198. POTENTIAL EFFECTS OF COUNTY PAYMENTS BY COMMUNITY ...............................................................................722

TABLE 3-199. RACIAL MINORITY AND HISPANIC POPULATION CHANGE, 2000–2012..................................................................726

TABLE 3-200. POVERTY POPULATION AND MEDIAN HOUSEHOLD INCOME, 2000 AND 2012 ........................................................727

TABLE 3-201. SUMMARY OF MINORITY POPULATIONS MEETING ENVIRONMENTAL JUSTICE CRITERIA...............................................728

TABLE 3-202. SUMMARY OF LOW-INCOME POPULATIONS MEETING ENVIRONMENTAL JUSTICE CRITERIA..........................................732

TABLE 3-203. ESTIMATED TIMBER PROGRAM COSTS PER MBF OF TIMBER VOLUME.....................................................................737

TABLE 3-204. BLM BUDGET BY DISTRICT, FY 2012 .............................................................................................................737

TABLE 3-205. BLM EMPLOYEES BY DISTRICT; CURRENT CONDITION AND THE AVERAGE OF THE FIRST DECADE...................................738

TABLE 3-206. BLM BUDGET BY DISTRICT; CURRENT CONDITION AND THE AVERAGE OF THE FIRST DECADE .......................................738

TABLE 3-207. DETRIMENTAL SOIL DISTURBANCE FROM TIMBER HARVEST AND BY HARVEST METHOD DURING THE FIRST DECADE FOR THE

COASTAL/NORTH AND INTERIOR/SOUTH .....................................................................................................................751

TABLE 3-208. ACRES OF CUMULATIVE DETRIMENTAL SOIL DISTURBANCE FROM ROAD CONSTRUCTION DURING THE FIRST DECADE ........754

TABLE 3-209. ACRES OF DETRIMENTAL SOIL DISTURBANCE FROM ROAD CONSTRUCTION BY ROAD TYPE DURING THE FIRST DECADE.......755

TABLE 3-210. FUEL TREATMENTS BY METHOD, 2003–2012 .................................................................................................760

TABLE 3-211. DETRIMENTAL SOIL DISTURBANCE FROM FUEL TREATMENTS BY METHOD, 2003–2012............................................760

TABLE 3-212. DETRIMENTAL SOIL DISTURBANCE FROM FUELS TREATMENTS COMPARED TO THE CURRENT CONDITION........................761

TABLE 3-213. DETRIMENTAL SOIL DISTURBANCE FROM ALL SOURCES, BY THE CURRENT CONDITION AND DURING THE FIRST DECADE .....764

TABLE 3-214. BIOMASS AVAILABLE FROM BLM-ADMINISTERED LANDS AS TIMBER HARVEST SLASH................................................771

TABLE 3-215. RIGHT-OF-WAY EXCLUSION AND AVOIDANCE AREAS...........................................................................................772

TABLE 3-216. ACRES THAT WOULD HAVE LEASABLE STIPULATIONS...........................................................................................774

TABLE 3-217. EXISTING 1995 RMP PUBLIC MOTORIZED ACCESS DESIGNATIONS WITHIN THE DECISION AREA...................................777

TABLE 3-218. PUBLIC MOTORIZED ACCESS DESIGNATIONS......................................................................................................781

TABLE 3-219. AREAS CLOSED TO PUBLIC MOTORIZED ACCESS BY LAND USE ALLOCATION OR DESIGNATION .......................................783

TABLE 3-220. MILES OF BLM-MANAGED ROADS WITHIN THE DECISION AREA BY FUNCTIONAL CLASSIFICATION ................................786

TABLE 3-221. ROAD CONDITION, MILEAGE, REPLACEMENT VALUE, AND DEFERRED MAINTENANCE BACKLOG....................................787

TABLE 3-222. BRIDGE CONDITION, REPLACEMENT VALUE, AND DEFERRED MAINTENANCE BACKLOG ...............................................787

TABLE 3-223. MAJOR CULVERT CONDITION, REPLACEMENT VALUE, AND DEFERRED MAINTENANCE BACKLOG...................................787

TABLE 3-224. FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS..........................................................789

TABLE 3-225. FIRST DECADE NEW ROAD CONSTRUCTION ASSOCIATED WITH HARVEST METHODS....................................................789

TABLE 3-226. NO ACTION FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS..........................................790

TABLE 3-227. ALTERNATIVE A FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS ....................................790

TABLE 3-228. ALTERNATIVE B FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS ....................................790

TABLE 3-229. ALTERNATIVE C FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS.....................................791

TABLE 3-230. ALTERNATIVE D FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS ....................................791

TABLE 3-231. PROPOSED RMP FIRST DECADE NEW ROAD CONSTRUCTION BY ROAD SURFACING AND STATUS...................................791

TABLE 3-232. FIRST DECADE PERMANENT ROAD CLOSURE......................................................................................................792

TABLE 3-233. FIRST DECADE LONG-TERM ROAD CLOSURE ......................................................................................................792

TABLE 3-234. FIRST DECADE EXISTING ROAD RENOVATION AND IMPROVEMENT .........................................................................793

TABLE 3-235. FIRST DECADE EXISTING ROAD UTILIZATION BY SURFACE TYPE...............................................................................794

TABLE 3-236. FIRST DECADE PAVED ROAD MAINTENANCE FEE COLLECTIONS COMPARED TO ANNUAL MAINTENANCE (AM) NEED.........794

TABLE 3-237. FIRST DECADE ROCKED ROAD MAINTENANCE FEE COLLECTIONS COMPARED TO ANNUAL MAINTENANCE (AM) NEED .......795

TABLE 3-238. FIRST DECADE PAVED AND ROCK-SURFACED ROADS RENOVATION EXPENDITURES COMPARED TO THE DEFERRED 

MAINTENANCE (DM) BACKLOG.................................................................................................................................796

TABLE 3-239. MILEAGE OF NEW ROAD CONSTRUCTION AND ROAD RENOVATION OR IMPROVEMENT ..............................................809

TABLE 3-240. VISUAL RESOURCE INVENTORY CLASS DISTRIBUTION IN THE DECISION AREA†...........................................................816

TABLE 3-241. ACRES OF VISUAL RESOURCE MANAGEMENT CLASSES IN THE DECISION AREA .........................................................817

TABLE 3-242. VISUAL RESOURCE INVENTORY CLASS DESIGNATIONS BY MANAGEMENT CLASS .......................................................819

TABLE 3-243. COMPATIBILITY OF SUSTAINED YIELD MANAGEMENT REGIMES WITH VRM CLASSIFICATIONS ......................................821

TABLE 3-244. THE HARVEST LAND BASE WITHIN EACH VISUAL RESOURCE INVENTORY CLASS........................................................822

TABLE 3-245. BALD EAGLE MANAGEMENT AREAS WITHIN THE DECISION AREA..........................................................................825
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TABLE 3-246. CURRENT CONDITION IN 2013 OF HABITAT EXPRESSED BY STRUCTURAL STAGE .......................................................836

TABLE 3-247. LAND USE ALLOCATIONS OF EXISTING (2013) MATURE OR STRUCTURALLY-COMPLEX HABITAT IN THE DECISION AREA ....842

TABLE 3-248. NUMBER OF SPECIES* THAT WOULD HAVE AN INCREASE IN HABITAT BY 2063 BY STRUCTURAL STAGE ASSOCIATION†

(PERCENT OF SPECIES IN GROUP)...............................................................................................................................843

TABLE 3-249. NUMBER OF SPECIES* THAT WOULD HAVE AN INCREASE IN HABITAT BY 2063 (PERCENT OF SPECIES IN GROUP).............845

TABLE 3-250. SIZE OF THE RESERVES WITHIN THE DECISION AREA ............................................................................................850

TABLE 3-251. DEER MANAGEMENT AREAS ON BLM-ADMINISTERED LANDS ..............................................................................867

TABLE 3-252. ELK MANAGEMENT AREAS ON BLM-ADMINISTERED LANDS.................................................................................867

TABLE 3-253. CURRENT FISHER HABITAT IN THE DECISION AND PLANNING AREAS........................................................................874

TABLE 3-254. FISHER HABITAT PATCH METRICS....................................................................................................................876

TABLE 3-255. FISHER POPULATION IN THE PLANNING AREA IN 50 YEARS...................................................................................879

TABLE 3-256. GOLDEN EAGLE BREEDING AREAS WITHIN THE PLANNING AREA ............................................................................882

TABLE 3-257. CURRENT MARBLED MURRELET NESTING HABITAT .............................................................................................901

TABLE 3-258. LAND USE ALLOCATIONS OF MARBLED MURRELET TOTAL NESTING HABITAT IN 2013 ................................................905

TABLE 3-259. LAND USE ALLOCATIONS OF HIGH-QUALITY MARBLED MURRELET NESTING HABITAT IN 2013 .....................................905

TABLE 3-260. MARBLED MURRELET NESTING HABITAT PATCH METRICS ....................................................................................905

TABLE 3-261. DECADAL FORECAST FOR MARBLED MURRELET NESTING HABITAT CONSIDERED FOR HARVEST OVER 50 YEARS (2013–2063)

..........................................................................................................................................................................910

TABLE 3-262. MARBLED MURRELET NESTING HABITAT MODELED FOR HARVEST THAT WOULD BE SUBJECT TO SURVEYS PRIOR TO HARVEST

..........................................................................................................................................................................910

TABLE 3-263. MARBLED MURRELET NESTING HABITAT MODELED FOR HARVEST THAT WOULD NOT BE SUBJECT TO SURVEYS ................911

TABLE 3-264. KNOWN MARBLED MURRELET SITES IN THE PLANNING AREA ................................................................................914

TABLE 3-265. DECADAL FORECAST FOR MARBLED MURRELET OCCUPIED SITES LOST OVER 50 YEARS (2013–2063)..........................915

TABLE 3-266. DECADAL FORECAST FOR MARBLED MURRELET OCCUPIED SITES DISCOVERED OVER 50 YEARS (2013–2063)................915

TABLE 3-267. KNOWN OBSERVATIONS (395) OF RED TREE VOLES WITHIN THE NORTH OREGON COAST DPS...................................924

TABLE 3-268. LAND USE ALLOCATIONS WITHIN THE NORTH OREGON COAST DPS (348,186 ACRES OF BLM-ADMINISTERED LANDS)..924

TABLE 3-269. EXISTING RED TREE VOLE HABITAT AND FORECAST OF OCCUPIED STANDS WITHIN THE NORTH OREGON COAST DPS WITHIN 

THE HARVEST LAND BASE ........................................................................................................................................925

TABLE 3-270. METRICS TO IDENTIFY BLOCKS OF NORTHERN SPOTTED OWL NESTING-ROOSTING HABITAT.........................................934

TABLE 3-271. METRICS TO IDENTIFY AND MAP LARGE BLOCKS OF NORTHERN SPOTTED OWL NESTING-ROOSTING HABITAT ..................934

TABLE 3-272. ESTIMATED (OBSERVED) AND MODIFIED BARRED OWL ENCOUNTER RATES..............................................................952

TABLE 3-273. NO TIMBER HARVEST REFERENCE ANALYSIS: NORTHERN SPOTTED OWL RANGE-WIDE POPULATIONS (MEAN OF 500

REPLICATE NON-STOCHASTIC SIMULATIONS) BY YEAR.....................................................................................................957

TABLE 3-274. NO TIMBER HARVEST REFERENCE ANALYSIS: SIMULATED NORTHERN SPOTTED OWL POPULATIONS (MEAN OF 500 REPLICATE 

NON-STOCHASTIC SIMULATIONS), BY MODELING REGION AND YEAR..................................................................................957

TABLE 3-275. NO TIMBER HARVEST REFERENCE ANALYSIS: SIMULATED NORTHERN SPOTTED OWL POPULATIONS (MEAN OF 500 REPLICATE 

NON-STOCHASTIC SIMULATIONS), BY PHYSIOGRAPHIC PROVINCE AND YEAR........................................................................957

TABLE 3-276. NO TIMBER HARVEST REFERENCE ANALYSIS: ACRES OF HABITAT STRONGLY AVOIDED BY THE NORTHERN SPOTTED OWL IN 

MOIST FOREST LAND USE ALLOCATIONS RESERVED UNDER THE NORTHWEST FOREST PLAN, AND IN MOIST FOREST CRITICAL HABITAT 

UNITS, ON BLM-ADMINISTERED LANDS IN THE PLANNING AREA.......................................................................................975

TABLE 3-277. ACRES OF RESERVE LAND USE ALLOCATIONS THAT WOULD BE AFFECTED BY HIGH- AND MODERATE-INTENSITY WILDFIRE 

DURING EACH DECADE.............................................................................................................................................980

TABLE 3-278. ACRES OF NORTHERN SPOTTED OWL CRITICAL HABITAT THAT WOULD BE AFFECTED BY HIGH- AND MODERATE-INTENSITY 

WILDFIRE DURING EACH DECADE ...............................................................................................................................981

TABLE 3-279. ACRES AND PERCENTAGES OF NORTHERN SPOTTED OWL CRITICAL HABITAT ON BLM-ADMINISTERED LANDS IN THE HARVEST 

LAND BASE ...........................................................................................................................................................991

TABLE 3-280. OREGON SPOTTED FROG HABITAT IN THE DECISION AND PLANNING AREAS ...........................................................1003

TABLE 3-281. DESIGNATED CRITICAL HABITAT FOR THE PACIFIC COAST DPS OF THE WESTERN SNOWY PLOVER...............................1007

TABLE 3-282. DESIGNATED WILD AND SCENIC RIVERS WITHIN THE PLANNING AREA .................................................................1026

TABLE 3-283. 1995 RMPS SUITABLE WILD AND SCENIC RIVERS WITHIN THE PLANNING AREA....................................................1026

TABLE 3-284. ALL ELIGIBLE RIVER SEGMENTS WITHIN THE DECISION AREA ...............................................................................1029

TABLE 3-285. ELIGIBLE RIVERS WITHIN THE DECISION AREA THAT THE BLM IDENTIFIED AS MEETING SUITABILITY CRITERIA ................1030

TABLE 3-286. ELIGIBLE RIVER SEGMENT PROTECTION TOTALS WITHIN THE DECISION AREA..........................................................1031
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TABLE 3-287. RIVER SEGMENTS NOT RECOMMENDED FOR INCLUSION IN THE NATIONAL SYSTEM RECEIVING INCIDENTAL PROTECTION 

FROM MINERAL AND RIGHT-OF-WAY MANAGEMENT ...................................................................................................1033

TABLE 3-288. ELIGIBLE RIVER SEGMENT CORRIDORS WITH OVERLAPPING SCENERY ORVS AND VRM CLASS I OR II, WHERE THE RIVER 

SEGMENT IS NOT RECOMMENDED FOR INCLUSION INTO THE NATIONAL SYSTEM................................................................1034

TABLE 3-289. ELIGIBLE RIVER SEGMENT CORRIDORS WITH OVERLAPPING ACEC DESIGNATIONS WHERE THE RIVER SEGMENT IS NOT 

RECOMMENDED FOR INCLUSION IN THE NATIONAL SYSTEM ..........................................................................................1036

TABLE 3-290. ELIGIBLE RIVER SEGMENTS WITH RECREATION ORVS AND OVERLAPPING RECREATION MANAGEMENT AREA DESIGNATIONS,

WHERE THE RIVER SEGMENT IS NOT RECOMMENDED FOR INCLUSION INTO THE NATIONAL SYSTEM.......................................1037

TABLE 3-291. ELIGIBLE RIVER SEGMENTS THAT HAVE CORRIDOR OVERLAP WITH THE HARVEST LAND BASE LAND USE ALLOCATION WHERE 

THE RIVER SEGMENT IS NOT RECOMMENDED FOR INCLUSION INTO THE NATIONAL SYSTEM .................................................1038

TABLE 3-292. PUBLIC MOTORIZED ACCESS DESIGNATION DESIGNATIONS FOR ELIGIBLE RIVER SEGMENTS .......................................1039

TABLE 4-1. FORMAL COOPERATORS.................................................................................................................................1046

TABLE 4-2. LIST OF KEY PROJECT STAFF .............................................................................................................................1053
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Summary

This summary presents a brief description of the major elements of this document. This summary is 

necessarily neither comprehensive nor complete. Furthermore, this summary omits the citations, 

definitions, and explanations provided in the document. Therefore, the details in the four chapters of this 

document are essential to understanding fully the planning process, the alternatives and the Proposed 

RMP, and their effects.

Introduction

The Bureau of Land Management (BLM) is revising the resource management plans (RMPs) for its Coos 

Bay, Eugene, Medford, Roseburg, and Salem Districts, and the Klamath Falls Field Office of the 

Lakeview District. This Proposed RMP/Final Environmental Impact Statement (Proposed RMP/Final 

EIS) provides a description of the various alternative management approaches the BLM is considering for 

the management of these lands along with an analysis of the potential effects of the alternatives and the 

Proposed RMP.

The 1995 RMPs are consistent with the 1994 Northwest Forest Plan, which the Department of the Interior 

and the Department of Agriculture adopted for Federal forests within the range of the northern spotted 

owl. This RMP revision would replace the 1995 RMPs and thereby replace the Northwest Forest Plan for 

the management of BLM-administered lands in western Oregon. The purpose and need for this RMP 

revision are different from the purpose and need for the Northwest Forest Plan. As such, the action

alternatives and the Proposed RMP in this Proposed RMP/Final EIS do not contain all elements of the 

Northwest Forest Plan.

The BLM conducted plan evaluations, which concluded that a plan revision is needed to address the 

changed circumstances and new information that has led to a substantial, long-term departure from the 

timber management outcomes predicted under the 1995 RMPs. Moreover, the BLM needs to revise 

existing plans to replace the 1995 RMPs’ land use allocations and management direction because of new 

scientific information and policies related to the northern spotted owl.

The purpose of the RMP revision is to—

 Provide a sustained yield of timber;

 Contribute to the conservation and recovery of threatened and endangered species, including—

o Maintaining a network of large blocks of forest to be managed for late-successional 

forests; and

o Maintaining older and more structurally-complex multi-layered conifer forests;

 Provide clean water in watersheds;

 Restore fire-adapted ecosystems;

 Provide recreation opportunities; and

 Coordinate management of lands surrounding the Coquille Forest with the Coquille Tribe.

The Alternatives and the Proposed RMP

The BLM designed the range of alternatives in the Draft RMP/EIS to span the full spectrum of 

alternatives that would respond to the purpose and need for the action. The BLM developed the 

alternatives to represent a range of overall management approaches, rather than exemplify gradations in 

design features. In the Draft RMP/EIS, the BLM analyzed in detail the No Action alternative and four 
xxiv | P a g e

action alternatives. In addition, the BLM analyzed how two sub-alternatives, which modify an individual 

component of northern spotted owl conservation in an alternative, would alter effects on timber 

production and northern spotted owls. The BLM is carrying forward the action alternatives and subalternatives as presented in the Draft RMP/EIS into the Proposed RMP/Final EIS.

The No Action alternative is implementation of the 1995 RMPs as written (in contrast to the BLM’s 

current implementation practices under the 1995 RMPs). Implementation of the timber management 

program has departed substantially from the outcomes predicted in the 1995 RMPs, and continuing to 

harvest timber at the declared annual productive capacity level for multiple decades into the future would 

not be possible using the current practices.

The action alternatives and the Proposed RMP include the following land use allocations: 

Congressionally Reserved Lands and National Landscape Conservation System, District-Designated 

Reserves, Late-Successional Reserve, Riparian Reserve, Harvest Land Base, and Eastside Management 

Area (Figure i). The location and acreage of these allocations, with the exception of Congressionally 

Reserved Lands, vary by alternative and the Proposed RMP. Within the action alternatives and the 

Proposed RMP, the Harvest Land Base, Late-Successional Reserve, and Riparian Reserve have specific, 

mapped sub-allocations with differing management direction.

Alternative A has a Late-Successional Reserve larger than the No Action alternative. The Harvest Land 

Base is comprised of the Uneven-aged Timber Area and the High Intensity Timber Area. The High 

Intensity Timber Area includes regeneration harvest with no retention (i.e., clearcuts).

Alternative B has a Late-Successional Reserve similar in size to Alternative A, though of a different 

spatial design. The Harvest Land Base is comprised of the Uneven-aged Timber Area, Low Intensity 

Timber Area, and Moderate Intensity Timber Area. The portion of the Harvest Land Base in Uneven-aged 

Timber Area is the largest of the action alternatives. The Low Intensity Timber Area and Moderate 

Intensity Timber Area include regeneration harvest with varying levels of retention.

Sub-alternative B is identical to Alternative B, except that it includes protection of habitat within the 

home ranges of all northern spotted owl known and historic sites.

Alternative C has the largest Harvest Land Base of any of the alternatives. The Harvest Land Base is 

comprised of the Uneven-aged Timber Area and the High Intensity Timber Area. The High Intensity 

Timber Area includes regeneration harvest with no retention (i.e., clearcuts). Alternative C has the 

smallest acreage in the Riparian Reserve of the action alternatives.

Sub-alternative C is identical to Alternative C, except that the Late-Successional Reserve includes all 

stands 80 years old and older.

Alternative D has the smallest Late-Successional Reserve of any of the action alternatives. The Harvest 

Land Base is comprised of the Uneven-aged Timber Area, Owl Habitat Timber Area, and Moderate 

Intensity Timber Area. The Owl Habitat Timber Area includes timber harvest applied in a manner that 

would maintain northern spotted owl habitat. The Moderate Intensity Timber Area includes regeneration 

harvest with retention. Alternative D has the largest acreage in the Riparian Reserve of all of the action 

alternatives.

The Proposed RMP

The BLM has developed the Proposed RMP as a variation on Alternative B, which the BLM identified in 

the Draft RMP/EIS as the preferred alternative. The Proposed RMP has a Late-Successional Reserve that 
xxv | P a g e

is a refinement of the Late-Successional Reserve design in Alternative B and is within the spectrum of 

Late-Successional Reserve designs of the action alternatives. The Harvest Land Base is comprised of the 

Uneven-aged Timber Area, Low Intensity Timber Area, and Moderate Intensity Timber Area, as in

Alternative B. The geographic extent of the portion of the Harvest Land Base in Uneven-aged Timber 

Area in the Proposed RMP is intermediate between Alternative B and Alternative C. As in Alternative B, 

the Low Intensity Timber Area and Moderate Intensity Timber Area include regeneration harvest with 

varying levels of retention.

To reduce the risk of adverse effects to ESA-listed fish and water quality compared to Alternative B, the 

Proposed RMP includes a Riparian Reserve design that is intermediate among the alternatives and 

incorporates elements of each of the alternatives. The Proposed RMP carries forward the concept of key 

watersheds from the No Action alternative, in that it varies riparian management based on the importance 

of the subwatershed to the conservation and recovery of ESA-listed fish. For fish-bearing streams and 

perennial streams in all subwatersheds, the Riparian Reserve design is similar to Alternative D. For nonfish-bearing intermittent streams, the Riparian Reserve design in Class I and II subwatersheds is a slight 

modification of Alternative A, and the Riparian Reserve design in Class III subwatersheds is similar to

Alternative C.

To increase protection of unique recreation settings and increase recreation use compared to Alternative 

B, the Proposed RMP includes an approach to the management of recreation resources modified from 

Alternative C.

To increase protection of identified lands with wilderness characteristics compared to Alternative B, the 

Proposed RMP includes an approach to the management of lands with wilderness characteristics from 

Alternative A.

To minimize the spread of sudden oak death compared to Alternative B, the Proposed RMP includes the

sudden oak death treatment approach of the No Action alternative, Alternative C, and Alternative D.

Table i summarizes key features of the alternatives and the Proposed RMP that vary substantially and are 

easily quantified and summarized.
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Table i. Key features of the alternatives and the Proposed RMP

Alternative/

Proposed RMP

Total LateSuccessional

Reserve

(Acres)

Protection of

Structurallycomplex Forest

Riparian Reserve

Total Width

Riparian Reserve

Inner Zone Width

Marbled Murrelet

Survey and Protection

No Action 478,860 None specified

2 SPTH* on fish-bearing streams;

1 SPTH* on non-fish-bearing 

streams

None specified

Survey in Zones 1 and 2;

protect contiguous recruitment 

and existing habitat within 1/2

mile of sites

Alt. A 1,147,527 ≥ 120 years 1 SPTH* on all streams

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

None

Alt. B 1,127,320 District-defined map 

based on existing, 

district-specific 

information

1 SPTH* on perennial and fishbearing streams;

100’ on debris-flow-prone nonfish-bearing intermittent streams;

50’ on other non-fish-bearing 

intermittent streams

60’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

Survey in Zone 1;

protect contiguous habitat within 

300’ of sites Sub. B 1,422,933

Alt. C 949,279 ≥ 160 years 150’ on perennial and fishbearing streams;

50’ on non-fish-bearing streams

60’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

Survey stands >120 years;

protect contiguous habitat within 

300’ of sites

Sub. C 1,373,206 ≥ 80 years None

Alt. D 714,292

≥ 120/140/160 years 

on high/moderate/low 

productivity sites

1 SPTH* on all streams 120’ on all streams

Survey in Zones 1 and 2;

protect habitat within 1/2 mile of 

sites

PRMP 948,466

District-defined map 

based on existing, 

district-specific 

information (updated 

from Alternative B)

Class I and II subwatersheds:

1 SPTH* on all streams

Class I subwatersheds:

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams;

Middle zone from 50’ to 120’ on non-fishbearing intermittent streams

Survey nesting habitat in all land 

use allocations in Zone 1, survey 

nesting habitat in reserve land use 

allocations in Zone 2;

protect contiguous habitat within 

300’ of sites

Class III subwatersheds:

1 SPTH* on perennial and fishbearing streams;

50’ on non-fish-bearing 

intermittent streams

Class II and III subwatersheds:

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

* Site-potential tree height
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Alternative/

Proposed RMP

Total

Harvest

Land Base

(Acres)

Green Tree Retention

Areas of Critical

Environmental

Concern

(Number

Designated)

Recreation Management Areas

DistrictDesignated

ReserveLands

Managed for

their

Wilderness

Characteristics

(Acres)

Wild and Scenic Rivers

Recommended for National

System Inclusion

(Number of River Segments)

Special

Recreation

Management

Area

(Acres)

Extensive

Recreation

Management

Area

(Acres)

No Action 691,998

GFMA†: 6–8 TPA‡

Connectivity/Diversity:

12–18 TPA‡

Southern GFMA†:

16–25 TPA

86

(and 55 potential) 168,968 2,397,460 -

-

(all 51 eligible would continue 

receiving interim protections)

Alt. A 343,900 No retention 107 20,065 - 79,709 -

Alt. B 556,335 Low Intensity Timber Area:

15–30% retention

Moderate Intensity Timber 

Area: 5–15% retention

105 24,972 139,320 76,525 6

Sub. B 298,121

Alt. C 741,332

No retention 101 59,046 357,771 66,190 6

Sub. C 495,507

Alt. D 650,382

Owl Habitat Timber Area: 

maintain owl habitat

Moderate Intensity Timber 

Area: 5–15% retention

107 86,693 580,458 - 51

PRMP 469,215

Low Intensity Timber Area:

15–30% retention

Moderate Intensity Timber 

Area: 5–15% retention

108 70,730 420,311 79,107 6

† GFMA = General Forest Management Area

‡ TPA = Trees per acre
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Figure i. Land use allocations under the alternatives and the Proposed RMP 

LateSuccessional 

Reserve

19% Other 

Reserves

9%

Matrix

28%

Eastside 

Management 

Area

6%

Riparian 

Reserve

38%

LateSuccessional 

Reserve

46%

Other 

Reserves

7%

Harvest 

Land Base

14%

Eastside 

Management 

Area

6%

Riparian 

Reserve

27%

LateSuccessional 

Reserve

46%

Other 

Reserves

11%

Harvest 

Land Base

22%

Eastside 

Management 

Area

6%

Riparian 

Reserve

15%

LateSuccessional 

Reserve

38%

Other 

Reserves

11%

Harvest 

Land Base

30%

Eastside 

Management 

Area

6%

Riparian 

Reserve

15%

LateSuccessional 

Reserve

29%

Other 

Reserves

10%

Harvest 

Land Base

26%

Eastside 

Management 

Area

6%

Riparian 

Reserve

29%

LateSuccessional 

Reserve

38%

Other 

Reserves

11%

Harvest 

Land Base

19%

Eastside 

Management 

Area

6%

Riparian 

Reserve

26%

No Action* Alternative A

Alternative B Alternative C

Alternative D Proposed RMP

* No action displays modified hierarchy (see Chapter 2)
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Affected Environment and Environmental 

Consequences

This section summarizes the existing conditions and environmental consequences for each resource that 

the RMPs are likely to affect. Throughout this document, the BLM uses the term ‘planning area’ to refer 

to the 22 million acres of land within the geographic boundary of this planning effort regardless of 

jurisdiction, and uses the term ‘decision area’ to refer to the 2.5 million acres of BLM-administered lands

within the planning area.

Air Quality

The action alternatives and the Proposed RMP would produce more particulate emissions than the No 

Action alternative and current conditions. However, adherence to the requirements of the Oregon Smoke 

Management Plan would continue to limit impacts to human health and visibility from prescribed fires.

Areas of Critical Environmental Concern

The alternatives and the Proposed RMP consider the designation of 131 potential Areas of Critical 

Environmental Concern. The Proposed RMP would designate the most and Alternative C the fewest areas 

as Areas of Critical Environmental Concern at 108 and 101, respectively.

Climate Change

Carbon storage would increase under the alternatives and the Proposed RMP. Greenhouse gas emissions 

associated with BLM-administered lands would increase under the alternatives and the Proposed RMP, 

but would remain less than 1 percent of the 2010 statewide greenhouse gas emissions. Climate change 

provides uncertainty that reserves will function as intended and that planned timber harvest levels can be

attained, with the uncertainty increasing over time.

Cultural and Paleontological Resources

The BLM can reduce or eliminate effects to cultural and paleontological resources through systematic and 

thorough cultural and paleontological resource inventories. Implementation of Alternatives A and D 

would be the least likely to result in potential adverse impacts to cultural and paleontological resources.

Fire and Fuels

The action alternatives and the Proposed RMP would increase stand-level fire resistance and reduce 

wildfire hazard on BLM-administered lands compared to current conditions. The BLM-administered 

lands constitute only a small portion of the entire interior/south dry forest landscape. Consequently, the 

modest shifts under the alternatives and the Proposed RMP would not result in any substantial change in 

the overall landscape fire resilience. The dry forest landscape would continue to have an overabundance 

of mid-seral closed forest and a deficit of late-seral open forest.

Fisheries

The alternatives and the Proposed RMP would increase the potential large wood and small functional 

wood contribution to streams from the current conditions over time. Sediment production from road 

construction and operation would increase by less than one percent under the alternatives and the 

Proposed RMP, and the effects to fish would not differ at this scale of analysis. These effects to fish 

would be short-term and localized and could result from increases in turbidity or deposition of fines in the 

stream channel substrates affecting habitat.
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Forest Management

Even-aged systems with clear-cutting would produce more uniform stands in a mix of age classes without 

structural legacies. Two-aged systems with variable-retention regeneration harvesting would produce 

stands in a mix of age classes with legacy structures and multiple canopy layers. Uneven-aged 

management systems with selection harvesting regimes would produce mostly older, structurally-complex 

stands and mature forests with multiple canopy layers.

The allowable sale quantity (ASQ) of timber under the alternatives and the Proposed RMP would range 

from 120 million board feet (MMbf) per year under Sub-alternative B to 486 MMbf per year under 

Alternative C. Non-ASQ timber harvest volumes in the first decade would range from 4 MMbf per year 

under Alternative D to 122 MMbf per year under the No Action alternative. The ASQ under the Proposed 

RMP would be 205 MMbf per year, and the non-ASQ would be 73 MMbf per year in the first decade.

Hydrology

Under the No Action alternative, Alternatives A and D, and the Proposed RMP, less than 0.5 percent of 

all perennial and fish-bearing stream reaches in the decision area would currently be susceptible to shade 

reductions that could affect stream temperature if the BLM applies thinning in the outer zone of the 

Riparian Reserve. Under Alternative B and C, approximately 5 percent of all perennial and fish-bearing 

reaches in the decision area would currently be susceptible to shade reductions that could affect stream 

temperature if the BLM applies thinning in the outer zone of the Riparian Reserve.

Under all alternatives and the Proposed RMP, potential sediment delivery to streams from new road 

construction would constitute less than a 1 percent increase above current levels of fine sediment delivery 

from existing roads. Less than 2 percent of the decision area would be susceptible to peak flow increases 

over time under any alternative or the Proposed RMP. Less than 1 percent of the Harvest Land Base 

would be susceptible to landsliding with the potential to deliver sediment to streams over time under the

alternatives and the Proposed RMP.

Invasive Species

The risk of introducing and spreading invasive plant species over the next 10 years, and in the long term, 

would be lowest under Alternative D, and highest under Alternatives B and C. The No Action alternative, 

Alternatives C and D, and the Proposed RMP would result in the smallest increase in sudden oak death

infestation, because the BLM would treat all detected infestations.

Lands and Realty

Under all alternatives and the Proposed RMP, BLM-administered lands would generally be available for

rights-of-way. Alternative D would most constrain the BLM’s ability to grant rights-of-way compared to

the current conditions.

Lands with Wilderness Characteristics

Alternative A and the Proposed RMP would provide the largest protection of identified lands with 

wilderness characteristics within the decision area. Alternatives B and C would provide intermediate 

protection of lands identified with wilderness characteristics within the decision area. Alternative D 

provides no protection of lands identified with wilderness characteristics with the decision area.

Livestock Grazing

Under Alternatives A, B, and C, public land available for livestock grazing would decrease from 490,047

acres to 366,231 acres. This change would occur through the BLM making 47 allotments or leases

unavailable for grazing. Under the Proposed RMP, the BLM-administered lands available for livestock 
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grazing would decrease from 490,047 acres to 360,303 acres. This change would occur through the BLM 

making 51 allotments or leases unavailable for grazing. Under Alternative D, the BLM would no longer 

authorize livestock grazing within the decision area, a change that would affect 490,047 acres. This 

change would occur through the BLM terminating existing grazing authorizations and making all 

allotments unavailable for grazing.

Minerals

Under the action alternatives and the Proposed RMP, the BLM would recommend for withdrawal from 

locatable mineral entry between 6 and 8 percent of the decision area, in addition to the 4 percent already 

withdrawn. Approximately 90 percent of the decision area would remain open to locatable mineral entry

and salable mineral material disposal. All of the decision area would remain open to leasable mineral

development.

National Trails System

Alternative D would provide the largest National Trail Corridor and protect the largest number of acres of 

BLM-administered lands within the viewshed. However, these acres only account for 9 percent of all 

viewable acres. Under the Proposed RMP, the BLM would administer 23 percent of the visible acres of 

BLM-administered lands within the viewshed as the Pacific Crest Trail’s National Trail Management 

Corridor.

Rare Plants and Fungi

Only two ESA-listed plant species occur within forest and woodland habitat in the decision area:

Kincaid’s lupine and Gentner’s fritillary; the BLM would conduct pre-disturbance surveys and apply 

conservation measures for these species. The BLM would manage Bureau Sensitive plant and fungi 

species under the Bureau’s Special Status Species program under all alternatives and the Proposed RMP. 

Species that are currently Survey and Manage and not included on the Bureau Sensitive species list would 

receive no specific protections under any action alternative or the Proposed RMP.

Recreation and Visitor Services

Alternative A would provide a reduction in recreation opportunities when compared to the existing 

management situation. Alternative D would provide the largest number and acres of recreation 

management areas in closest proximity to the twelve most populated communities in the planning area.

The Proposed RMP would provide more acres allocated as recreation management areas than Alternatives 

A, B, and C, and fewer acres than Alternative D.

Socioeconomics

BLM-administered lands provide a wide variety of market and non-market goods and services to the 

planning area such as timber, recreation, carbon storage, minerals, and source water protection. The 

annual harvest value of timber, compared to $23 million in 2012, would increase under all alternatives

and the Proposed RMP, from $37 million under Alternative D to $135 million under Alternative C. Under 

the Proposed RMP, the annual harvest value of timber would increase to $51 million. Using non-market 

valuation techniques, recreation on BLM-administered lands had a value of $223 million in 2012. Based 

on a phased recreation development timeline of 50 years, the value of recreation in 2023 would range 

from $243 million under Alternative A to $278 million under Alternative D. Under the Proposed RMP, 

the value of recreation in 2023 would be $271 million. Assuming a 20-year phase-in period rather than a 

50-year period, the value of recreation in 2023 would range from $230 to $331 million, with the Proposed 

RMP value at $311 million. Carbon storage on BLM-administered lands had a value of $85 million in 

2012. The annual value of net carbon storage would increase under the Proposed RMP and all alternatives 

except Alternative C, under which it would fall to $43 million. Under the Proposed RMP, the annual 

value of net carbon storage would increase to $159 million in 2022.
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In 2012, BLM management contributed 7,900 jobs and $355 million in earnings to the planning area, 

which is about 0.4 percent of the total jobs and earnings. Under the action alternatives, these contributions 

from BLM management would range from a low of 7,100 jobs and $310 million in earnings (Alternative 

D) to a high of 12,200 jobs and $573 million in earnings (Alternative C). Under the Proposed RMP, 

contributions from BLM management would be 8,500 jobs and $330 million in earnings. Employment 

effects to low-income populations in Coos and Curry Counties would be disproportionately negative 

under Alternatives A, B, and D, and the Proposed RMP. Under Alternative D, employment effects in 

Douglas and Klamath Counties would also be disproportionately negative. Low-income communities and 

Tribes in these counties would be vulnerable to these disproportionately negative effects.

There is uncertainty regarding the source and amounts of future payments to counties from activities on 

BLM-administered lands. Congress has not authorized payments under the Secure Rural Schools and 

Community Self-Determination Act (SRS) beyond 2016. SRS payments to counties totaled $38 million in 

2012. Had payments in 2012 been based on the O&C Act formula, they would have been $12 million. 

Under the action alternatives, assuming payments were based on the formula in the O&C Act, payments 

in 2018 would range from a low of $19 million under Alternative D, to a high of $67 million under 

Alternative C. The Proposed RMP would result in payments of $26 million.

Soil Resources

All alternatives and the Proposed RMP would increase the acreage of detrimental soil disturbance from 

timber harvest, road construction, and fuels treatments by 13–29 percent of current amounts during the 

first decade. The BLM would be able to reduce the acreage of detrimental soil conditions from timber 

harvest, road construction, and fuels treatments through management practices that would limit initial 

compaction levels, remove existing or created compacted surfaces, and improve soil water and organic 

matter levels.

Sustainable Energy

Under the alternatives and the Proposed RMP, the majority of the land in the decision area would be

available for the potential development of sustainable energy resources. While there is no current 

geothermal development and limited potential in the decision area, the action alternatives and the 

Proposed RMP would be less constraining to geothermal development than the current condition.

Trails and Travel Management

The action alternatives and the Proposed RMP would increase the acreage designated as closed for public 

motorized access and decrease the acreage designated as open for public motorized access when 

compared to the No Action alternative.

Tribal Interests

An ongoing dialogue between BLM representatives and designated Tribal representatives and their 

leadership produced the issues addressed in the Tribal Interests section. A large portion of the tribally 

identified issues are covered under specific resource sections (e.g., fish, water, socioeconomics, and

cultural resources), though the effects specific to tribal communities may differ due to the unique 

relationships that Tribes have with the landscape and resources on it.

Visual Resources Management

Under the action alternatives and the Proposed RMP, visual landscape character would be subject to 

change and would result in a reduction to the scenic resource value over time. The BLM would manage a 

substantial acreage of land at a less protective Visual Resource Management class than what would be 

commensurate with the assigned Visual Resource Inventory class. Alternative D would provide the most
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protection, and Alternatives A, B, and C would provide the least protection of visual resources. The 

Proposed RMP would provide more protection of visual resources within the decision area than

Alternatives B and C, and less protection than Alternatives A and D and the No Action alternative.

Wildlife

Northern spotted owl

The northern spotted owl population is under severe biological stress in much of western Oregon and has 

an even chance of being extirpated from the Coast Range within 20 years. This population risk is 

predominately due to competitive interactions between northern spotted owls and barred owls. Under 

current barred owl encounter rates, the BLM has no opportunity through habitat management alone in the 

Coast Range to reduce risks to the northern spotted owl during the next 50 years, and there are no 

substantive differences among the alternatives and the Proposed RMP in their potential effects from 

habitat management on those risks. However, in the western Cascades and Klamath Basin, the BLM 

would contribute to self-sustaining northern spotted owl populations during the next 50 years under the 

alternatives and the Proposed RMP. Under the Proposed RMP, the BLM would participate in, cooperate 

with, and provide support for an interagency program for barred owl management to implement Recovery 

Action 30 when the U.S. Fish and Wildlife Service determines the best manner in which barred owl 

management can contribute to the recovery of the northern spotted owl. Additionally, under the Proposed 

RMP, the BLM would not authorize timber sales that would cause the incidental take of northern spotted 

owls from timber harvest until implementation of a barred owl management program has begun.

Marbled Murrelet

All alternatives would result in an increase in the amount of marbled murrelet high-quality nesting habitat 

and total nesting habitat in 50 years. Alternatives A, B, and C would result in the loss of 106, 23, and 189

future marbled murrelet sites, respectively, because of timber harvest in the Harvest Land Base in the 

absence of surveys. The Proposed RMP would result in the loss of 13 future marbled murrelet sites 

because of timber harvest in the Harvest Land Base in the absence of surveys.

Wild Horses

The Pokegama herd is the only wild horse herd in the decision area and is currently 40 percent over 

appropriate management level of 30–50 horses. Alternative D, which would eliminate livestock grazing, 

would reduce competition for forage and provide the potential for increased growth of the Pokegama 

herd. Otherwise, the alternatives and the Proposed RMP would not differ in their effects on the Pokegama 

herd.

Wild and Scenic Rivers

Under the No Action alternative, the BLM would continue to manage the 51 eligible Wild and Scenic 

River segments under interim management to protect their Outstandingly Remarkable Values (ORVs), 

water quality, free-flowing characteristics, and tentative classification as Wild, Scenic, or Recreational 

until suitability is determined during subsequent land use planning efforts. Under Alternative A, the BLM 

would not recommend any of the 51 eligible Wild and Scenic River segments for inclusion into the 

National System, resulting in impacts to all eligible river segments and their associated values. Under 

Alternatives B and C, and the Proposed RMP, the BLM would recommend the 6 eligible Wild and Scenic 

River segments determined to be suitable. Under Alternative D, the BLM would recommend all 51 

eligible Wild and Scenic River segments for inclusion into the National System, resulting in the largest 

protection for all segments and their associated river values.
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Consultation and Coordination

The preparation of the Draft RMP/EIS included 38 public involvement efforts, including formal scoping, 

regional workshops on recreation management, community listening sessions, and public meetings about 

the Planning Criteria and preliminary alternatives.

On April 24, 2015, the BLM released the Draft RMP/EIS, announcing, at that time, a 90-day comment 

period that would conclude on July 23, 2015. On July 13, 2015, the BLM extended the comment period 

on the Draft RMP/EIS until August 21, 2015. During the comment period, the BLM held 17 scheduled 

public meetings in May and June of 2015. These meetings included open houses in Roseburg, 

Springfield, Salem, Klamath Falls, Medford, Coos Bay, and Portland. These public meetings also 

included workshops on socioeconomics in Salem and Roseburg, workshops on recreation in Roseburg, 

Grants Pass, Salem, and Springfield, workshops on forest management and wildlife in Salem and 

Medford, and a workshop on riparian management in Springfield. The BLM also held a public meeting 

with an invitation for elected officials in Salem. The BLM received approximately 4,500 comments on 

the Draft RMP/EIS during the comment period.

The BLM is consulting on a government-to-government level with the nine federally recognized Tribes 

located within, or that have interests within, the planning area. The Confederated Tribes of Grand Ronde, 

the Confederated Tribes of Siletz Indians, the Coquille Indian Tribe, the Confederated Tribes of Coos, 

Lower Umpqua, and Siuslaw Indians, the Cow Creek Band of Umpqua Tribe of Indians, and the Klamath 

Tribes are formal cooperators in the RMP revisions, in addition to their government-to-government status.

The BLM has been assisted in the preparation of the Proposed RMP/Final EIS by a Cooperating Agency 

Advisory Group, which includes representatives of Federal and State agencies, counties, and Tribes. In 

addition to meeting as a full group periodically throughout the development of the Draft RMP/EIS and

the Proposed RMP/Final EIS, the Cooperating Agency Advisory Group also created five working groups 

in order to facilitate a more detailed level of engagement with the BLM on the following topics: aquatics, 

outreach, terrestrial, socio-economics, and tribal issues.

Working through a robust engagement process with neutral facilitation, the cooperators have provided 

expertise on much of the subject matter the BLM is addressing in the Proposed RMP/Final EIS, as well as 

advice based on experience with similar planning efforts. The cooperators have provided feedback on 

public outreach sessions, data sources and analytical methods, and components of the alternatives. They 

have provided oral and written feedback and ideas throughout the process of developing the Draft 

RMP/EIS and the Proposed RMP/Final EIS. Nearly all cooperators have been positive about the level of 

engagement and the general direction of the planning process. However, the Association of O&C 

Counties (which is the designated representative of 15 counties) has continued to express a high level of 

concern about the BLM’s planning process. Specifically, the Association of O&C Counties continues to 

assert that the BLM’s Purpose and Need statement was fatally flawed by failing to place sustained 

sustained-yield timber production as the primary purpose of the planning effort.

The BLM district managers and planning personnel have met with individual county commissioners on 

an ongoing basis to provide updates on progress and key milestones. As noted above, several county 

governments are formal cooperators in the planning process. While the Association of O&C Counties 

represents most of the counties at the Cooperating Agency Advisory Group meetings, BLM district 

managers also maintain relationships with local county representatives.

The BLM has begun consultation with the U.S. Fish and Wildlife Service and the National Marine 

Fisheries Service under Section 7(a)(2) of the Endangered Species Act (ESA) and will complete 

consultation before signing Records of Decision for the RMP revision. The BLM, U.S. Fish and Wildlife 
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Service, and National Marine Fisheries Service signed an ESA Consultation Agreement, which identifies 

responsibilities for each agency and defines the processes, products, actions, timeframe, and expectations 

for the consultation process.
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Chapter 1 – Introduction 

The Bureau of Land Management (BLM) is revising the resource management plans (RMPs) for its Coos 

Bay, Eugene, Medford, Roseburg, and Salem Districts, and the Klamath Falls Field Office of the 

Lakeview District (1995 RMPs; USDI BLM 1995 a, b, c, d, e, f). This Proposed RMP/Final 

Environmental Impact Statement (Proposed RMP/Final EIS) provides a description and analysis of the 

management approach that the BLM is proposing for these lands, along with the various alternative 

management approaches that the BLM analyzed in the Draft RMP/EIS. 

In 2012, the BLM conducted an evaluation of the 1995 RMPs in accordance with its planning regulations, 

which require that RMPs “shall be revised as necessary based on monitoring and evaluation findings, new 

data, new or revised policy and changes in circumstances affecting the entire plan or major portions of the 

plan” (43 CFR 1610.5–6). This evaluation contains the conclusion that “[a] plan revision is needed to 

address the changed circumstances and new information that has led to a substantial, long-term departure 

from the timber management outcomes predicted under the 1995 RMPs” (USDI BLM 2012a, p. 12). 

Included in this evaluation was the identification of new information related to northern spotted owls, 

(including new demographic studies, the Revised Recovery Plan for the Northern Spotted Owl (Strix 

occidentalis caurina)(owl recovery plan; USDI FWS 2011), and revision of critical habitat by the U.S. 

Fish and Wildlife Service (77 FR 71875)), and the BLM concluded that the EIS supporting the 1995 

RMPs contains outdated analysis relative to the development of suitable habitat for the northern spotted 

owl (USDI BLM 2012, p. 14). From this evaluation, the BLM identified a need to modify or update 

management direction for most of the other resource management programs due to changed 

circumstances and new information. 

Summary of Notable Changes from the Draft RMP/EIS 

Chapter 1 of this Proposed RMP/Final EIS—

• Expands the discussion in “Relationship of the RMPs to Other Plans and Programs” to address 

the relationship of the Proposed RMP to the Aquatic Conservation Strategy in the Northwest 

Forest Plan, and 

• Updates the list of existing decisions that will be carried forward into the RMPs. 

The Planning Area 

The planning area includes approximately 2.5 million acres of BLM-administered lands in western 

Oregon managed by the BLM’s Coos Bay, Eugene, Medford, Roseburg, and Salem Districts and the 

Klamath Falls Field Office of the Lakeview District (Map 1-1).
2 | Page

INSERT 

Map 1-1. Major ownerships within the planning area 
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Throughout this document, the BLM will use the term ‘planning area’ to refer to all lands within the 

geographic boundary of this planning effort regardless of jurisdiction. However, the BLM will only make 

decisions on lands that fall under BLM jurisdiction (including mineral estate). The BLM will use the term 

‘decision area’ to refer to the lands within the planning area for which the BLM has authority to make 

land use and management decisions. In general, the BLM has jurisdiction over all BLM-administered 

lands (surface and subsurface) and over mineral estate in areas of split estate (i.e., areas where the BLM 

administers Federal mineral estate, but the surface is not administered by the BLM). 

Within the western Oregon offices, three BLM-administered areas are not included in the decision area: 

the Cascade Siskiyou National Monument (Medford District), the Upper Klamath Basin and Wood River 

Wetland (Klamath Falls Field Office), and the West Eugene Wetlands (Eugene District). These areas have 

independent RMPs, and this revision process will not alter these independent RMPs. 

Planning Process 

The BLM integrates its planning process with its compliance with the National Environmental Policy Act 

(NEPA; 42 U.S.C. 4321 et seq.), which requires that Federal agencies prepare an environmental impact 

statement (EIS) for all actions that significantly affect the quality of the human environment. The BLM 

planning regulations direct: “Approval of a resource management plan is considered a major Federal 

action significantly affecting the quality of the human environment. The environmental analysis of 

alternatives and the proposed plan shall be accomplished as part of the resource management planning 

process and, wherever possible, the proposed plan and related environmental impact statement shall be 

published in a single document” (43 CFR 1601.0–6). Therefore, the BLM presents this Proposed RMP 

integrated with the Final Environmental Impact Statement as a single document (Proposed RMP/Final 

EIS). 

Preparing a RMP involves the following nine interrelated actions or steps: 

1. Conduct scoping and identify issues. 

2. Collect inventory data. 

3. Analyze management situation. 

4. Develop planning criteria. 

5. Formulate alternatives. 

6. Analyze effects of alternatives. 

7. Select the preferred alternative; issue Draft RMP/EIS. 

8. Issue Proposed RMP/Final EIS. 

9. Sign Record of Decision. 

The BLM has prepared a single Proposed RMP/Final EIS for the revision of the RMPs for the Coos Bay, 

Eugene, Medford, Roseburg, and Salem Districts and the Klamath Falls Field Office of the Lakeview 

District. At this time, the BLM anticipates issuing two Records of Decision/Resource Management Plans 

(RODs/RMPs): one ROD/RMP that would apply to the Coos Bay District, Eugene District, Salem 

District, and the Swiftwater Field Office of the Roseburg District; and another ROD/RMP that would 

apply to the Klamath Falls Field Office of the Lakeview District, the Medford District, and the South 

River Field Office of the Roseburg District. 

Decision to be Made 

Through this effort, the BLM will decide on an approach to managing the public land it administers in 

western Oregon. As described in the Federal Land Policy and Management Act (FLPMA; 43 U.S.C, 

1701(a)(2)), RMPs are tools by which “present and future use is projected.” The BLM’s planning 
4 | P a g e

regulations make clear that RMPs are a preliminary step in the overall process of managing public lands, 

and are “designed to guide and control future management actions and the development of subsequent, 

more detailed and limited scope plans for resources and uses” (43 CFR 1601.0–2).

The major provisions of the RMPs will include the following land use plan decisions:

• Objectives for the management of BLM-administered lands and resources;

• Land use allocations relative to future uses for the purposes of achieving the various objectives; 

and

• Management direction that identifies where future actions may or may not be allowed and what 

restrictions or requirements may be placed on those future actions to achieve the objectives set for 

the BLM-administered lands and resources.

Management objectives are descriptions of desired outcomes for BLM-administered lands and resources

in an RMP; the resource conditions that the BLM envisions or desires would eventually result from 

implementation of the RMP. As such, management objectives are not rules, restrictions, or requirements 

by which the BLM determines which implementation actions to conduct or how to design specific 

implementation actions.

Through the RMPs, the BLM will determine and declare the annual productive capacity for sustainedyield timber production.1 The annual productive capacity is the timber volume that a forest can produce 

continuously under the intensity of management described in the RMPs for those lands allocated for 

sustained-yield timber production. The BLM will make the determination and declaration of the annual 

productive capacity for each of the six sustained yield units, which match the five western Oregon BLM 

district boundaries and the western portion of the Klamath Falls Field Office in the Lakeview District.2

The determination of the annual productive capacity includes compliance with other laws and 

consideration of the objectives, land use allocations, and management direction of the RMPs, which affect 

the amount of timber that each of the sustained yield units can produce. Chapter 3 contains additional 

discussion of the determination of the annual productive capacity under Vegetation Modeling Products.

In both the 1995 RMPs and in the 2008 RMPs, the BLM identified that there would be some level of 

variation in the annual amount of timber offered for sale. In this plan revision process, the BLM will 

consider whether the plan will include some level of variation in the amount of sustained-yield timber 

volume that the BLM will offer on an annual basis or over a longer period of time. In making a decision 

about the extent to which the plan will identify such variation in the amount of sustained-yield timber 

volume to be offered, the BLM will take into account a number of factors, including the availability of 

resources and compliance with applicable law, among other agency considerations. The BLM would 

identify the level of variation in the amount of sustained-yield timber volume that may be offered as part 

of the declaration of the annual productive capacity in this RMP.

The Proposed RMP does not include any implementation decisions to be included in the eventual Records 

of Decision/RMPs.3 That is, the BLM anticipates that all of the decisions in the Records of 

Decision/RMPs will be land use plan decisions.

 

1 The terms ‘annual productive capacity,’ ‘annual sustained yield capacity,’ ‘sustained yield capacity,’ and 

‘allowable sale quantity’ are synonymous.

2 The BLM is in the process of consolidating the Eugene District and Salem District under a single administrative 

and operational unit with one District Manager. This consolidation does not alter the Eugene sustained-yield unit or 

the Salem sustained-yield unit, and these sustained-yield units remain the basis upon which the BLM determines and 

declares the ASQ.

3

Implementation decisions authorize implementation of on-the-ground projects. Land use plan decisions (land use 

allocations, management objectives, and management direction) do not directly authorize implementation of on-theground projects. Land use plan decisions guide and control future implementation decisions, which can be carried 
5 | P a g e

Purpose and Need for Action

The purpose and need statement describes why the BLM is revising the 1995 RMPs and what outcomes 

the BLM intends the RMPs to achieve. The purpose and need statement defines the range of alternatives 

that will be analyzed in the planning process, because alternatives must respond to the purpose and need 

for action to be considered reasonable.

The proposed action is to revise the 1995 RMPs with land use allocations, management objectives, and 

management direction that best meet the purpose and need.

This plan revision process takes place against the backdrop of past planning efforts. These previous 

planning efforts and their supporting analyses, including the Record of Decision for the Northwest Forest 

Plan (USDA FS and USDI BLM 1994a), the 1995 RMPs (the plans currently in effect; USDI BLM 1995 

a, b, c, d, e, f), and the 2008 RMPs (which are no longer in effect; USDI BLM 2008 a, b, c, d, e, f), 

together with the results of the scoping process for this planning effort help to inform the BLM’s 

discretion in determining the purpose and need for this action and to identify the scope of alternatives and 

impacts that need to be explored in this planning effort.

Need for the Action

The BLM conducted plan evaluations in accordance with its planning regulations, which require that 

RMPs “shall be revised as necessary based on monitoring and evaluation findings, new data, new or 

revised policy and changes in circumstances affecting the entire plan or major portions of the plan” (43 

CFR 1610.5–6). These evaluations concluded that “[a] plan revision is needed to address the changed 

circumstances and new information that has led to a substantial, long-term departure from the timber 

management outcomes predicted under the 1995 RMPs” (USDI BLM 2012a, p. 12). These evaluations 

also concluded that the management direction for most of the other resource management programs need 

to be modified or updated because of changed circumstances and new information. These evaluations 

concluded that changes are particularly indicated for the fisheries, aquatics, recreation, off-highway 

vehicle, and fire and fuels programs.

Moreover, the BLM needs to revise existing plans to replace the 1995 RMPs’ land use allocations and 

management direction because of new scientific information and policies related to the northern spotted 

owl. Since the 1995 RMPs were approved, there have been analyses on the effects of land management 

on northern spotted owl habitat, demographic studies, and analyses of the effects of barred owls on 

northern spotted owls. In addition, since that time, new policies for northern spotted owls have been put 

in place, including a revised recovery plan and a new designation of critical habitat.

Purpose of the Action

The purpose of this proposed action is to make land use plan decisions to guide the management of BLMadministered lands.

Several of the purposes of the action are necessary for the BLM to be able to deliver a predictable supply 

of timber from the BLM-administered lands, based on the BLM’s almost two decades of experience 

implementing the Northwest Forest Plan, new scientific information, and the advice of other Federal 

 

out only after completion of further appropriate NEPA analysis or documentation, consultation, and decisionmaking processes.
6 | P a g e

agencies, as discussed below. Harvesting timber on a sustained-yield basis for the Oregon and California 

Railroad and Coos Bay Wagon Road Grant Lands Act (O&C Act; 43 U.S.C. 1181a et seq.) purposes is 

required under the O&C Act. Harvesting timber on a sustained-yield basis ensures that the BLM will 

achieve the purposes of the O&C Act, which include continuing to be able to provide, over the long term, 

a sustained volume of timber within the management direction in the RMP. Declining populations of 

species now listed under the Endangered Species Act (16 U.S.C. 1531 et seq.) have caused the greatest 

reductions and instability in the BLM’s supply of timber in the past. Any further population declines of 

listed species or new species listings would likely lead to additional reductions in timber harvest. 

Contributing to the conservation and recovery of listed species is essential to delivering a predictable 

supply of timber. Specifically, the BLM recognizes that providing large, contiguous blocks of latesuccessional forest and maintaining older and more structurally-complex multi-layered conifer forests are 

necessary components of the conservation and recovery of the northern spotted owl. Providing clean 

water is essential to the conservation and recovery of listed fish, and a failure to protect water quality 

would lead to restrictions that would further limit the BLM’s ability to provide a predictable supply of 

timber. Furthermore, the O&C Act recognizes the importance of water quality; the purposes of sustained 

yield include, among others, “protecting watersheds and regulating stream flow.” Finally, in fire-prone 

ecosystems in southern Oregon, the BLM must manage forests to reduce the likelihood of catastrophic 

fires and the attendant loss of timber. These purposes require the BLM to exercise its discretion to 

determine how best to achieve sustained-yield timber production over the long term and avoid future 

limitations on timber production.

Provide a Sustained Yield of Timber

The purpose of the action includes providing a sustained yield of timber. The O&C Act requires that the 

revested Oregon and California Railroad Grant lands and reconveyed Coos Bay Wagon Road Grant lands 

(O&C lands) be managed “for permanent forest production, and the timber thereon shall be sold, cut, and 

removed in conformity with the principal of sustained yield for the purpose of providing a permanent 

source of timber supply, protecting watersheds, regulating stream flow, and contributing to the economic 

stability of local communities and industries, and providing recreational facilities” (43 U.S.C. 1181a). The 

O&C Act goes on to state that “[t]he annual productive capacity for such lands shall be determined and 

declared ... [p]rovided, [t]hat timber from said lands ... not less than the annual sustained yield capacity 

... shall be sold annually, or so much thereof as can be sold at reasonable prices on a normal market.” In 

meeting the various requirements for managing the O&C lands, the Secretary of the Interior has discretion 

under the O&C Act to determine how to manage the forest to provide for permanent forest production on 

a sustained-yield basis, including harvest methods, rotation length, silvicultural regimes under which 

these forests would be managed, or minimum level of harvest. In addition, the FLPMA specifically 

provides that if there is any conflict between its provisions and the O&C Act related to management of 

timber resources or the disposition of revenues from the O&C lands and resources, the O&C Act prevails 

(i.e., takes precedence) (43 U.S.C. 1701 note (b)). Thus, the multiple-use management direction of the 

FLPMA does not apply to the O&C lands that are suitable for timber production. The planning process 

established by the FLPMA is applicable to the O&C lands, because it is not in conflict with the O&C 

Act’s management direction for those lands.

For the public domain lands, the FLPMA requires that public lands be managed “on the basis of multiple 

use and sustained yield unless otherwise specified by law” (43 U.S.C. 1701 [Sec. 102.a.7]). The FLPMA 

also requires that “the public lands be managed in a manner which recognizes the Nation’s need for 

domestic sources of minerals, food, timber, and fiber from the public lands” (43 U.S.C. 1701 [Sec. 

102.a.12]).
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Conservation and Recovery of Threatened and Endangered 

Species

The purpose of the action includes contributing to the conservation and recovery of threatened and 

endangered species within the planning area, including the northern spotted owl, marbled murrelet, and 

threatened and endangered anadromous fish. The Endangered Species Act requires agencies to ensure that 

their actions are not likely to jeopardize the continued existence of ESA-listed species or result in the 

adverse modification or destruction of critical habitat. Since the adoption of the Northwest Forest Plan, 

BLM has recognized that additional species listings could have the effect of further limiting the BLM’s 

ability to provide a sustained yield of timber under the O&C Act (USDA FS and USDI BLM 1994a, pp. 

49–50). Using its discretion and authority under the O&C Act and the FLPMA, the BLM can direct 

sustained-yield management of the O&C lands and public domain lands in western Oregon in a manner 

that contributes to the conservation and recovery of ESA-listed species and helps limit or avoid future 

listings, and thereby best ensures a permanency of timber production over the long term, while, among 

other benefits of sustained yield, contributing to the economic stability of local communities.

The purpose of contributing to the conservation and recovery of the northern spotted owl necessarily 

includes maintaining a network of large blocks of forest to be managed for late-successional forests and 

maintaining older and more structurally-complex multi-layered conifer forests, based on the existing 

scientific information on the conservation needs of the northern spotted owl and the results of previous 

analyses as described below.

Large, Contiguous Blocks of Late-successional Forests

Large, contiguous blocks of late-successional forest have been an element of northern spotted owl

conservation strategies for over two decades. Thomas et al. (1990, pp. 23–27) described that a 

conservation strategy for the northern spotted owl requires large blocks of nesting, roosting, and foraging 

habitat (i.e., suitable habitat) that support clusters of reproducing owls, distributed across a variety of 

ecological conditions and spaced so as to facilitate owl movement between the blocks. Courtney et al. 

(2004, pp. 9-11, 9-15), in the status review for the northern spotted owl, evaluated the conservation needs 

of the northern spotted owl and concluded that, based on existing knowledge, large contiguous blocks of 

suitable habitat are still necessary for northern spotted owl conservation. Culminating this confirmation of 

the scientific information on the conservation needs of the northern spotted owl, the owl recovery plan 

recommends managing for large, contiguous blocks of late-successional forest (USDI FWS 2011, p. III19).

Based on the results of previous analyses, large contiguous blocks of late-successional forest would not 

develop in the absence of a land use allocation reserving a network of large blocks of forest. The 

Supplemental EIS for the Northwest Forest Plan (USDA FS and USDI BLM 1994b, p. 2-22) explicitly 

required that all alternatives analyzed in detail include the allocation of a network of Late-Successional 

Reserves. Other previous planning efforts have considered alternatives that would not allocate such a 

network, including:

• Alternative A in the 1994 RMP/EIS, which would have reserved no late-successional forest 

outside of special areas and sites occupied by ESA-listed species

• Alternative B in the 1994 RMP/EIS, which would have reserved small blocks of late-successional 

forest

• Alternative 3 in the 2008 Final EIS (FEIS), which would have allocated the majority of the 

landscape to a General Landscape Area that directed timber harvest on long rotations

For each of those alternatives, the analyses concluded that these alternatives would have resulted in less 

contribution to northern spotted owl conservation than alternatives that allocated a network of large 
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blocks of forest. Notably, Alternative 3 in the 2008 FEIS would have resulted in a total acreage of 

northern spotted owl habitat comparable to most other action alternatives, but would have failed to meet 

the conservation needs of the spotted owl because of the arrangement of that habitat. Overall, these 

previous analyses demonstrated that large, contiguous blocks of late-successional forest would not have 

developed under these alternatives, further demonstrating that reserving a network of large blocks of 

forest from programmed timber harvest is a necessary part of the purpose of contributing to the 

conservation and recovery of the northern spotted owl.

Older and More Structurally-complex Multi-Layered Conifer Forests

The scientific foundation for the importance of older, more structurally-complex multi-layered conifer 

forests as habitat for the northern spotted owl has been clearly established. Thomas et al. (1990) described 

high-quality northern spotted owl habitat as older, multilayered, structurally-complex forests 

characterized by large-diameter trees, high amounts of canopy cover, numerous large snags, and lots of 

downed wood and debris. Courtney et al. (2004, pp. 5–18), in the status review for the northern spotted 

owl, evaluated the existing scientific information on spotted owl habitat and confirmed that nesting, 

foraging, and roosting habitat is associated with older, more structurally-complex multi-layered conifer 

forests in the Pacific Northwest. The 15-year spotted owl monitoring report concluded that the highest 

stand-level habitat suitability for spotted owls is provided by older, more structurally-complex forests 

(Davis et al. 2011, p. 38).

The owl recovery plan recommends maintaining older and more structurally-complex multi-layered 

conifer forests. As noted in the owl recovery plan, the maintenance of older, more structurally-complex 

multi-layered conifer forests has scientific support at several scales: “At the scale of a spotted owl 

territory, Dugger et al. (in press) found an inverse relationship between the amount of old forest within 

the core area and northern spotted owl extinction rates from territories. At the population scale, Forsman 

et al. (2011) found a positive relationship between recruitment of spotted owls into the overall population 

and the percent cover of spotted owl NRF [nesting, roosting, and foraging] habitat within study areas” 

(USDI FWS 2011, p. III-67). The U.S. Fish and Wildlife Service noted that, in dry forest areas, 

maintaining these older and more structurally-complex multi-layered conifer forests may require active 

management to meet the overlapping goals of spotted owl recovery and restoration of dry forest structure, 

composition, and processes including fire, insects, and disease.

Previous planning efforts have considered a wide variety of approaches to the management of older, more 

structurally-complex multi-layered conifer forests, including—

• Alternative A in the 1994 RMP/EIS, which would have reserved no late-successional forest 

outside of special areas and sites occupied by ESA-listed species;

• The 1995 RMP, which reserved approximately 83 percent of old-growth forest;

• The Proposed RMP in the 2008 FEIS, which would have reserved 81 percent of old-growth forest 

and would have deferred harvest of any forest older than 160 years old for 15 years;

• Alternative E in the 1994 RMP/EIS, which would have reserved all old-growth forest;

• A sub-alternative for Alternative 1 in the 2008 FEIS, which would have reserved all forests older 

than 200 years old; and

• A sub-alternative for Alternative 1 in the 2008 FEIS, which would have reserved all forests older 

than 80 years old.

None of these alternative approaches defined management direction explicitly in terms of older, more 

structurally-complex multi-layered conifer forests, but used a variety of different terms, such as older 

forest, old-growth forest, late-successional forests, or a specific stand age. Nevertheless, these different 

management approaches would have resulted in the maintenance of differing amount of older and more 

structurally-complex multi-layered conifer forests. Those analyses demonstrated that alternatives that 
9 | P a g e

would have maintained more older and more structurally-complex multi-layered conifer forests would 

have maintained more northern spotted owl habitat and would have provided better conditions for 

northern spotted owl movement between large blocks of habitat than alternatives that would have 

maintained less older and more structurally-complex multi-layered conifer forests.

The existing science clearly establishes the importance of older and more structurally-complex multilayered conifer forests as northern spotted owl habitat; the owl recovery plan recommends the 

maintenance of older and more structurally-complex multi-layered conifer forests; and the results of 

previous analyses demonstrate that maintaining older and more structurally-complex multi-layered 

conifer forests would contribute to meeting conservation needs of the northern spotted owl. Therefore, 

maintaining older and more structurally-complex multi-layered conifer forest is a necessary part of the 

purpose of contributing to the conservation and recovery of the northern spotted owl.

To respond to this purpose for the action, alternatives would explore differing approaches to defining 

older and more structurally-complex multi-layered conifer forest, by such criteria as stand age, structure, 

size, or landscape context. In addition, alternatives would explore differing management approaches to 

maintaining older and more structurally-complex multi-layered conifer forest, such as active management 

in dry forest areas to reduce fire risk and restore fire resiliency.

The purpose of this action includes maintaining marbled murrelet habitat. The status review of the 

marbled murrelet prepared for the U.S. Fish and Wildlife Service reviewed the existing scientific 

information and confirmed the importance of maintaining suitable nesting habitat to the conservation and 

recovery of the marbled murrelet (McShane et al. 2004, pp. 4-61 – 4-63). Additionally, the recovery plan 

for the marbled murrelet (USDI FWS 1997) recommends protecting adequate nesting habitat for the 

marbled murrelet.

The purpose of this action includes protecting existing habitat and restoring degraded habitat for 

threatened and endangered anadromous fish. The status review of threatened and endangered anadromous 

fish prepared by the National Marine Fisheries Service reviewed the existing scientific information and 

confirmed the importance of maintaining existing habitat and restoring degraded habitat to the 

conservation and recovery of threatened and endangered fish (Good et al. 2005). The National Marine 

Fisheries Service has prepared several final and draft recovery plans for ESA-listed salmonid fish within 

the planning area, including the Upper Willamette River Conservation and Recovery Plan for Chinook 

Salmon and Steelhead (ODFW/USDC NMFS 2011), which recommend maintaining existing habitat and 

restoring degraded habitat.

Provide Clean Water in Watersheds

The purpose of the action includes continuing to comply with the Clean Water Act (33 U.S.C. 1251 et 

seq.), which directs the restoration and maintenance of the chemical, physical, and biological integrity of 

the nation’s waters. The policy declaration in the FLPMA states that the BLM should manage the public 

lands in a manner that protects many resources and their values, including the water resource (43 U.S.C. 

1701[a][8]). The FLPMA directs that land use plans provide for compliance with applicable State and 

Federal air, water, noise, or other pollution control laws, standards, or implementation plans (43 U.S.C. 

1712[c][8]).

In addition, the O&C Act includes reference to protecting watersheds and regulating stream flows, 

requiring that the O&C lands be managed “for permanent forest production, and the timber thereon shall 

be sold, cut, and removed in conformity with the principal of sustained yield for the purpose of ... 

protecting watersheds, regulating stream flow ...” (43 U.S.C. 1181a).
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Restore Fire-adapted Ecosystems

The purpose of the action includes restoring fire-adapted ecosystems to increase fire resiliency. Previous 

analyses have shown that active management in the dry forest landscape of southern Oregon can 

positively influence fire risk and fire resiliency, thereby restoring fire-adapted ecosystems (2008 FEIS). 

Further, as noted in the owl recovery plan, natural landscape resilience mechanisms in the dry forest 

landscape of southern Oregon have been decoupled by fire exclusion and wildfire suppression activities. 

The owl recovery plan recommends active management within the dry forest landscape to restore 

ecosystem resiliency. Additionally, in order to provide for sustained yield of timber from public lands 

under the O&C Act, BLM management must account for potential loss of this timber to fire. Based on the 

BLM’s authority under the O&C Act, the results of previous analyses showing the benefits of active 

management in restoring fire-adapted ecosystems, and in light of the recommendations in the owl 

recovery plan, the purpose of this action includes restoring fire-adapted ecosystems to increase fire 

resiliency.

Provide for Recreation Opportunities

The purpose of the action includes providing for recreation opportunities. The FLPMA requires that, 

among other uses, “the public lands be managed in a manner that will ... provide for outdoor recreation” 

43 CFR 1701 [Sec. 102.a.8]. In addition, the O&C Act states that O&C lands shall be managed “... for 

permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with 

the principal of sustained yield for the purpose of ... providing recreational facilities” (43 U.S.C. 1181a). 

Finally, changes in BLM policy since the 1995 RMPs for recreation land use allocations and management 

objectives necessitate plan revision, as concluded in the BLM plan evaluations (USDI BLM 2012, pp. 

28–29).

Coordinate Management of Lands Surrounding the Coquille 

Forest with the Coquille Tribe

The management of the Coquille Forest is subject by law (25 U.S.C. 715c (d)) to the standards and 

guidelines of forest plans for adjacent or nearby Federal forest lands. Title V of the Oregon Resource 

Conservation Act of 1996 (Pub. L. 104-208) created the Coquille Forest to be held in trust for the benefit 

of the Coquille Tribe. This Act states that the Coquille Forest shall be managed “under applicable State 

and Federal forestry and environmental protection laws, and subject to critical habitat designations under 

the Endangered Species Act and subject to the standards and guidelines of Federal forest plans on 

adjacent or nearby Federal lands, now and in the future.” This Act also requires the Secretary of the 

Interior to take the Coquille Forest lands into trust for the benefit of the Coquille Tribe. As such, the 

purpose of the action includes coordinating the management of BLM-administered lands “adjacent or 

nearby” the Coquille Forest with the Coquille Tribe.

Guidance for Development of All Action Alternatives and the 

Proposed RMP

The BLM developed all action alternatives and the Proposed RMP to meet the purposes for the action, 

described above in the Purpose and Need for Action. To be considered reasonable, action alternatives and 

the Proposed RMP had to make a substantial and meaningful contribution to meeting each of the 

purposes, rather than a minimal contribution. The alternatives and the Proposed RMP explored various 

ways of contributing to these purposes and meeting the requirements of the management guidance 

provided in this document.

In developing all action alternatives and the Proposed RMP, the BLM—
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• Reviewed existing Areas of Critical Environmental Concern (ACECs) and nominations for new 

ACECs. In this review, the BLM did the following:

o Determined if they meet the Relevance and Importance criteria

o Determined, for those on O&C lands that meet Relevance and Importance criteria, if 

designation would be in conflict with the O&C Act, as detailed below under The O&C 

Act and the FLPMA

o Eliminated from further consideration those areas that do not meet criteria for designation 

as ACECs

o Determined the relevant and important resource values of the remaining nominations 

which could be protected and maintained through other features of the alternatives or if 

special management attention is needed

o Included in the development of the alternatives those nominations that meet criteria for 

designation as ACECs

• Designated areas as Special Recreation Management Areas or Extensive Recreation Management 

Areas; lands not designated as one of these two categories are public lands not designated for 

recreation. Developed a range of recreation management area scenarios in relationship to various 

land use allocations and management objectives among the alternatives, consistent with the 

discussion of recreation management areas below under The O&C Act and the FLPMA

• Designated Visual Resource Management classifications for all areas; developed a range of 

Visual Resource Management classification scenarios in relationship to various land use 

allocations and management objectives among the alternatives, consistent with the discussion of 

visual resources below under The O&C Act and the FLPMA

• Evaluated all eligible Wild and Scenic River segments and determined which were suitable or 

non-suitable per Section 5(d)(1) of the Wild and Scenic Rivers Act of 1968 (16 U.S.C. 1271 et 

seq.) and consistent with BLM Manual 6400 – Wild and Scenic Rivers (USDI BLM 2012b).

• Designated areas as open, limited, or closed to public motorized access in accordance with 43 

CFR 8342.1; developed a range of travel management area scenarios in relationship to various 

land use allocations and management objectives among the alternatives; and deferred

implementation-level travel and transportation management planning until after completion of the 

RMP revision process. For those areas designated as limited in the RMP, defined interim 

management objectives and clearly identified the process leading from the interim area 

designation of ‘limited to existing roads, primitive roads and trails’ to the development of a 

designated network of roads, primitive roads and trails, consistent with BLM Handbook 8342 –

Travel and Transportation Handbook (USDI BLM 2012c)

• Considered a range of management alternatives for addressing lands with wilderness 

characteristics, consistent with the discussion of lands with wilderness characteristics below 

under The O&C Act and the FLPMA

• Designated areas that are available and have the capacity for planned, sustained-yield timber 

harvest, and declared an Allowable Sale Quantity of timber that represents the annual productive 

capacity for sustained-yield timber production

• Designated lands that are available or not available for livestock grazing; for lands available for 

livestock grazing, identified the amount of forage available for livestock

• Designated land tenure zones identifying lands for retention, disposal, or acquisition

• Designated lands as open, stipulated, or closed to the several forms of mineral entry location, 

leasing, or sale as appropriate to the type of commodity and land status; identified areas, if any, 

that the BLM would recommend for withdrawal from locatable mineral entry

In developing the action alternatives and the Proposed RMP, the BLM considered the concepts contained 

in the Framework to Guide Forest Service and Bureau of Land Management Land Use Plan Revisions and 

Amendments, dated April 11, 2011 (RIEC 2011).
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The BLM did not constrain the development of alternatives by current or projected BLM budget or staff 

levels. As long as alternatives were economically feasible, the analysis of the alternatives assumed that 

BLM budget and staff would be sufficient to implement all alternatives and the Proposed RMP. The 

analysis of alternatives and the Proposed RMP included an evaluation of the cost of implementation.

In accordance with national BLM planning policy (USDI BLM 2005, pp. 11–13), the RMP will 

emphasize management direction for allowable uses and management actions needed to achieve desired 

resource goals and objectives, rather than administrative process, reviews, or analysis requirements. The 

BLM will use program guidance issued outside the land use planning process to provide direction on 

administrative process, reviews, and analysis. Ongoing program guidance provides more flexibility to 

respond to changing national or state-level BLM administrative process or analysis requirements. Of 

course, the RMP process itself will be conducted consistent with procedural, review, and analysis 

requirements necessary to comply with Federal law and regulations applicable to planning for BLMadministered lands.

The BLM developed action alternatives and the Proposed RMP to provide a high degree of predictability 

and consistency about implementing land management actions and a high degree of certainty of achieving 

management objectives (desired outcomes), especially those outcomes related to discrete statutory 

mandates.

The BLM developed action alternatives and the Proposed RMP to provide cumulative effects analysis,

which provides a framework to simplify and facilitate project-level NEPA analysis for management 

actions implementing the RMP.

The BLM developed action alternatives to simplify implementation of management actions and reduce 

the costs of implementation.

Working closely with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service, the 

BLM developed the action alternatives and the Proposed RMP to provide sufficient detail in the analysis 

to facilitate RMP-level Endangered Species Act consultation, as well as eventual project-level 

consultation for management actions implementing the RMP.

Working closely with the Oregon Department of Environmental Quality, in coordination with the 

Environmental Protection Agency, the BLM developed the action alternatives and the Proposed RMP to 

satisfy State and Federal water quality rules and regulations at the RMP level.

Major Authorizing Laws

This section discusses how various laws affect management of the BLM-administered lands in the 

planning area. The planning area includes lands of different status: O&C lands, public domain lands, and 

acquired lands. This section only addresses the laws that have a substantial effect on the development and 

design of alternatives in this RMP revision. In addition to the laws presented here, many other legal 

authorities affect management of BLM-administered lands (Appendix A).

The O&C Act has been the statutory authority for the management of the O&C lands since 1937. 

Subsequent laws affect the management of the O&C lands to varying degrees. Laws, such as the 

Endangered Species Act and Clean Water Act, are directly applicable to how the BLM exercises its 

statutory authorities in managing the O&C lands, but none of these laws repealed the underlying primary 

direction and authority for the O&C lands. Thus, the BLM has a duty to find a way to implement 

concurrently all these laws, in a manner that harmonizes any seeming conflict between them, unless 
13 | P a g e

Congress has provided that one law would override another law, such as with the O&C Act and the 

FLPMA, as described below.

Endangered Species Act

Section 7 of the Endangered Species Act requires Federal agencies to use their legal authorities to 

promote the conservation purposes of the act. This section also requires Federal agencies to consult with 

the U.S. Fish and Wildlife Service or the National Marine Fisheries Service to ensure that actions these 

agencies authorize, fund, or carry out will not jeopardize species listed as threatened or endangered under 

the Endangered Species Act or cause destruction or adverse modification to designated critical habitat for 

such species. Critical habitat is defined, in part, as geographic areas occupied by the species that contain 

the physical or biological features essential to the conservation of a species listed under the Endangered 

Species Act and that may need special management or protection. The BLM will complete Section 7 

consultation with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service prior to 

signing Records of Decision/RMPs for this RMP revision.

Clean Water Act

The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological 

integrity of the nation’s waters. To accomplish this objective, the statute requires that: water quality 

standards consistent with the statutory goals of the Clean Water Act be established; water bodies be 

monitored to determine whether the water quality standards are being met; and, if all of the water quality 

standards are being met, then anti-degradation policies and programs, including ambient monitoring, be 

employed to keep the water quality at acceptable levels. In accord with this statute, the responsibility for 

establishing these standards, developing a strategy for meeting these standards, and monitoring their 

attainment in Oregon has been delegated to the Oregon Department of Environmental Quality.

Sections 303(d), 313(a), and 319 of the Clean Water Act are relevant to management of water resources 

on BLM-administered lands. Section 303(d) (codified as 33 U.S.C. 1313[d]) directs the states and tribes 

to develop a list of waters that fail to meet water quality standards for various constituents including, 

among others, sediment, temperature, and bacteria. Section 303(d) requires states and tribes to develop 

total maximum daily loads that apportion a load of pollutants that can be discharged into the waters of a 

state. The total maximum daily loads determine what level of pollutant load would be consistent with 

meeting the water quality standards and allocate acceptable loads among sources of the relevant 

pollutants. Necessary reductions in pollutant loading are achieved by implementing strategies authorized 

by the Clean Water Act, along with other tools available from Federal, state, and local governments and 

nongovernmental organizations. Section 313(a) (codified as 33 U.S.C. 1323[a]) directs that the Federal 

Government, “(1) having jurisdiction over any property or facility, or (2) engaged in any activity

resulting, or which may result, in the discharge or runoff of pollutants,” shall comply with requirements 

for the control and abatement of water pollution. Section 319 (codified as 33 U.S.C. 1329) established 

management programs to control water pollution from nonpoint sources, such as sediment.

Federal Land Policy and Management Act

The FLPMA provides the legal authority to the Secretary of the Interior for the management of public 

lands. The FLPMA requires, in part, that “the public lands be managed in a manner that will protect the 

quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, 

and archaeological values; that, where appropriate, will preserve and protect certain public lands in their 

natural condition; that will provide food and habitat for fish and wildlife and domestic animals; and that 

will provide for outdoor recreation and human occupancy and use” (43 U.S.C. 1701 [Sec. 102.a.8]). In 
14 | P a g e

addition, the FLPMA requires that “the public lands be managed in a manner which recognizes the 

Nation’s need for domestic sources of minerals, food, timber, and fiber from the public lands” (43 U.S.C. 

1701 [Sec. 102.a.12]). The FLPMA directs that acquired lands “... shall, upon acceptance of title, become 

public lands, and, for the administration of public land laws not repealed by this Act, shall remain public 

lands” (43 U.S.C. 1701 [Sec. 205.c]).

Oregon and California Railroad and Coos Bay Wagon Road Grant 

Lands Act

The O&C Act provides the legal authority to the Secretary of the Interior for management of the O&C 

lands. The O&C Act requires that the O&C lands “classified as timberlands ... shall be managed ... for 

permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with 

the principal [sic] of sustained yield for the purpose of providing a permanent source of timber supply, 

protecting watersheds, regulating stream flow, and contributing to the economic stability of local 

communities and industries, and providing recreational facilities” (43 U.S.C. 1181a). Section 701(b) of 

the FLPMA states, “Notwithstanding any provision of this Act, in the event of conflict with or 

inconsistency between this Act and [the O&C Act] ..., insofar as they relate to management of timber 

resources, and disposition of revenues from lands and resources, the latter Acts shall prevail.” In this case, 

the “latter Acts” refers to the O&C Act.

The O&C Act and the FLPMA

On August 28, 1937, Congress enacted the O&C Act, which provides the legal authority for the 

management of O&C lands and Coos Bay Wagon Road lands. Approximately 81 percent of the BLMadministered lands in the planning area are O&C lands, and approximately 3 percent are Coos Bay 

Wagon Road lands (Map 1-2). The provision of the O&C Act that provides the management direction for 

the O&C lands states, in part, that these lands:

“shall be managed except as provided in section 3 hereof, for permanent forest production, and 

the timber thereon shall be sold, cut, and removed in conformity with the [principle] of sustained 

yield for the purpose of providing a permanent source of timber supply, protecting watersheds, 

regulating stream flow, and contributing to the economic stability of local communities and 

industries, and providing recreational facilities...”

Based on the language of the O&C Act, the O&C Act’s legislative history, and case law, it is clear that 

sustained-yield timber production is the primary or dominant use of the O&C lands in western Oregon. In 

managing the O&C lands for that primary or dominant use, the BLM must exercise its discretion to 

determine how to manage the forest to provide for sustained-yield timber production, including harvest 

methods, rotation length, silvicultural regimes under which these forests would be managed, or minimum 

level of harvest. In addition, the BLM must conduct this management “for the purpose of providing a 

permanent source of timber supply, protecting watersheds, regulating stream flow, and contributing to the 

economic stability of local communities and industries, and providing recreational facilities.” Finally, 

when implementing the O&C Act, the BLM must do so in full compliance with a number of subsequent 

laws that direct how the BLM accomplishes the statutory direction.

The FLPMA provides the legal authority for the management of public domain lands and acquired lands. 

These lands and resources are to be managed under the principles of multiple use and sustained yield. 

Approximately 15 percent of the BLM-administered lands in the planning area are public domain lands, 

and less than 1 percent is acquired lands (Map 1-2). The FLPMA specifically provides that if there is any 

conflict between its provisions and the O&C Act related to management of timber resources or the 
15 | P a g e

disposition of revenues from the O&C lands and resources, the O&C Act prevails (i.e., takes precedence) 

(43 U.S.C. 1701 note (b)). However, provisions of the FLPMA that do not conflict with the O&C Act 

related to management of timber resources or the disposition of revenues from the O&C lands are 

applicable to the O&C lands. Preparation of the RMPs and EIS will conform to these land laws as 

described in this section and will comply with other Federal laws, including, but not limited to, the 

Endangered Species Act, the Clean Water Act, and the National Environmental Policy Act. 
16 | Page

INSERT 

Map 1-2. Public domain and acquired lands 
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In developing the range of alternatives in this planning process, the BLM will need to apply the direction 

set forth in the O&C Act to key issues associated with the management of areas or resources that typically 

arise during land use planning. These areas or resources include:

 Areas of Critical Environmental Concern

 Lands with wilderness characteristics

 Visual resources

 Recreation management areas

 Sensitive species

Areas of Critical Environmental Concern (ACECs)

The FLPMA provides authority for designation of Areas of Critical Environmental Concern (43 U.S.C. 

1712 [Sec. 202.c.3]). In this planning process, the BLM will evaluate nominated and existing ACECs to 

determine whether relevant and important values are present and if special management is needed to 

maintain those values.

For areas that have relevant and important values and need special management to maintain those values, 

the BLM will designate and manage ACECs on public domain lands and acquired lands. The BLM will 

also designate and manage ACECs on O&C lands where the special management needed to maintain 

relevant and important values would not conflict with the planning for sustained-yield timber production 

for the purposes of the O&C Act. For example, designating and managing ACECs on O&C lands would 

not conflict with sustained-yield timber production in the following circumstances: on non-forested lands; 

on O&C lands that would otherwise be allocated to a land use allocation that would preclude sustainedyield timber production; or on lands for which the Timber Productivity Capability Classification4

category is ‘not included in the harvest land base.’ In addition, designating and managing ACECs on 

O&C lands would not conflict with sustained-yield timber production if the special management needed 

to maintain relevant and important values were compatible with sustained-yield timber production, even if 

that special management might condition how sustained-yield timber production would be conducted. 

Finally, designation and management of Research Natural Areas, which are a type of ACEC, on O&C 

lands would not conflict with sustained-yield timber production when the scientific value of the research 

is relevant to sustained-yield timber production.

Lands with Wilderness Characteristics

Designated Wilderness Areas will be managed pursuant to the Wilderness Act of 1964 (16 U.S.C. 1131 et 

seq.), the area’s designating statute, the BLM’s wilderness regulations at 43 CFR 6300 – Management of 

Designated Wilderness, and BLM Manual 6340 – Management of Designated Wilderness Areas (USDI 

BLM 2012d). In this planning process, the BLM will consider whether to manage lands outside of 

designated Wilderness Areas for wilderness characteristics on public domain lands and acquired lands. 

The BLM will also consider whether to manage lands outside of designated Wilderness Areas for 

wilderness characteristics on O&C lands where management for wilderness characteristics would not 

conflict with the planning for sustained-yield timber production for the purposes of the O&C Act. For 

example, management for wilderness characteristics on O&C lands would not conflict with sustainedyield timber production in the following circumstances: on non-forested lands; on lands that would 

otherwise be allocated to a land use allocation that would preclude sustained-yield timber production; or 

on lands for which the Timber Productivity Capability Classification category is ‘not included in the 

harvest land base.’

 

4 Timber Productivity Capability Classification is the process of partitioning forestland into major classes indicating 

relative suitability to produce timber. See Chapter 2.
18 | P a g e

However, management for wilderness characteristics cannot be compatible with sustained-yield timber 

production, because the selling, cutting, and removing timber in conformance with the principles of 

sustained yield would alter such areas to the point of reducing or eliminating their wilderness 

characteristics. Thus, in developing the range of alternatives for this planning effort, alternatives should 

not include managing O&C lands outside of designated Wilderness Areas for wilderness characteristics in 

areas dedicated to sustained-yield timber production.

Visual Resources

The FLPMA provides authority for protection of scenic values (43 U.S.C. 1701 [Sec. 102.a.8]). Through 

this planning process, the BLM will designate Visual Resource Management classes for all BLMadministered lands, based on an inventory of visual resources and management considerations for other 

land uses.

In this planning process, the BLM will designate Visual Resource Management classes that would protect 

scenic values as identified through a visual resource management inventory where the protection is 

required as part of the management specified by Congress in legislation, such as the Wild and Scenic 

Rivers Act of 1968 (16 U.S.C. 1271 et seq.). In this planning process, the BLM will consider designating 

Visual Resource Management classes that would conflict with sustained-yield timber production to 

protect scenic values as identified through a visual resource management inventory on public domain 

lands and acquired lands; on non-forested O&C lands; on O&C lands that would otherwise be allocated to 

a land use allocation that would preclude sustained-yield timber production; or on O&C lands for which 

the Timber Productivity Capability Classification category is ‘not included in the harvest land base.’ 

Finally, in this planning process, the BLM will consider designating Visual Resource Management 

classes to protect scenic values as identified through a visual resource management inventory on O&C 

lands. This would occur to the extent that the protection of scenic values is compatible with sustainedyield timber production, even if that protection might condition how sustained-yield timber production 

would be conducted. The O&C Act contemplates that sustained-yield forest management can be 

conducted in a manner to provide for purposes including recreation, and the BLM recognizes that scenery 

can be an important component of recreation.

Recreation Management Areas

The FLPMA provides authority for management for outdoor recreation (43 U.S.C. 1701 [Sec. 102.a.8]). 

The O&C Act contemplates that sustained-yield timber production can be conducted in a manner to 

provide for purposes including recreation. A Special Recreation Management Area is an administrative 

unit where the existing recreation opportunities and recreation setting characteristics are recognized for 

their unique value, importance, and distinctiveness, as compared to other areas used for recreation. 

Consistent with BLM Manual 8320 – Planning for Recreation and Visitor Services (USDI BLM 2011a), 

within a Special Recreation Management Area, recreation and visitor services management is recognized 

as the predominant land use plan focus, where specific recreation opportunities and recreation setting 

characteristics are managed and protected on a long-term basis.

In this planning process, the BLM will consider designating Special Recreation Management Areas on 

public domain lands and acquired lands; on non-forested O&C lands; on O&C lands that would otherwise 

be allocated to a land use allocation that would preclude sustained-yield timber production; or on O&C 

lands for which the Timber Productivity Capability Classification category is not included in the harvest 

land base. Finally, in this planning process, the BLM will consider designating Special Recreation 

Management Areas on O&C lands to the extent that the management for recreation and visitor services 

would be compatible with planning for sustained-yield timber production for the purposes of the O&C 
19 | P a g e

Act, even if that management might condition how sustained-yield timber production would be 

conducted. However, in developing the range of alternatives for this planning effort, alternatives should 

not include Special Recreation Management Areas on O&C lands if the management for recreation and 

visitor services would conflict with planning for sustained-yield timber production for the purposes of the 

O&C Act.

An Extensive Recreation Management Area is an administrative unit that requires specific management 

consideration in order to address recreation use, demand, or recreation and visitor services program 

investments. Extensive Recreation Management Areas do not necessarily conflict with sustained-yield 

timber production. Consistent with BLM Manual 8320, management of Extensive Recreation 

Management Areas “...is commensurate with the management of other resources and resource uses.” 

Furthermore, this manual explains that land use plan decisions for management of Extensive Recreation 

Management Areas will be “...compatible with other resource objectives.” Because management for 

recreation values in Extensive Recreation Management Areas is intended to be done in a manner that is 

compatible with other resource uses, such as sustained-yield timber production, designation of Extensive 

Recreation Management Areas would not necessarily conflict with sustained-yield timber production. 

Therefore, the BLM will consider designating Extensive Recreation Management Areas on all lands in 

the planning area, including O&C lands.

Sensitive Species

The FLPMA provides authority for management for ecological and environmental values and to provide 

food and habitat for fish and wildlife (43 U.S.C. 1701 [Sec. 102.a.8]). Consistent with BLM Manual 6840 

– Special Status Species (USDI BLM 2008g), the BLM shall designate Bureau Sensitive species and 

implement measures to conserve these species and their habitats. It is in the interest of the BLM to 

undertake conservation actions for such species before listing under the Endangered Species Act is 

warranted. By doing so, the BLM will have greater flexibility in managing the public lands to accomplish 

native species conservation objectives and other legal mandates. BLM Manual 6840 also directs that 

specific protection to species that are listed by the BLM as sensitive on lands governed by the O&C Act

must be consistent with timber production as the dominant use of those lands.

In developing the range of alternatives to be considered in this planning process, the BLM will consider 

providing measures to conserve Bureau Sensitive species and their habitats on O&C lands to the extent 

that the conservation measures are compatible with planning for sustained-yield timber production for the 

O&C Act purposes. The BLM will consider providing these measures even if the conservation measures 

might condition how sustained-yield timber production would be conducted. Furthermore, the BLM will

consider providing measures to conserve Bureau Sensitive species and their habitats on O&C lands to the 

extent that the conservation measures are necessary to prevent the need to list Bureau Sensitive species 

under the Endangered Species Act. Future listings under the Endangered Species Act could have the 

effect of limiting the BLM’s ability to provide a sustained yield of timber under O&C Act; limiting or 

avoiding future listings could best ensure a permanency of timber production over the long term.

Management of the Public Domain Lands in Relation to the O&C 

Lands

Out of the approximately 2.5 million acres of BLM-administered lands in the planning area, 384,273 

acres are public domain lands. While the FLPMA requires that the public domain lands be managed for a 

multitude of values, the Act does not require that every parcel be managed for every value. As in previous 

RMPs, these public domain parcels will be managed in accordance with the 1975 Public Land Order No. 

5490 (40 FR 7450), which reserves these intermingled public domain lands for multiple-use management, 
20 | P a g e

including the sustained yield of forest resources in connection with the intermingled O&C lands. The 

alternatives include a range of uses and management objectives for public domain lands in the planning 

area, which permits the BLM to consider multiple uses for the public domain lands, consistent with the 

requirements of the FLPMA.

Relationship of the RMPs to Other Plans and Programs

The 1995 RMPs are consistent with the 1994 Northwest Forest Plan, which was adopted by the 

Department of the Interior and the Department of Agriculture for Federal forests within the range of the 

northern spotted owl as an “ecosystem management plan for managing habitat for late-successional and 

old-growth forest related species.” The April 1994 Record of Decision for the Northwest Forest Plan, 

signed jointly by the Secretary of the Interior and the Secretary of Agriculture amended the BLM’s land 

use plans in effect at the time. In 1995, the BLM completed new RMPs, which were designed to be 

consistent with the Northwest Forest Plan’s land use allocations and its standards and guidelines. 

The Northwest Forest Plan is not a statute or regulation. It was a coordinated, multi-agency amendment to 

the then-current RMPs of the BLM and forest plans of the U.S. Forest Service. The Secretaries and the 

agencies retained authority provided by statutes and regulations to revise these plans in the future. The 

only provision the Northwest Forest Plan made concerning future amendments or modifications to these 

plans was that they would be “coordinated” through the “Regional Interagency Executive Committee and 

the Regional Ecosystem Office” (USDA FS and USDI BLM 1994a, p. 58). In keeping with the intention 

of the Northwest Forest Plan to encourage cooperation and coordination of programs among the Federal 

agencies, the BLM has coordinated with the Regional Interagency Executive Committee on this RMP

revision. Furthermore, many of the agencies that are represented on the Regional Interagency Executive 

Committee are cooperating agencies in this RMP Revision. Those cooperating agencies include the U.S. 

Forest Service, U.S. Fish and Wildlife Service, National Marine Fisheries Service, and the Environmental 

Protection Agency (Chapter 4).

The Northwest Forest Plan did not change the authority of the BLM, provided under the FLPMA and its 

promulgating regulations, for amending or revising RMPs. The 1995 RMPs, consistent with FLPMA 

planning regulations, anticipated the possibility that periodic plan evaluations could lead to RMP 

amendments and revisions. The BLM has subsequently amended the 1995 RMPs, as described below.

The interagency Record of Decision and Standards and Guidelines for Amendments to the Survey and 

Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines in Forest Service 

and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl 

(USDA FS and USDI BLM 2001), amended all of the 1995 RMPs.5

The BLM has also amended the Coos Bay, Medford, and Roseburg District RMPs with the Record of 

Decision and Resource Management Plan Amendment for Management of Port-Orford-cedar in 

Southwest Oregon, Coos Bay, Medford, and Roseburg District (USDI BLM 2004), which was based on 

 

5 The Survey and Manage categorizations for the red tree vole were established in this record of decision. The Ninth 

Circuit Court decision in Klamath-Siskiyou Wildlands Center v. Boody, 468 F.3d 549 (2006), found that the changes 

to those Survey and Manage categorizations for the red tree vole would constitute plan amendments that need to be 

analyzed with NEPA procedures. The court then invalidated the re-categorizations regarding the red tree vole, 

because the BLM had not prepared a plan amendment and appropriate environmental analysis consistent with the 

FLPMA and NEPA.
21 | P a g e

an interagency supplemental EIS. Under all alternatives in this RMP revision, the BLM would continue to 

manage Port-Orford-cedar in accordance with this 2004 Record of Decision.

6

In addition, the BLM has amended individual RMPs with amendments of more limited scope than the 

above amendments, and has periodically maintained individual RMPs.7Individual District Annual 

Program Summaries have documented these RMP amendments and RMP maintenance actions.

In contrast to these amendments of the 1995 RMPs, this RMP revision would replace the 1995 RMPs and 

thereby replace the Northwest Forest Plan for the management of BLM-administered lands in western 

Oregon. The purpose and need for this RMP revision, as described earlier in this chapter, is different from 

the purpose and need for the Northwest Forest Plan. As such, the action alternatives and the Proposed 

RMP do not contain all elements of the Northwest Forest Plan.

Survey and Manage

The BLM adopted a purpose and need for this RMP revision that is consistent with the agency’s 

discretion and obligations under the FLPMA and the O&C Act. Under the O&C Act, the BLM has no 

specific wildlife conservation mandate, but has a range of discretion on how to manage the O&C 

timberlands for permanent, sustained-yield timber production. The purpose and need for this RMP 

revision differs from the purpose and need for the Northwest Forest Plan, and reflects the BLM’s 

determination that it can achieve the goals of the O&C Act without the Survey and Manage measures. 

While neither the Proposed RMP nor any of the action alternatives in this Proposed RMP/Final EIS 

therefore includes the Survey and Manage measures, Survey and Manage is reflected in the Proposed 

RMP/Final EIS’s No Action alternative described in Chapter 2.8

The purpose and need for the Northwest Forest Plan was guided by the policy pronouncements of 

President Clinton at the 1993 Forest Conference directing the BLM and U.S. Forest Service to adopt a 

“comprehensive ... common management approach to the [federal] lands administered throughout an 

entire ecological region” (USDA FS and USDI BLM 1994a, p. 1). To achieve this comprehensive 

approach, the Northwest Forest Plan included a goal of supporting “viable populations, well-distributed 

across their current range, of species known (or reasonably expected) to be associated with old-growth 

forest conditions” (FEMAT 1993, p. II-5; USDA FS and USDI BLM 1994b, p. 3&4-113). This goal was 

founded on the Forest Service planning regulation issued under the National Forest Management Act 

(NFMA) “to maintain viable populations of existing native and desired nonnative vertebrate species in the 

planning area” (36 CFR 219.19).9 This Forest Service planning regulation did not and does not apply to 

 

6 The Standards and Guidelines in the 2004 Port-Orford-cedar ROD describe all currently available disease-control 

practices, dividing them between those that should be applied generally and those that may be applied to specific 

management activities. The Standards and Guidelines include a Risk Key (pp. 32–37) to clarify the environmental 

conditions that require implementation of one or more of the listed disease-controlling management practices. The 

BLM would apply the Risk Key during site-specific project planning. This approach precludes the need for 

additional analysis because BLM would continue to implement the Port-Orford-cedar ROD under any alternative or 

the Proposed RMP in accordance with the conditions described in the Risk Key for risk reduction management 

practices.

7 RMP maintenance actions respond to minor data changes and incorporation of activity plans and are limited to 

further refining or documenting a previously approved decision incorporated in the plan. Plan maintenance does not 

result in expansion of the scope of resource uses or restrictions or change the terms, conditions, and decisions of the 

approved RMP.

8 As further explained in Chapter 2, the No Action alternative in this Proposed RMP/Final EIS is implementation of 

the 1995 RMPs as written (in contrast to the BLM’s current implementation practices under the 1995 RMPs).

9

Since the adoption of the Northwest Forest Plan, the Forest Service adopted new planning regulations at 36 CFR 

219 in 2000 and in 2012, which replaced the cited regulation.
22 | P a g e

the BLM, and is not a part of the purpose for this RMP revision. There is no comparable regulation for 

maintaining “viable populations” in the BLM’s regulations implementing the FLPMA or O&C Act. In 

carrying out this goal, the Secretaries for the respective departments included what is known as ‘Survey 

and Manage’ as mitigation in the Northwest Forest Plan to provide benefits to these species and increase 

the likelihood of viable, well-distributed populations across all Federal lands in the planning area, 

including BLM-administered lands (USDA FS and USDI BLM 1994b, p. 3&4-129).

The Northwest Forest Plan species viability objective is not part of this RMP revision. However, the 

purpose of this revision does include contributing to the conservation and recovery of threatened and 

endangered species, consistent with the BLM’s mandate under the Endangered Species Act. Furthermore, 

all of the action alternatives and the Proposed RMP would implement the BLM’s Special Status Species 

policy, which is described in detail in the Final Supplemental Environmental Impact Statement to 

Remove or Modify the Survey and Manage Mitigation Measure Standards and Guidelines, which is 

incorporated here by reference (USDA FS and USDI BLM 2004, pp. 45–54), and include conservation 

measures to the extent necessary to prevent the need to list Bureau Sensitive species under the 

Endangered Species Act (BLM Manual 6840 – Special Status Species Management).

In addition, in developing a plan consistent with the purpose and need for this RMP revision, the BLM 

will not need the Survey and Manage measures to protect species associated with older and more 

structurally-complex forests. This is because the purpose of this RMP revision includes maintaining a 

network of large blocks of forest to be managed for late-successional forests and maintaining older and 

more structurally-complex multi-layered conifer forests, as necessary components of contributing to the 

conservation and recovery of the northern spotted owl. All action alternatives and the Proposed RMP 

therefore allocate a Late-Successional Reserve network, where sustained-yield timber harvest would not 

occur, that is larger than what is provided in the Northwest Forest Plan and broadly encompasses “oldgrowth forests.” Each alternative and the Proposed RMP would more than sufficiently address 

maintenance of older and more structurally-complex forests, without the need for additional mitigation 

like that provided by Survey and Manage. Further, even if the larger Late-Successional Reserve and 

protection of older and more structurally-complex forests were not sufficient to provide adequate habitat 

for Survey and Manage species, before such species could need listing under the Endangered Species Act, 

the BLM would be able to include such species on the BLM Sensitive species list and provide necessary 

management to avoid the need for listing (see the Rare Plants and Fungi and Wildlife sections of Chapter 

3).

Finally, based on this analysis, the BLM concludes that the action alternatives and the Proposed RMP

would avoid potential disruptions to sustained-yield timber production by avoiding contributing to future 

listing of any Survey and Manage species under the Endangered Species Act. Even if the habitat and site 

protection under action alternatives and the Proposed RMP were not sufficient to provide adequate habitat 

for Survey and Manage species, before such species could need listing under the Endangered Species Act, 

the BLM would be able to include such species on the BLM sensitive species list and provide necessary 

management to avoid the need for listing and thus avoid potential disruptions to future sustained-yield 

timber production on BLM-administered lands. 

Aquatic Conservation Strategy

As described earlier in this chapter, this RMP revision would replace the 1995 RMP’s and thereby replace 

the Northwest Forest Plan for the management of BLM-administered lands in western Oregon. The BLM 

adopted a purpose and need for this RMP revision that is consistent with the agency’s discretion and 

obligations under the FLPMA and the O&C Act. The purpose and need differs from the purpose and need 

for the Northwest Forest Plan and reflects BLM’s determination that it can achieve the goals of the O&C 

Act without the Aquatic Conservation Strategy (ACS) in its entirety as constituted in the Northwest 
23 | P a g e

Forest Plan. Because of these differences, none of the action alternatives or the Proposed RMP in this 

Proposed RMP/Final EIS includes the ACS in its entirety as constituted in the Northwest Forest Plan. The 

ACS in its entirety as constituted in the Northwest Forest Plan is reflected in the Proposed RMP/Final 

EIS’s No Action alternative described in Chapter 2.

As previously discussed, the purpose and need for the Northwest Forest Plan was guided by the policy 

pronouncements of President Clinton at the 1993 Forest Conference directing the BLM and U.S. Forest 

Service to adopt a “comprehensive ... common management approach to the [federal] lands administered 

throughout an entire ecological region” (USDA FS and USDI BLM 1994a, p. 1). To achieve this 

comprehensive approach, the Northwest Forest Plan includes the ACS, which was intended to fulfill nine 

broad objectives, including restoring and maintaining the ecological health of watersheds and aquatic 

ecosystems and supporting well-distributed populations of riparian-dependent species. These objectives 

were based on the Forest Service organic statute and implementing regulations. The ACS consists of four 

components: riparian reserves, key watersheds, watershed analysis, and watershed restoration.

The Proposed RMP addresses all four of the components of the ACS of the Northwest Forest Plan (see 

Chapter 2 and Appendix B for more detailed description of the land use allocations, management 

objectives, and management direction of the Proposed RMP). The BLM has modified several of the ACS 

components from how they are constituted in the Northwest Forest Plan, consistent with the purpose and 

need and guidance for the development of all action alternatives for this RMP revision (discussed earlier 

in this chapter) and in light of monitoring results and new scientific information (discussed in the 

Fisheries and Hydrology sections of Chapter 3).

Riparian Reserves

The Northwest Forest Plan allocates ‘interim’ Riparian Reserve widths along all streams, wetlands, and 

water bodies. These ‘interim’ widths have not been modified in practice as anticipated. The Northwest 

Forest Plan ties requirements for management actions within the Riparian Reserve to consistency with the 

nine broad ACS objectives.

The Proposed RMP allocates a Riparian Reserve along all streams, wetlands, and water bodies, with 

management objectives related to fish habitat and water quality, and management direction for actions 

within the Riparian Reserve. In the Proposed RMP, the Riparian Reserve widths vary by class of 

watershed, as described below.

Key Watersheds

The Northwest Forest Plan designates three categories of watersheds: Tier 1 Key Watersheds, Tier 2 Key 

Watersheds, and non-key watersheds. Tier 1 and Tier 2 Key Watersheds have the same management 

approach, which has three requirements that differ from non-key watersheds:

 No net increase in road mileage

 Key watersheds are highest priority for watershed restoration

 Watershed analysis is required prior to most management activities

The Proposed RMP defines three classes of subwatersheds and varies Riparian Reserve widths and 

management direction for actions within the Riparian Reserve by these classes of subwatershed.

Watershed Analysis

The Northwest Forest Plan directs the process of conducting watershed analysis: a systematic procedure 

to characterize the aquatic, riparian, and terrestrial features within a watershed. The Northwest Forest 

Plan requires the use of watershed analyses to refine Riparian Reserve boundaries, prescribe land 

management activities including watershed restoration, and develop monitoring programs. The Northwest 
24 | P a g e

Forest Plan required the completion of watershed analysis prior to approval of several types of 

implementation actions.

As noted earlier in this chapter, the guidance for the development of all action alternatives includes 

emphasizing management direction for allowable uses and management actions needed to achieve desired 

resource goals and objectives, rather than administrative process, reviews, or analysis requirements. 

Consistent with this guidance, the Proposed RMP does not include management direction requiring or 

directing a specific watershed analysis procedure. However, as discussed in more detail in Appendix X,

the BLM will compile watershed-scale information on aquatic and riparian resources, including 

identifying resource conditions, watershed processes, risks to resources, and restoration opportunities, as 

needed for planning and analysis of implementation actions under the approved RMP.

Watershed Restoration

The Northwest Forest Plan directs watershed restoration actions to control road-related runoff and 

sediment production, restore riparian vegetation, and restore in-stream habitat complexity. 

The Proposed RMP includes management direction for watershed restoration similar to the watershed 

restoration described in the Northwest Forest Plan (see Appendix B and Appendix V).

Existing Decisions

Under all alternatives and the Proposed RMP, this RMP revision would not alter the following existing 

decisions, which remain valid for continued implementation within the decision area:

 Record of Decision for Implementation of a Wind Energy Development Program and Associated 

Land Use Plan Amendments (USDI BLM 2005b)

 Record of Decision and Resource Management Plan Amendments for Geothermal Leasing in the 

Western United States (USDA FS and USDI BLM 2008)

 Approved Resource Plan Amendments/Record of Decision for Designation of Energy Corridors 

on Bureau of Land Management-administered lands in the 11 Western States (USDI BLM 2009)

 Vegetation Treatments Using Herbicides on BLM Lands in Oregon Record of Decision (USDI 

BLM 2010)

 Record of Decision for Management of Port-Orford-cedar in Southwest Oregon (Coos Bay, 

Medford, and Roseburg Districts; USDI BLM 2004a)

 Seed Orchard Records of Decision for Integrated Pest Management (Eugene, Medford and Salem 

Districts; USDI BLM 2005c, 2006, 2005d)

 Pokegama Wild Horse Herd Management Area Plan (Klamath Falls Field Office; USDI BLM 

2002)

 Rogue National Wild and Scenic River Comprehensive Management Plan (Medford District; 37 

FR 13408)

 Rogue National Wild and Scenic River: Hellgate Recreation Area Recreation Area Management 

Plan (Medford District; USDI BLM 2004b)

 North Bank Habitat Management Area and Area of Critical Environmental Concern Record of 

Decision (Roseburg District; USDI BLM 2001)

 North Umpqua River Management Plan (Roseburg District; USDA FS, USDI BLM, and Oregon 

State Parks and Recreation Department 1992)

 Molalla River-Table Rock Recreation Area Management Plan (Salem District; USDI BLM 

2011b)

 Quartzville Creek National Wild and Scenic River Management Plan (Salem District; USDI BLM 

1992)
25 | P a g e

 Salmon National Wild and Scenic River Management Plan (Salem District; USDA FS and USDI 

BLM 1993)

 Sandy Wild and Scenic River and State Scenic Waterway Management Plan (Salem District; 

USDI BLM 1993)

 Table Rock Wilderness Management Plan (Salem District; USDI BLM 1987)

 Yaquina Head Outstanding Natural Area Management Plan (Salem District; USDI BLM 1983)

The BLM would continue to implement actions directed by these decisions unless and until the BLM 

amends, revises, or rescinds these existing decisions in decision-making separate from this RMP revision. 

The BLM provided separate NEPA compliance to support these existing decisions. This RMP revision

does not alter these existing decisions or analyses; accordingly, this Proposed RMP/Final EIS considers 

such actions among the past, present, and reasonably foreseeable future actions in cumulative effects 

analyses. For the purpose of NEPA analysis, the BLM summarizes and cites these decisions and their 

supporting analyses to incorporate them by reference into Chapter 3 of this Proposed RMP/Final EIS 

where they are relevant to the analysis, consistent with 40 CFR 1502.21.

The Medford District is currently preparing an environmental assessment for an amendment to the 1995 

Medford RMP to change the boundary of the Table Rocks Area of Critical Environmental Concern 

(ACEC) to include newly acquired Federal lands and to encompass lands administered by The Nature 

Conservancy. If the BLM acquires The Nature Conservancy parcels in the future, The Nature 

Conservancy lands would become part of the ACEC. The environmental assessment will also analyze the 

impacts of an implementation action of converting temporary public use restrictions into permanent 

supplementary rules. The Table Rocks ACEC was originally designated in the 1986 Medford 

Management Framework Plan to recognize and protect botanical and geological features, threatened, 

endangered, and special status species, and natural systems.

This RMP revision would not alter the Cascade Siskiyou National Monument Record of Decision and 

Resource Management Plan (Medford District; USDI BLM 2008h), the Upper Klamath Basin and Wood 

River Wetland Record of Decision and Resource Management Plan (Klamath Falls Field Office; USDI 

BLM 1995g), or the West Eugene Wetlands Record of Decision and Resource Management Plan (Eugene 

District; USDI BLM 2015). The BLM-administered lands under these RMPs are not within the decision 

area for this RMP revision.

References

Courtney, S. P., J. A. Blakesley, R. E. Bigley, M. L Cody, J. P. Dumbacher, R. C. Fleischer, A. B. Franklin, J. F. Franklin, R. J. 

Gutiérrez, J. M. Marzluff, and L. Sztukowski. 2004. Scientific evaluation of the status of the northern spotted owl. 

Sustainable Ecosystems Institute, Portland, OR. 508 pp.

Davis, R. J., K. M. Dugger, S. Mohoric, L. Evers, and W. C. Aney. 2011. Northwest Forest Plan – the first 15 years (1994–2008): 

status and trends of northern spotted owl populations and habitats. USDA FS, Pacific Northwest Research Station, Portland, 

OR. General Technical Report PNW-GTR-850. 147 pp. http://www.fs.fed.us/pnw/pubs/pnw_gtr850.pdf.

FEMAT. 1993. Forest ecosystem management: an ecological, economic, and social assessment. Report of the Forest Ecosystem 

Management Assessment Team (FEMAT). 1993-793-071. Washington, DC: GPO.

Good, T. P., R. S. Waples, and P. Adams (editors). 2005. Updated status of federally listed ESUs of West Coast salmon and 

steelhead. USDOC NOAA. Technical Memo. NMFS-NWFSC-66. 598 pp. 

http://swfsc.noaa.gov/publications/fed/00749.pdf.

McShane, C., T. Hamer, H. Carter, G. Swartzman, V. Friesen, D. Ainley, R. Tressler, K. Nelson, A. Burger, L. Spear, T. 

Mohagen, R. Martin, L. Henkel, K. Prindle, C. Strong, and J. Keany. 2004. Evaluation report for the 5-year status review of 

the marbled murrelet in Washington, Oregon, and California. Unpublished report. EDAW, Inc., Seattle, WA. Prepared for 

the USFWS, Region 1. Portland, OR. 

http://www.fws.gov/wafwo/species/Fact%20sheets/5%20Year%20Status%20Review%202004.pdf.

Oregon Department of Fish and Wildlife (ODFW) and USDOC NMFS. 2011. Upper Willamette River Conservation and 

Recovery Plan for Chinook Salmon and Steelhead. [Place of publication unknown]. 

http://www.nmfs.noaa.gov/pr/pdfs/recovery/chinook_steelhead_upperwillametteriver.pdf.
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Regional Interagency Executive Committee (RIEC). 2011. Memorandum of Understanding for Management of Forest Service 

and Bureau of Land Management Forest Land within the Range of the Northern Spotted Owl at the Regional Level. 

Framework to Guide Forest Service and Bureau of Land Management Land Use Plan Amendments and Revisions. April 

2011. http://reo.ordvac.com/riec/2328%20B%20RIEC%20MOU%20signed%20&%20dated%2011April2011.pdf.

Thomas, J. W., E. D. Forsman, J. B. Lint, E. C. Meslow, B. R. Noon, and J. Verner. 1990. A conservation strategy for the 

northern spotted owl. Interagency Scientific Committee to Address the Conservation of the Northern Spotted Owl. USDA 

FS, USDI BLM, USFWS, and USDI NPS, Portland, OR.

USDA FS and USDA BLM. 1993. Salmon National Wild and Scenic River Management Plan. Mt. Hood National Forest, 

Gresham, OR, and Salem District, Salem, OR. http://www.rivers.gov/documents/plans/salmon-oregon-plan.pdf

---. 1994a. Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within 

the Range of the Northern Spotted Owl, and Standards and Guidelines for Management of Habitat for Late-Successional and 

Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl. Portland, OR.

http://www.reo.gov/documents/reports/newroda.pdf.

---. 1994b. Final Supplemental Environmental Impact Statement on Management of Habitat for Late-Successional and OldGrowth Forest Related Species Within the Range of the Northern Spotted Owl. Portland, OR. 

http://www.blm.gov/or/plans/nwfpnepa/FSEIS-1994/FSEIS-1994-I.pdf.

---. 2001. Record of Decision and Standards and Guidelines for Amendments to the Survey & Manage, Protection Buffer, and 

other Mitigation Measures Standards and Guidelines. Portland, OR.

---. 2008. Record of Decision and Resource Management Plan Amendments for Geothermal Leasing in the United States.

USDA FS, USDI BLM, and Oregon State Parks and Recreation Department. 1992. North Umpqua River Management Plan. 

Roseburg District, Roseburg, OR. http://www.blm.gov/or/districts/roseburg/plans/files/NoUmpRvr.pdf

USDI BLM. 1987. Table Rock Wilderness Management Plan. Salem District, Salem, OR. On file at the BLM Salem District 

office.

---. 1992. Quartzville Creek National Wild and Scenic River Management Plan. Salem District, Salem, OR. On file at the BLM 

Salem District office.

---. 1993. Sandy Wild and Scenic River and State Scenic Waterway Management Plan. Salem District, Salem, OR. On file at the 

BLM Salem District office.

---. 1995a. Coos Bay District Record of Decision/Resource Management Plan. Portland, OR.

---. 1995b. Eugene District Record of Decision/Resource Management Plan. Portland, OR.

---. 1995c. Klamath Falls Record of Decision/Resource Management Plan. Portland, OR.

---. 1995d. Medford District Record of Decision/Resource Management Plan. Portland, OR.

---. 1995e. Roseburg District Record of Decision/Resource Management Plan. Portland, OR.

---. 1995f. Salem District Record of Decision/Resource Management Plan. Portland, OR.

---. 1995g. Upper Klamath Basin and Wood River Wetland Record of Decision and Resource Management Plan. Klamath Falls 

Field Office. http://www.blm.gov/or/districts/lakeview/plans/files/KFRA_WRW_RMP_ROD.pdf

---. 2002. Pokegama Wild Horse Herd Management Area Plan. Lakeview District, Klamath Falls, OR.

http://www.blm.gov/or/districts/lakeview/plans/files/PokegamaHMAP.pdf

---. 2004a. Final - Supplemental Environmental Impact Statement Management of Port-Orford-cedar in Southwest Oregon. SEIS. 

Portland, OR.

---. 2004b. Rogue National Wild and Scenic River: Hellgate Recreation Area Recreation Area Management Plan. Medford 

District. http://www.blm.gov/or/resources/recreation/rogue/files/hellgate_RAMP.pdf

---. 2005a. Land Use Planning Handbook. H-1601-1. Release 1-1693, 11 March 2005. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_handbook.Par.38665.File.dat/

h1601-1.pdf.

---. 2005b. Record of Decision Implementation of a Wind Energy Development Program and Associated Land Use Plan 

Amendments.

---. 2005c. Record of Decision: Integrated Pest Management Program, BLM Travis Tyrell Seed Orchard, Lorane, Lane County, 

OR. BLM Eugene District, Springfield, OR. 56 pp.

---. 2005d. Record of Decision: Integrated Pest Management Program, BLM Walter H. Horning Tree Seed Orchard, BLM Salem 

District, Salem, OR.

---. 2006. Record of Decision: Integrated Pest Management. Provolt Seed Orchard, Grants Pass, OR, and Charles A. Sprague 

Seed Orchard, Merlin, OR. BLM Medford District, Medford, OR. 82 pp. 

http://www.blm.gov/or/districts/medford/plans/files/Provolt-Sprague_eis_ROD_acc.pdf.

---. 2008a. Coos Bay District Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008b. Eugene District Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008c. Klamath Falls Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008d. Medford District Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008e. Roseburg District Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008f. Salem District Record of Decision. Portland, OR. http://www.blm.gov/or/plans/wopr/rod/index.php.

---. 2008g. Special Status Species Management Manual. Release 6-125, 1December 12, 2008. Washington, D. C. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.43545.File.dat/68

40.pdf.
27 | P a g e

---. 2008h. Cascade-Siskiyou National Monument Record of Decision and Resource Management Plan. Medford District. 

http://www.blm.gov/or/districts/medford/plans/files/CSNM%20ROD%20and%20RMP_8-15-08.pdf

---. 2009. Approved Resource Plan Amendments/Record of Decision for Designation of Energy Corridors on Bureau of Land 

Management-administered lands in the 11 Western States. 

http://www.blm.gov/style/medialib/blm/wo/MINERALS__REALTY__AND_RESOURCE_PROTECTION_/lands_and_rea

lty.Par.27853.File.dat/Energy_Corridors_final_signed_ROD_1_14_2009.pdf.

---. 2010. Vegetation Treatments Using Herbicides on BLM Lands in Oregon. Record of Decision. Oregon State Office, Portland, 

OR. http://www.blm.gov/or/plans/vegtreatmentseis/files/Veg_Treatments_ROD_Oct2010.pdf.

---. 2011a. Planning for Recreation and Visitor Services Manual 8320. Washington, D.C. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.82237.File.dat/83

20.pdf.

---. 2011b. Molalla River-Table Rock Recreation Area Management Plan. Salem District, Salem, OR. 

http://www.blm.gov/or/districts/salem/plans/molalla/files/molalla_plan_complete.pdf

---. 2012a. Resource Management Plan Evaluation Report: Western Oregon. Portland, OR. 

http://www.blm.gov/or/plans/files/RMPEvaluation.pdf.

---. 2012b. Wild and Scenic Rivers Manual 6400 – Policy and Program Direction for Identification, Evaluation, Planning, and 

Management. Washington, D.C. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.76771.File.dat/64

00.pdf.

---. 2012c. Travel and Transportation Handbook H-8342. Washington, D.C. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_handbook.Par.34786.File.dat/

8342.pdf.

---. 2012d. Management of Designated Wilderness Areas Manual 6340. Release 6-135, 13 July 2012. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.22269.File.dat/63

40.pdf.

---. 2015. West Eugene Wetlands Record of Decision and Resource Management Plan. Eugene District, Eugene, OR. 

http://www.blm.gov/or/districts/eugene/plans/files/wew-rod.pdf

USDI FWS. 1997. Recovery plan for the threatened marbled murrelet (Brachyramphus marmoratus) in Washington, Oregon and 

California. Region 1. Portland, OR.

---. 2011. Revised recovery plan for the northern spotted owl (Strix occidentalis caurina). Region 1. Portland, OR. 258 pp. 

http://www.fws.gov/wafwo/pdf/NSO%20Revised%20Recovery%20Plan%202011.pdf.
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Chapter 2 – Alternatives

Introduction

This chapter describes the alternatives and the Proposed RMP. The range of alternatives considered in this 

Proposed RMP/Final EIS builds on the alternatives considered in the Draft RMP/EIS. The BLM is 

carrying forward the No Action alternative and action alternatives and sub-alternatives as presented in the 

Draft RMP/EIS. The BLM has developed the Proposed RMP as a variation on Alternative B from the 

Draft RMP/EIS.

The Council on Environmental Quality regulations direct that an EIS shall “...rigorously explore and 

objectively evaluate all reasonable alternatives...” 40 CFR 1502.14. Guidance from the Council on 

Environmental Quality further explains, “When there are potentially a very large number of alternatives, 

only a reasonable number of examples, covering the full spectrum of alternatives, must be analyzed and 

compared in the EIS” (“Forty Most Asked Questions...” 46 FR 18027). The purpose and need for action 

dictates the range of alternatives that must be analyzed, because action alternatives are not reasonable if 

they do not respond to the purpose and need for the action (USDI BLM 2008, pp. 35–36, 49–50).

For an RMP, there are potentially endless variations in design features or combinations of different plan 

components. The BLM designed the range of alternatives in the Draft RMP/EIS to span the full spectrum 

of alternatives that would respond to the purpose and need for the action. The BLM developed those 

alternatives to represent a range of overall management approaches, rather than exemplify gradations in 

design features. The BLM has developed the Proposed RMP from the alternatives considered in the Draft 

RMP/EIS, and the Proposed RMP represents a management approach that is within the spectrum of the 

alternatives analyzed in detail in the Draft RMP/EIS.

This chapter describes the Proposed RMP, the No Action alternative, and the action alternatives that are 

analyzed in detail. This chapter also discusses alternatives that the BLM considered but did not analyze in 

detail. Finally, this chapter presents a comparison of the alternatives and the Proposed RMP, including a 

summary of the environmental effects of the alternatives and the Proposed RMP.

Summary of Notable Changes from the Draft RMP/EIS

Chapter 2 of this Proposed RMP/Final EIS has added a description of the Proposed RMP. The Proposed 

RMP/Final EIS has corrected an error in the section-scale illustrations in Map 2-3 and Map 2-4 in the 

Draft RMP/EIS, which displayed incorrect widths for the Riparian Reserve on perennial streams and fishbearing streams under Alternative B and Sub-alternative B. The Proposed RMP/Final EIS also has 

corrected an error in the description of the management approach for Visual Resources Management 

under all action alternatives, and an error in the description of the management approach for Recreation 

Management Areas under all action alternatives. Finally, the Proposed RMP/Final EIS has expanded the 

discussion of alternatives considered but not analyzed in detail.

No Action Alternative

The BLM is carrying forward the No Action alternative as presented in the Draft RMP/EIS.

The Council on Environmental Quality NEPA regulations require that an EIS analyze a No Action 

alternative (40 CFR 1502.14(d)). The Council on Environmental Quality guidance explains that, for plans 
30 | P a g e

such as this RMP revision, No Action means there is no change from current management direction or 

level of management intensity (CEQ 1981). The No Action alternative, as presented in the Draft 

RMP/EIS, is implementation of the 1995 RMPs as written (in contrast to the BLM’s current 

implementation practices under the 1995 RMPs).

10 A section later in this chapter, titled Alternatives 

Considered but not Analyzed in Detail, includes further discussion of an alternative that would seek to 

continue the current practices. That section also includes discussion of an alternative that would seek to 

implement the 1995 RMPs at the sustained-yield timber harvest levels declared in the 1995 RMPs.

The land use allocations and management actions/direction in the 1995 RMPs for the Coos Bay, Eugene, 

Medford, Roseburg, and Salem Districts and the Klamath Falls Field Office of the Lakeview District, as 

amended and modified by court order, describe the No Action alternative (Figure 2-1, Table 2-1, and 

Map 2-1) and are incorporated here by reference. The No Action alternative, as analyzed in this Proposed 

RMP/Final EIS, includes Survey and Manage measures, consistent with—

 The January 2001, Record of Decision and Standards and Guidelines for Amendments to the 

Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines 

in Forest Service and Bureau of Land Management Planning Documents Within the Range of the 

Northern Spotted Owl;

 The 2001, 2002, and 2003 Annual Species Review modifications to the Survey and Manage

species list, except for the changes made for the red tree vole; and

 The Pechman exemptions.11

 

10 Implementation of the 1995 RMPs as written includes the incorporation of all amendments and plan maintenance 

of the 1995 RMPs. The BLM has documented all amendments and plan maintenance of the 1995 RMPs in the 

district annual program summaries and monitoring reports from 1996 through 2015.

11 The District Court for the Western District of Washington issued a remedy order on February 18, 2014, in the case 

of Conservation Northwest et al. v. Boonie et al., No. 08-1067-JCC (W.D. Wash.)/No. 11-35729 (9th Cir.) that 

vacated the 2007 Records of Decision to Remove or Modify the Survey and Manage Mitigation Measure Standards 

and Guidelines. Vacatur of the 2007 RODs has the effect of returning the BLM to the status quo in existence prior to 

the 2007 RODs, which was defined by three previous legal rulings, as follows:

 Judge Pechman reinstated the 2001 ROD, including any amendments or modifications to the 2001 ROD 

that were in effect as of March 21, 2004 (CV-04-00844-MJP, January 9, 2006), and this ruling incorporated 

the 2001, 2002, and 2003 Annual Species Reviews;

 The Ninth Circuit Court of Appeals in Klamath-Siskiyou Wildlands Center v. Boody, 468 F3d 549 (2006) 

vacated the 2001 Annual Species Review category change and 2003 Annual Species Review removal for 

the red tree vole in the mesic zone; and

 Judge Pechman ordered four categories of projects exempt from compliance with the Survey and Manage

standards and guidelines (CV-04-00844-MJP, October 11, 2006, ‘Pechman exemptions’): thinnings in 

forest stands younger than 80 years of age, culvert replacement/removal, riparian and stream improvement 

projects, and hazardous fuels treatments applying prescribed fire for noncommercial projects.
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Figure 2-1. No Action alternative land use allocations 

Table 2-1. No Action alternative land use allocations 

Land Use Allocation Acres Total Acres

(Percent)

Late-Successional Reserve* 879,031 36%

Riparian Reserve in Matrix 527,550 21%

Other Reserves†233,410 9%

Matrix‡691,998 28%

Eastside Management Area 146,867 6%

* Late-Successional Reserve includes Adaptive Management Areas within the Late-Successional Reserve and predictions of the 

acreage of newly discovered marbled murrelet sites. 

† Other Reserves in the No Action alternative include Congressionally Reserved lands, District-Designated Reserves, and lands 

reserved within the Matrix.

‡ Matrix includes the General Forest Management Area, Connectivity/Diversity Blocks, and Adaptive Management Areas. 

Late-Successional 

Reserve 

36% 

Other Reserves 

Matrix 

28% 

e 

ent 

Riparian Reserves 

in Matrix 

21% 

9%

Eastsid

Managem

Area

6%
32 | Page

Map 2-1. No Action alternative land use allocations 
33 | Page

Map 2-1. No Action alternative land use allocations (continued) 
34 | P a g e

For comparing the acreage by land use allocation for the No Action alternative to the action alternatives

and the Proposed RMP, the Matrix land use allocation in the No Action alternative is comparable to the 

Harvest Land Base land use allocation in the action alternatives and the Proposed RMP.

The Eastside Management Area in the No Action alternative comprises those BLM-administered lands in 

the Klamath Falls Field Office outside the range of the northern spotted owl. In the action alternatives and 

the Proposed RMP, the Eastside Management Area comprises those BLM-administered lands in the 

Klamath Falls Field Office east of Highway 97. Because of these different boundaries, the acreage for the 

Eastside Management Area is slightly higher in the No Action alternative than in the action alternatives

and the Proposed RMP.

The No Action alternative defined interim Riparian Reserve widths that could be modified after 

watershed analysis. For this analysis, the BLM assumed that the Riparian Reserve under the No Action 

alternative would remain at the interim widths.

The Riparian Reserve acreage for the No Action alternative in Figure 2-1 and Table 2-1, presents only 

the Riparian Reserve within the Matrix, which is how the 1995 RMPs presented the hierarchy of land use 

allocations. The Late-Successional Reserve acreage for the No Action alternative does not account for the 

Riparian Reserve within the Late-Successional Reserve. In the No Action alternative, the Riparian 

Reserve would overlay the Late-Successional Reserve, and implementation in those overlapping areas 

would apply the management objectives and management direction for both land use allocations (USDA

FS and USDI BLM 1994, pp. A-5 – A-6). As a result, the 1995 RMPs only accounted for the Riparian 

Reserve acreage in the Late-Successional Reserve as Late-Successional Reserve; the only Riparian 

Reserve acreage calculated were those in the Matrix. Thus, the acreage of Riparian Reserve and LateSuccessional Reserve presented in the 1995 RMPs cannot be directly compared to the acreages presented 

in this analysis for the action alternatives and the Proposed RMP.

To facilitate more direct comparison of these acreages by land use allocation for the No Action alternative 

to the action alternatives and the Proposed RMP, Figure 2-2 and Table 2-2, present a modified hierarchy 

of land use allocations in the No Action alternative to display the Riparian Reserve acreage regardless of 

the underlying land use allocation (Figure 2-1 and Table 2-1). The results are a reduction in acreage 

identified as Late-Successional Reserve and a corresponding increase in acreage identified as Riparian 

Reserve that allows for direct comparative analysis in this Proposed RMP/Final EIS.
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Figure 2-2. No Action alternative land use allocations with modified hierarchy 

Table 2-2. No Action alternative land use allocations with modified hierarchy 

Land Use Allocation Acres Total Acres

(Percent)

Late-Successional Reserve 478,860 19%

Riparian Reserve 927,721 38%

Other Reserves*233,410 9%

Matrix 691,998 28%

Eastside Management Area 146,867 6%

* Other Reserves in the No Action alternative include Congressionally Reserved lands, District-Designated Reserves, and lands 

reserved within the Matrix. 

Late-Successional 

Reserve

19%

Other

Reserves

9%

Matrix

28%

Eastside 

Management 

Area

6%

Riparian Reserve

38%
36 | P a g e

The Action Alternatives and the Proposed RMP 

The BLM is carrying forward the action alternatives and sub-alternatives as presented in the Draft 

RMP/EIS. The Proposed RMP and four action alternatives with two sub-alternatives comprise a range of 

management strategies that the BLM designed in the Draft RMP/EIS to meet the purpose and need 

discussed in Chapter 1. In addition, the BLM developed the action alternatives and the Proposed RMP to 

be consistent with the guidance for the formulation of alternatives discussed in Chapter 1. The action 

alternatives and the Proposed RMP examine potential management strategies through land use 

allocations, management objectives, and management direction. Some land use allocations, management 

objectives, and management direction are common to all action alternatives and the Proposed RMP, and 

some vary by action alternative, as described below. The BLM has developed the Proposed RMP as a 

variation on Alternative B from the Draft RMP/EIS.

The BLM developed the action alternatives in response to input received during external and internal 

scoping, and developed the Proposed RMP in consultation with cooperating agencies and Tribes and 

based on further input from public comments and analysis results from the Draft RMP/EIS. The action 

alternatives and the Proposed RMP described below include land use allocations designed to respond to 

the purpose and need for action, including areas managed for sustained-yield timber production that 

would provide the annual productive capacity of timber and areas reserved from sustained-yield timber 

production for purposes such as the protection of clean water and the conservation and recovery of ESAlisted species. Within the context of the purpose and need for action, the BLM developed the action 

alternatives and the Proposed RMP to mitigate adverse effects on natural resources. Several of the 

purposes of the action directly address avoiding or reducing adverse effects on natural resources, such as 

providing clean water in watersheds and restoring fire-adapted ecosystems. As such, the action 

alternatives and the Proposed RMP primarily address mitigating adverse effects through their design, 

specifically the land use allocations and the management direction. Additionally, the BLM developed two 

sub-alternatives, as described below, to consider how specific design changes might further mitigate 

adverse effects to specific resources.

Sub-alternatives

Sub-alternatives are variations of an action alternative that modify an individual component of the 

alternative to explore how these changes would alter certain outcomes. These examinations provide the 

responsible official with information that is useful for both fully understanding the alternatives and for 

informing the development of the Proposed RMP.

The BLM focuses and limits the analysis of the sub-alternatives to the specific analytical question that is 

associated with a sub-alternative; that is, how modifying a single component would alter the effects on the 

resources associated with that component. This is in contrast to the broader analysis that is associated 

with the No Action alternative, the four action alternatives, and the Proposed RMP, which explore the 

effects of the alternatives and the Proposed RMP on all resources. The sub-alternatives are variations on 

the action alternatives and, as such, could be carried forward as the Proposed RMP; their individual 

components could also be incorporated into the Proposed RMP.

The BLM developed two sub-alternatives in the Draft RMP/EIS, which vary individual components to 

test specific questions about alternative design based on input received during external and internal 

scoping. For both sub-alternatives, the BLM focused analysis on how the changes in the sub-alternative 

would alter effects on timber production and northern spotted owls. The BLM focused the analysis of 

these sub-alternatives on these two resources, because the modification of the alternative component 

would vary the approach to an element of northern spotted owl conservation, and the change in the sub-
37 | P a g e

alternatives would directly and explicitly alter the approach to timber production. The specific features of 

these sub-alternatives are described under the pertinent action alternatives.

Features Common to the Action Alternatives and the Proposed 

RMP

This section contains a summary of those features that are common to all action alternatives and the 

Proposed RMP. The subsequent section contains a description of the features that differ among the action 

alternatives and the Proposed RMP.

All action alternatives and the Proposed RMP include several types of land use allocations or 

administrative designations that the BLM will use to manage different resources or groups of resources. 

These types of allocations or designations include but are not limited to—

 Vegetation and habitat management (Congressionally Reserved and National Landscape 

Conservation System, District-Designated Reserves, Late-Successional Reserve, Riparian 

Reserve, Harvest Land Base, and Eastside Management Area);

 Land tenure (Zones 1, 2, or 3);

 Visual Resource Management (VRM) (Class I, II, III, or IV); and

 Public motorized access (open, limited, or closed).

Within each type of allocation or designation, including the examples above, all action alternatives and 

the Proposed RMP would assign each acre within the decision area to one, and only one category.12 For 

example, in the land tenure designation type, every acre in the decision area would be assigned to a single 

Land Tenure Zone 1, 2, or 3 category. Similarly, for visual resource management, every acre within the 

decision area would be assigned to a single VRM Class I, II, III, or IV category. See Figure 2-3 for a 

graphic example.

 

12 An exception are Areas of Critical Environmental Concern (ACECs) that would overlap the Harvest Land Base 

where the special management needed to maintain the relevant and important values of the ACEC would be 

compatible with sustained-yield timber production. In these areas, the BLM would apply the management direction 

for both ACECs and the Harvest Land Base.
38 | P a g e

Figure 2-3. Example of how decision area acres are assigned by land use allocation/administrative 

designation type

These different types of allocations or designations overlap. For example, the BLM might allocate an 

individual acre to the Riparian Reserve, Land Tenure Zone 2, Visual Resource Management Class IV, and 

closed to public motorized vehicle use.

The action alternatives and the Proposed RMP include the following land use allocations categories for 

vegetation and habitat management: Congressionally Reserved Lands and National Landscape 

Conservation System, District-Designated Reserves, Late-Successional Reserve, Riparian Reserve, 

Harvest Land Base, and Eastside Management Area. The location and acreage of these categories of 

allocations, with the exception of Congressionally Reserved Lands, vary by the alternatives and the 

Proposed RMP.

Within each action alternative and the Proposed RMP, the land use allocation categories of DistrictDesignated Reserves, Eastside Management Area, Harvest Land Base, Late-Successional Reserve, and 

Riparian Reserve have been further divided into sub-allocations with differing management direction. The 

Harvest Land Base has multiple sub-allocations with differing management direction for forest 

management summarized in Table 2-3. Appendix B of this Proposed RMP/Final EIS contains detailed 

descriptions of the management direction for the sub-allocations of the Harvest Land Base for the 

Proposed RMP. Appendix B – Management Objectives and Direction in the Draft RMP/EIS contains 

detailed descriptions of the management direction for the sub-allocations of the Harvest Land Base for 

Alternatives A–D and Sub-alternatives B and C, which are hereby incorporated by reference (USDI BLM 

2014, pp. 905–986).
39 | P a g e

Table 2-3. Forest management practices by Harvest Land Base sub-allocation

Harvest Land Base 

Sub-allocation

Alternatives that 

Include Sub-allocation Forest Management Practices

High Intensity 

Timber Area

Alt. A

Alt. C Thinning and regeneration harvest with no retention

Moderate Intensity 

Timber Area

Alt. B

Alt. D

Proposed RMP

Thinning and regeneration harvest with retention of 

5–15 percent of the pre-harvest basal area of the 

stand

Low Intensity Timber 

Area

Alt. B

Proposed RMP

Thinning and regeneration harvest with retention of 

15–30 percent of the pre-harvest basal area of the 

stand

Uneven-aged Timber 

Area

All action alternatives

Proposed RMP

Prescribed fire, thinning, single tree selection harvest, 

and group selection harvest

Owl Habitat Timber 

Area Alt. D

Thinning and uneven-aged timber harvest applied in 

a manner that would maintain and promote the 

development of northern spotted owl habitat

In the context of these land use allocations, the term ‘reserve’ indicates that the BLM or Congress have 

reserved lands within the allocation from sustained-yield timber production. These reserve land use 

allocations—Congressionally Reserved Lands and National Landscape Conservation System Lands, 

District-Designated Reserves, Late-Successional Reserve, and Riparian Reserve—are in contrast to the 

Harvest Land Base, which includes management objectives for sustained-yield timber production. This 

does not mean that the BLM is necessarily prohibiting active management in these reserve allocations. On 

the contrary, the action alternatives and the Proposed RMP include management direction to conduct the 

management actions necessary to achieve the management objectives for these reserve allocations.

Congressionally Reserved Lands and National Landscape

Conservation System

Congressionally Reserved Lands are those lands that Congress has designated and defined management 

through law, such as designated Wilderness and designated Wild and Scenic Rivers. The mandated 

management of these lands requires that the BLM reserve these lands from sustained-yield timber 

production. The location and acreage of Congressionally Reserved Lands does not vary among the 

alternatives and the Proposed RMP, including the No Action alternative.

In addition to Congressionally Reserved Lands, the BLM has also identified Wilderness Study Areas in 

the decision area, pursuant to Section 603 of the FLPMA. Until Congress makes a final determination on 

a Wilderness Study Area, the BLM manages these areas to preserve their suitability for designation as 

Wilderness.

District-Designated Reserves

District-Designated Reserves13 include lands that are reserved from sustained-yield timber production for 

a variety of reasons, including—

 

13 These areas have been termed Administratively Withdrawn in previous planning efforts. This Proposed 

RMP/Final EIS does not use the term withdrawn in this context to avoid confusion with the withdrawal of areas 

from operation of public land laws, location, and entry under mining laws, or application and offers under mineral 

leasing laws.
40 | P a g e

 Areas that the BLM has constructed for specific purposes (e.g., roads, buildings, maintenance 

yards, seed orchards, and other facilities and infrastructure);

 Areas that the BLM has identified through the Timber Production Capability Classification14

system as unsuitable for sustained-yield timber production (e.g., rock outcrops);

 Areas of Critical Environmental Concern, including Research Natural Areas, that would not 

overlap the Harvest Land Base; and

 Other reserves (e.g., Special Recreation Management Areas that would not overlap the Harvest 

Land Base, areas protected for Bureau Sensitive species, and District-Designated Reserve –

Lands Managed for their Wilderness Characteristics).

Under the action alternatives and the Proposed RMP, the BLM would manage roads, maintenance yards, 

buildings, and other facilities for the purpose for which they were constructed. 

The BLM identifies lands as unsuitable for sustained-yield timber production through the Timber 

Production Capability Classification system and may manage these areas for other uses, if those uses are 

compatible with the reason for which the BLM has reserved these lands (as identified by the Timber 

Production Capability Classification codes). The BLM will periodically add additional areas to those 

areas reserved through updates to the Timber Production Capability Classification system, when 

examinations indicate that an area meets the criteria for reservation. The BLM may also delete areas from 

those areas reserved and return the area to sustained-yield timber production through updates to the 

Timber Production Capability Classification system, when examinations indicate that an area does not 

meet the criteria for reservation. The BLM will implement these additions and deletions to the Timber 

Production Capability Classification through plan maintenance, because such changes will represent 

minor changes based on further refining the decision in the RMP (Appendix X).

Areas of Critical Environmental Concern are lands where special management attention is needed to 

protect and prevent irreparable damage to important historic, cultural, or scenic values, fish, and wildlife 

resources or other natural systems or processes or to protect life and provide safety from natural hazards, 

pursuant to Section 202(c)(3) of the FLPMA. For areas that have relevant and important values and need 

special management to maintain those values, the BLM will designate and manage Areas of Critical 

Environmental Concern on public domain lands and acquired lands. The BLM will also designate and 

manage Areas of Critical Environmental Concern on O&C lands where the special management needed to 

maintain relevant and important values would not conflict with the planning for sustained-yield timber 

production for the purposes of the O&C Act. For example, designating and managing Areas of Critical 

Environmental Concern on O&C lands would not conflict with sustained-yield timber production in the 

following circumstances: on non-forested lands; on O&C lands that would otherwise be allocated to a 

land use allocation that would preclude sustained-yield timber production; or on lands for which the 

Timber Productivity Capability Classification category is ‘not included in the harvest land base.’ In 

addition, designating and managing Areas of Critical Environmental Concern on O&C lands would not 

conflict with sustained-yield timber production if the special management needed to maintain relevant 

and important values were compatible with sustained-yield timber production, even if that special 

management might condition how sustained-yield timber production would be conducted. In these areas, 

the BLM would designate Areas of Critical Environmental Concern within the Harvest Land Base and 

apply the management direction for both Areas of Critical Environmental Concern and the Harvest Land 

Base. For Areas of Critical Environmental Concern not within the O&C Harvest Land Base, such as those 

 

14 The Timber Production Capability Classification is an analytical classification system by which the BLM 

inventories and identifies sites as capable of supporting sustained-yield timber production without degrading the 

site’s productive capacity. This classification considers factors such as soil depth, available moisture, slope, 

drainage, and stability. Sites that are not capable of supporting sustained-yield timber production are not included in 

the Harvest Land Base.
41 | P a g e

that would be within the Late-Successional Reserve or are on acquired lands within the Harvest Land 

Base, the BLM would allocate these as District-Designated Reserves where identified that special 

management is needed to maintain the relevant and important values.

The BLM would designate Special Recreation Management Areas as District-Designated Reserves on 

public domain lands and acquired lands; on non-forested O&C lands; on O&C lands that would otherwise 

be allocated to a land use allocation that would preclude sustained-yield timber production; or on O&C 

lands for which the Timber Productivity Capability Classification category is not included in the Harvest 

Land Base. The BLM would designate Special Recreation Management Areas on the Harvest Land Base 

on O&C lands to the extent that the management for recreation and visitor services would be compatible 

with planning for sustained-yield timber production for the purposes of the O&C Act, even if that 

management might condition how sustained-yield timber production would be conducted, consistent with 

the discussion in Chapter 1 under ‘The O&C Act and the FLPMA.’ In these areas, the BLM would 

manage recreation as the predominant use of the lands, applying the management direction and achieving 

the management objectives for both Special Recreation Management Areas and the Harvest Land Base.

District-Designated Reserve – Lands Managed for Their Wilderness Characteristics are areas outside of 

designated Wilderness or Wilderness Study Areas that the BLM has decided to manage for their 

wilderness characteristics. The BLM would reserve lands with wilderness characteristics (outside of 

Wilderness or Wilderness Study Areas) on O&C lands consistent with the discussion in Chapter 1 under 

‘The O&C Act and the FLPMA.’

Land Use Allocation Objectives that are Common to the Action 

Alternatives and the Proposed RMP in the Proposed RMP/Final 

EIS

Eastside Management Area

All action alternatives and the Proposed RMP include an Eastside Management Area land use allocation, 

which applies to BLM-administered lands in the Klamath Falls Field Office east of Highway 97. On 

forested lands, this allocation includes management objectives to—

 Manage forested lands on a sustainable basis for multiple uses including wildlife habitat, 

recreational needs, riparian habitat, cultural resources, community stability, and commodity 

production, including commercial timber and other forest products.

 Promote development of fire-resilient forests. 

 Offer for sale the probable sale quantity of 350 thousand board feet (Mbf) of timber per year.

On non-forested lands, this allocation includes management objectives to—

 Manage non-forested lands with the intent of maintaining or improving wildlife habitat and 

rangeland conditions based on ecological site parameters. Where conditions are currently late 

seral or potential natural community, maintain these conditions. Where conditions are early or 

mid seral, improve conditions towards late seral or potential natural community.

 Manage non-forested lands for multiple uses in addition to those listed above including 

recreational needs, community stability, and commodity production. Commodities include 

firewood, logs, biomass, chips, and other products and byproducts from juniper woodlands and 

rangelands.

 Promote development of fire-resilient woodlands and rangelands.

 Provide for the conservation of Bureau Special Status Species.
42 | P a g e

The Eastside Management Area – Riparian Reserve includes management objectives to—

 Provide for conservation of Bureau Special Status fish and other Bureau Special Status riparianassociated species.

 Provide for the riparian and aquatic conditions that supply stream channels with shade, sediment

filtering, leaf litter and large wood sources, and stream bank stability.

 Maintain and restore water quality and hydrologic functions.

 Maintain and restore access to stream channels for all life stages of aquatic species.

Maintain and restore the proper functioning condition and ecological site potential of riparian and 

wetland areas.

Harvest Land Base

The Harvest Land Base in the action alternatives and the Proposed RMP has management objectives to—

 Manage forests to achieve continual timber production that can be sustained through a balance of 

growth and harvest;

 Offer for sale the declared Allowable Sale Quantity of timber;

 Recover economic value from timber following disturbances, such as fires, windstorms, disease, 

or insect infestations;

 In harvested or disturbed areas, ensure the establishment and survival of desirable trees 

appropriate to the site and enhance their growth; and

 Enhance the economic value of timber in forest stands.

Late-Successional Reserve

The Late-Successional Reserve in the action alternatives and the Proposed RMP has management 

objectives to—

 Maintain nesting-roosting habitat for the northern spotted owl and nesting habitat for the marbled 

murrelet.

 Promote the development of nesting-roosting habitat for the northern spotted owl in stands that do 

not currently support northern spotted owl nesting and roosting.

 Promote the development of nesting habitat for the marbled murrelet in stands that do not 

currently meet nesting habitat criteria.

 Promote the development and maintenance of foraging habitat for the northern spotted owl, 

including creating and maintaining habitat to increase diversity and abundance of prey for the 

northern spotted owl.

Riparian Reserve

The Riparian Reserve (west of Highway 97) in the action alternatives and the Proposed RMP has 

management objectives to—

 Contribute to the conservation and recovery of ESA-listed fish species and their habitats and 

provide for conservation of Bureau Special Status fish and other special status riparian-associated 

species;

 Maintain and restore riparian areas, stream channels and wetlands by providing forest shade, 

sediment filtering, wood recruitment, stability of stream banks and channels, water storage and 

release, vegetation diversity, nutrient cycling, and cool and moist microclimates;

 Maintain water quality and stream flows within the range of natural variability, to protect aquatic 

biodiversity, and provide quality water for contact recreation and drinking water sources;

 Meet ODEQ water quality criteria;

 Maintain high-quality water and contribute to the restoration of degraded water quality 

downstream of BLM-administered lands; and

 Maintain high-quality waters within ODEQ designated Source Water Protection watersheds.
43 | P a g e

Resource-specific Objectives that are Common to all action 

alternatives and the Proposed RMP in the Proposed RMP/Final 

EIS

For many programs or resources, the management objectives and management direction differ from the 

No Action alternative, but do not vary among the action alternatives and the Proposed RMP. For some of 

these resources or programs, the management objectives and management direction do not vary among 

the action alternatives and the Proposed RMP, but the management of the resource is tied to allocations 

that do vary among action alternatives and the Proposed RMP. For example, the management objectives 

and management direction for designated Areas of Critical Environmental Concern do not vary among the 

action alternatives and the Proposed RMP. However, which specific areas the BLM would designate as 

Areas of Critical Environmental Concern would vary with the land use allocations of the action 

alternatives and the Proposed RMP. The following section summarizes the resource-specific management 

objectives that are common to the action alternatives and the Proposed RMP. Appendix B of this 

Proposed RMP/Final EIS contains detailed descriptions of the resource-specific management objectives

for the Proposed RMP. Appendix B – Management Objectives and Direction in the Draft RMP/EIS 

contains detailed descriptions of the resource-specific management objectives for Alternatives A–D and 

Sub-alternatives B and C, which are hereby incorporated by reference.

Air Quality: The BLM would follow the Clean Air Act by protecting air quality in Class 1 areas, such as 

designated Wilderness Areas, and preventing exceedances of National, State, or local ambient air quality 

standards.

Areas of Critical Environmental Concern (ACECs): The BLM would manage designated ACECs to 

maintain and restore their relevant and important values (though the array of ACECs that the BLM would 

designate varies by the alternatives and the Proposed RMP).

Cultural/Paleontological Resources: The BLM would protect significant cultural resources and ensure 

that all land and resource uses comply with the National Historic Preservation Act. The BLM would 

protect and preserve significant localities from natural or human-caused deterioration or potential conflict 

with other resources.

Fire and Fuels: In responding to wildfires, the BLM would provide for public and firefighter safety 

while meeting land management objectives. The BLM would also manage the land to restore and 

maintain resilience to wildfires and to decrease the risk of catastrophic wildfires.

Fisheries: The BLM would manage riparian areas to maintain and improve the aquatic habitat across the 

landscape.

Forest Management: The BLM would enhance the health, stability, growth, and vigor of forest stands. 

The BLM would not allow management activities that would disrupt the Density Management study sites 

until data collection is complete.

Hydrology: The BLM would manage to provide water that meets Oregon Department of Environmental 

Quality water quality standards for drinking water, contact recreation, and aquatic biodiversity.

Invasive Species: The BLM would prevent the introduction and spread of non-native invasive species.
44 | P a g e

Lands, Realty, and Roads: The BLM would adjust land tenure zones to facilitate potential changes in 

ownership to improve the management of resources and enhance public resource values. The BLM would 

also provide legal access to BLM-administered lands and facilities and rights-of-way, permits, leases, and 

easements in a manner that is consistent with Federal and State laws.

Minerals: The BLM would manage mineral resources in a manner that allows for their orderly and 

efficient development.

Rare Plants and Fungi: The BLM would manage to contribute toward the recovery of ESA-listed plant 

species. The BLM would also manage for an array of natural communities including oak woodlands, 

shrublands, grasslands, cliffs, rock outcrops, talus slopes, meadows, and wetlands, and would support 

ecological processes and disturbance mechanisms to allow for a range of seral conditions.

Recreation: The BLM would provide diverse recreational opportunities.

National Landscape Conservation System: The BLM would conserve, protect, and restore areas that 

Congress has designated for their outstanding values.

Travel and Transportation: The BLM would maintain a transportation network that best meets the full 

range of public, resource management, and administrative access needs.

Visual Resource Management: The BLM would manage for the protection of scenic values on public 

lands. The BLM would consider higher levels of protection where visual resource management is an issue 

or where high value visual resources exist (i.e., high scenic quality, visual sensitivity, and public 

visibility).

Soils: The BLM would manage to maintain the overall soil quality of BLM-administered lands.

Sustainable Energy: The BLM would allow for the development of sustainable energy resources to the 

maximum extent possible without precluding other land uses.

Wild Horses: The BLM would maintain a healthy population of wild and free-roaming horses in the 

Pokegama Herd Management Area.

Wildlife: The BLM would manage to contribute to the conservation and recovery of ESA-listed wildlife 

species. It would also implement proactive conservation measures that reduce or eliminate threats to 

Bureau Sensitive species to minimize the likelihood of and need for listing of these species under the 

Endangered Species Act.

Under all action alternatives and the Proposed RMP, the BLM would implement administrative actions at 

approximately the same levels as during the past decade. Administrative actions are routine transactions 

and activities that are required to serve the public and to provide optimum management of resources, 

including:

 Competitive and commercial recreation activities

 Special forest product collection permit issuance

 Lands and realty actions (including the issuance of grants, leases, and permits)

 Trespass resolution

 Facility maintenance

 Facility improvements

 Road maintenance
45 | P a g e

 Hauling permit issuance

 Recreation site maintenance

 Recreation site improvement

 Hazardous materials removal

 Abandoned Mine Land physical closure or removal and environmental remedial actions

 Law enforcement

 Legal land or mineral estate ownership surveys

 Engineering support assistance in mapping

 Field visits for the design of projects (including clearance inventories) and contract administration

 Tree sampling (including using the 3P fall, buck, and scale sampling method)

 Project implementation monitoring and plan effectiveness monitoring

 Incidental live or dead tree removal for safety or operational reasons

 Wildlife, fisheries, or plant community and population survey or monitoring

 Native plant seed collection and material development

Wild and Scenic Rivers

Under the No Action alternative, the BLM would continue to manage the 51 eligible Wild and Scenic 

River segments under interim management to protect their ORVs, water quality, free-flowing 

characteristics, and tentative classification as Wild, Scenic, or Recreational until suitability is determined

during subsequent land use planning efforts.

Action Alternative Descriptions

This section includes a summary of those features that differ among the action alternatives. Appendix B –

Management Objectives and Direction of the Draft RMP/EIS contains detailed descriptions by alternative 

of the management objectives and management direction that differ among the action alternatives, which 

are incorporated here by reference.

Alternative A

Alternative A has a Late-Successional Reserve larger than the No Action alternative (Figure 2-4, Table 

2-4, and Map 2-2; compare to Figure 2-2, Table 2-2). The Harvest Land Base is comprised of the 

Uneven-aged Timber Area and the High Intensity Timber Area. The High Intensity Timber Area includes 

regeneration harvest with no retention (i.e., clearcuts).
46 | P a g e

Late-Successional 

Reserve

46%

Other Reserves

7%

Harvest Land 

Base

14%

Eastside 

Management 

Area

6%

Riparian Reserve

27%

Figure 2-4. Alternative A land use allocations 

Table 2-4. Alternative A land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

1,147,527 46%

Structurally-complex Forest 655,125 26%

Late-Successional Reserve – Moist 265,376 11%

Late-Successional Reserve – Dry 188,440 8%

Existing Occupied Marbled Murrelet Sites 38,312 2%

Existing Red Tree Vole Sites* 274 <1%

Riparian 

Reserve 676,917 27% Riparian Reserve – Moist 441,603 18%

Riparian Reserve – Dry 235,313 9%

Other 

Reserves 170,540 7% Congressionally Reserved 40,537 2%

District-Designated Reserves 130,003 5%

Harvest Land 

Base 343,900 14% High Intensity Timber Area 289,060 12%

Uneven-aged Timber Area 54,840 2%

Eastside 

Management 

Area

139,972 6% - 139,972 6%

Totals 2,478,856 -

* Existing Red Tree Vole Sites means existing sites of the North Oregon Coast Distinct Population Segment of the red tree vole.
47 | P a g e

Page intentionally left blank
48 | Page

Map 2-2. Alternative A land use allocations 
49 | Page

Map 2-2. Alternative A land use allocations (continued) 
50 | P a g e

Late-Successional Reserve

The Late-Successional Reserve includes, primarily, Structurally-complex Forest, Large Block Forest 

Reserves (Late-Successional Reserve – Moist and Late-Successional Reserve – Dry), and much smaller 

acreages from existing occupied marbled murrelet sites and existing sites of the North Oregon Coast 

Distinct Population Segment of the red tree vole. Within the Late-Successional Reserve, the BLM would 

not conduct timber salvage after disturbance, except when necessary to protect public health and safety, 

or to keep roads and other infrastructure clear of debris.

Structurally-complex Forest

Alternative A includes within the Late-Successional Reserve all stands 120-years old and older, 

based on the current age of stands in the BLM Forest Operations Inventory.

Large Block Forest Reserves: Late-Successional Reserve – Moist and Late-Successional 

Reserve – Dry15

Alternative A includes within the Late-Successional Reserve all northern spotted owl critical 

habitat designated in 2013 and marbled murrelet critical habitat designated in 2011. In moist 

forests, the BLM would conduct thinning to promote the development of structurally-complex 

forest, but without commercial removal of timber (i.e., down woody debris and snag creation 

only). In dry forests, the BLM would conduct activities including thinning and prescribed burning 

to promote the development of structurally-complex forest and to improve resilience to 

disturbance. In dry forests, thinning would include removing cut trees, including commercial 

removal, as needed to reduce the risk of uncharacteristic high-severity or high-intensity fire.

Riparian Reserve

In Alternative A, the Riparian Reserve encompasses lands within one site-potential tree height16 on either 

side of all streams.

The Riparian Reserve includes an inner zone in which thinning is not permitted. Inner zone widths are—

 120 feet on either side of perennial and fish-bearing intermittent streams; and

 50 feet on either side of non-fish-bearing, intermittent streams.

Outside of the inner zone, the BLM would conduct thinning as needed to ensure that stands are able to 

provide trees to form stable instream structures. In moist forests, the BLM would conduct thinning 

without commercial removal of timber (i.e., down woody material and snag creation only). In dry forests, 

activities would include prescribed burning and thinning that would include removal of cut trees, 

including commercial removal, as needed to reduce the risk of uncharacteristic high-severity or highintensity fire.

Harvest Land Base

The Harvest Land Base is comprised of the Uneven-aged Timber Area and the High Intensity Timber 

Area. The allocation of the Uneven-aged Timber Area in Alternative A is based on areas below an 

average annual precipitation threshold. Timber management in the High Intensity Timber Area includes 

thinning and regeneration harvest with no retention (i.e., clearcuts). The High Intensity Timber Area has 

no snag or down woody material retention requirements.

 

15 For the purpose of Late-Successional Reserve and Riparian Reserve management in Alternative A, dry forests are 

defined by dry and very dry forest types identified by potential vegetation types.

16 Site-potential tree height is the average maximum height of the tallest dominant trees (200 years or older) for a 

given site class. Site-potential tree heights generally range from 140 feet to 240 feet across the decision area, 

depending on site productivity.
51 | P a g e

Wildlife

Within the Harvest Land Base, Alternative A does not include—

 Specific protections for northern spotted owl known or historic sites;

 A requirement for surveys for the marbled murrelet prior to management actions;

 Specific management requirements for trees capable of providing marbled murrelet nesting 

structures in younger stands; or

 A requirement for surveys for North Oregon Coast Distinct Population Segment of the red tree 

vole prior to management actions.

Rare Plants and Fungi

The BLM would create new populations and augment existing populations of ESA-listed and other 

special status plants and fungi to meet recovery plan or conservation strategy objectives.

Invasive Species

Alternative A does not include treatment of sudden oak death infection sites.

Livestock Grazing

The BLM would manage allotments in compliance with Standards for Rangeland Health and Guidelines 

for Livestock Grazing Management for Public Lands in Oregon and Washington (USDI BLM 1997). The 

BLM would adjust grazing levels and management practices when needed to meet or make progress 

toward meeting the standards for rangeland health. The BLM would make unavailable to grazing those 

allotments that have been generally been vacant or inactive for 5 years or more and currently have no 

Section 3 or Section 15 grazing preference.

Minerals

Under Alternative A, the BLM would recommend for withdrawal from locatable mineral entry 170,622

acres (in addition to the 98,400 acres previously withdrawn) and would close 200,878 acres to salable 

mineral material disposal.

Areas of Critical Environmental Concern

Under Alternative A, the BLM would designate 107 Areas of Critical Environmental Concern.

Recreation Management Areas

Alternative A includes designation of Special Recreation Management Areas where developed recreation 

sites or facilities currently exist. In the rest of the decision area, the BLM would not manage specifically 

for recreation.

Lands with Wilderness Characteristics

Alternative A includes management for wilderness characteristics of all identified lands with wilderness 

characteristics that are not within the Harvest Land Base.

Wild and Scenic Rivers

Under Alternative A, the BLM would not recommend any of the 51 eligible Wild and Scenic River

segments for inclusion in the National Wild and Scenic River System.

Visual Resource Management

Under Alternative A, the BLM would manage Congressionally Reserved lands where decisions have been 

made to preserve a natural landscape (e.g., designated Wilderness Areas and the Wild sections of Wild 

and Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following as 

VRM Class II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; 
52 | P a g e

National Trail management corridors; District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics; and Special Recreation Management Areas that fall within the Primitive and Backcountry 

setting. The BLM would manage the following as VRM Class III: designated and recommended suitable 

Wild and Scenic Rivers classified as Recreational; and Special and Extensive Recreation Management 

Areas that fall within the Middle Country setting. The BLM would manage ACECs as a VRM class 

commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class III as VRM Class III). 

The BLM would manage all other lands as Visual Resource Management Class IV.

Alternative B

Alternative B has a Late-Successional Reserve similar in size to Alternative A, though of a different 

spatial design (see Figure 2-5, Table 2-5, and Map 2-3). The Harvest Land Base is comprised of the 

Uneven-aged Timber Area, Low Intensity Timber Area, and Moderate Intensity Timber Area. The portion 

of the Harvest Land Base in Uneven-aged Timber Area is the largest of all the action alternatives. The 

Low Intensity Timber Area and Moderate Intensity Timber Area include regeneration harvest with 

varying levels of retention.

A sub-alternative of Alternative B (hereafter Sub-alternative B) includes reserving all known and historic 

northern spotted owl sites that would be in the Harvest Land Base in Alternative B. All other features of 

Sub-alternative B are the same as Alternative B. The description of Sub-alternative B, including the 

acreage of each land use allocation and a map, follows the description of Alternative B.
53 | P a g e

Figure 2-5. Alternative B land use allocations 

Table 2-5. Alternative B land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

1,127,320 46%

Structurally-complex Forest 463,910 19%

Late-Successional Reserve – Moist 371,305 15%

Late-Successional Reserve – Dry 223,399 9%

Existing Occupied Marbled Murrelet Sites 41,633 2%

Predicted Marbled Murrelet Sites 13,738 <1%

Existing Red Tree Vole Sites* 297 <1%

Predicted Red Tree Vole Sites* 13,039 <1%

Riparian 

Reserve 382,805 15% Riparian Reserve – Moist 215,231 9%

Riparian Reserve – Dry 167,574 7%

Other 

Reserves 260,510 11% Congressionally Reserved 40,537 2%

District-Designated Reserves 219,973 9%

Harvest 

Land Base 556,335 22%

Moderate Intensity Timber Area 210,087 8%

Low Intensity Timber Area 72,358 3%

Uneven-aged Timber Area 273,890 11%

Eastside 

Management 

Area

151,885 6% - 151,885 6%

Totals 2,478,856 -

* Existing Red Tree Vole Sites and Predicted Red Tree Vole Sites means those sites of the North Oregon Coast Distinct 

Population Segment.

Late-Successional 

Reserve 

46% 

vest Land 

Base 

22% 

astside 

nagement 

Area 

6% 

Riparian Reserve 

15% 

Other Reserves

11%

Har

E

Ma
54 | Page

Map 2-3. Alternative B land use allocations 
55 | Page

Map 2-3. Alternative B land use allocations (continued) 
56 | P a g e

Late-Successional Reserve 

The Late-Successional Reserve includes, primarily, Structurally-complex Forest, Large Block Forest 

Reserves (Late-Successional Reserve – Moist and Late-Successional Reserve – Dry), and much smaller 

acreages from existing occupied marbled murrelet sites and existing sites of the North Oregon Coast 

Distinct Population Segment of the red tree vole. In addition, Alternative B includes requirements for 

surveys for the marbled murrelet and the North Oregon Coast Distinct Population Segment of the red tree 

vole, as described below; newly discovered sites would be included in the Late-Successional Reserve. 

Thus, this description of the Late-Successional Reserve includes predictions of the acreage of newly 

discovered marbled murrelet and red tree vole sites. Within the Late-Successional Reserve, the BLM 

would not conduct timber salvage after disturbance, except when necessary to protect public health and 

safety, or to keep roads and other infrastructure clear of debris. 

Structurally-complex Forest Alternative B includes within the Late-Successional Reserve all 

stands identified by existing, district-specific information on structurally-complex forests. 

Large Block Forest Reserves: Late-Successional Reserve – Moist and Late-Successional 

Reserve – Dry17

Alternative B includes within the Late-Successional Reserve blocks of functional and potential 

northern spotted owl habitat, sufficient to meet block size and spacing requirements (Thomas et 

al. 1990, pp. 24, 28) in all provinces except the Coast Range province, where reserves include 

blocks of habitat without limitations for size and spacing. In moist forests, the BLM would 

conduct thinning to promote the development of structurally-complex forest, which may include 

commercial removal of cut trees. In dry forests, the BLM would conduct activities including 

thinning and prescribed burning to promote the development of structurally-complex forest and to 

improve resilience to disturbance, which may include commercial removal of cut trees. 

Riparian Reserve 

In Alternative B, the Riparian Reserve encompass lands within—

 One site-potential tree height on either side of fish-bearing and perennial streams; 

 100 feet on either side of debris-flow-prone, non-fish-bearing, intermittent streams; and 

 50 feet on either side of other non-fish-bearing, intermittent streams. 

The Riparian Reserve includes an inner zone in which thinning is not permitted. Inner zone widths are—

 60 feet on either side of perennial and fish-bearing intermittent streams; and 

 50 feet on either side of non-fish-bearing, intermittent streams. 

Outside of the inner zone, the BLM would conduct thinning, which may include commercial removal, as 

needed to develop diverse and structurally-complex riparian stands. 

Harvest Land Base 

The Harvest Land Base is comprised of the Uneven-aged Timber Area, Low Intensity Timber Area, and 

Moderate Intensity Timber Area. The allocation bases the Uneven-aged Timber Area in Alternative B on 

dry and very dry forest types identified by potential vegetation types. The portion of the Harvest Land 

Base outside of the Uneven-aged Timber Area is divided between the Low Intensity Timber Area in 

designated northern spotted owl critical habitat and the Moderate Intensity Timber Area outside of 

designated northern spotted owl critical habitat. Timber harvest in the Low Intensity Timber Area 

includes thinning and regeneration harvest with retention of 15–30 percent of the stand. In the Low 

Intensity Timber Area, the BLM would rely on natural tree regeneration after timber harvest. Timber 

 

17 For the purpose of Late-Successional Reserve and Riparian Reserve management in Alternative B, dry forests are 

defined by dry and very dry forest types identified by potential vegetation types. 
57 | Page

harvest in the Moderate Intensity Timber Area includes thinning and regeneration harvest with retention 

of 5–15 percent of the stand. In the Moderate Intensity Timber Area, the BLM would use either natural 

tree regeneration or replanting after timber harvest, but would maintain early seral habitat conditions for 

several decades after harvest. 

Wildlife

Within the Harvest Land Base, Alternative B includes—

 No specific protections for northern spotted owl known or historic sites; 

 A requirement for surveys for the marbled murrelet prior to management actions in marbled 

murrelet Zone 1 and protection of habitat within 300 feet around newly discovered occupied sites; 

 The protection of trees capable of providing marbled murrelet nesting structures in younger 

stands in marbled murrelet Zone 1; and 

 A requirement for surveys for North Oregon Coast Distinct Population Segment of the red tree 

vole prior to management actions and protection of habitat areas around newly discovered nest 

sites. 

Rare Plants and Fungi

The BLM would manage mixed hardwood/conifer communities outside of the Harvest Land Base to 

maintain and enhance oak persistence and structure. 

Invasive Species

Alternative B includes treatment at all sudden oak death infection sites outside of the Riparian Reserve 

and no treatment at infection sites in the Riparian Reserve. 

Livestock Grazing

The BLM would manage allotments in compliance with Standards for Rangeland Health and Guidelines 

for Livestock Grazing Management for Public Lands in Oregon and Washington (USDI BLM 1997). The 

BLM would adjust grazing levels and management practices when needed to meet or make progress 

toward meeting the standards for rangeland health. The BLM would make unavailable to grazing those 

allotments that have been generally been vacant or inactive for 5 years or more and currently have no 

Section 3 or Section 15 grazing preference. 

Minerals

Under Alternative B, the BLM would recommend for withdrawal from locatable mineral entry 168,072 

acres (in addition to the 98,400 acres previously withdrawn) and would close 194,858 acres to salable 

mineral material disposal. 

Areas of Critical Environmental Concern 

Under Alternative B, the BLM would designate 105 Areas of Critical Environmental Concern. 

Recreation Management Areas 

Alternative B includes designation of Special Recreation Management Areas at currently developed 

recreation facilities, and on lands where there are both unique recreation opportunities and where 

designation would not conflict with sustained-yield timber harvest. Alternative B includes designation of 

Extensive Recreation Management Areas where the BLM has developed and currently manages 

recreation activities outside of developed facilities, primarily where the BLM has authorized motorized 

and non-motorized trails, and where the BLM currently manages dispersed recreation activities. In the 

rest of the decision area, the BLM would not manage specifically for recreation. 

Lands with Wilderness Characteristics
58 | Page

Alternative B includes management for wilderness characteristics of all identified lands with wilderness 

characteristics that are outside of the Harvest Land Base, and where they are within compatible existing 

and potential Recreation Management Areas. 

Wild and Scenic Rivers

Under Alternative B, the BLM would recommend for inclusion in the National Wild and Scenic River 

System six eligible river segments that the BLM found suitable during the BLM’s suitability study (as 

outlined in BLM Manual 6400, USDI BLM 2012b). 

Visual Resource Management

Under Alternative B, the BLM would manage Congressionally Reserved lands where decisions have been 

made to preserve a natural landscape (e.g., designated Wilderness Areas and the Wild sections of Wild 

and Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following as 

VRM II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; National 

Trail management corridors; District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics and Special Recreation Management Areas that fall within the Primitive and Backcountry 

setting. The BLM would manage the following as VRM III: designated and recommended suitable Wild 

and Scenic Rivers classified as Recreational, and Special and Extensive Recreation Management Areas 

that fall within the Middle Country setting. The BLM would manage ACECs as a VRM class 

commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class III as VRM Class III). 

The BLM would manage all other lands as Visual Resource Management Class IV. 

58 | Page

Alternative B includes management for wilderness characteristics of all identified lands with wilderness 

characteristics that are outside of the Harvest Land Base, and where they are within compatible existing 

and potential Recreation Management Areas. 

Wild and Scenic Rivers

Under Alternative B, the BLM would recommend for inclusion in the National Wild and Scenic River 

System six eligible river segments that the BLM found suitable during the BLM’s suitability study (as 

outlined in BLM Manual 6400, USDI BLM 2012b). 

Visual Resource Management

Under Alternative B, the BLM would manage Congressionally Reserved lands where decisions have been 

made to preserve a natural landscape (e.g., designated Wilderness Areas and the Wild sections of Wild 

and Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following as 

VRM II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; National 

Trail management corridors; District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics and Special Recreation Management Areas that fall within the Primitive and Backcountry 

setting. The BLM would manage the following as VRM III: designated and recommended suitable Wild 

and Scenic Rivers classified as Recreational, and Special and Extensive Recreation Management Areas 

that fall within the Middle Country setting. The BLM would manage ACECs as a VRM class 

commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class III as VRM Class III). 

The BLM would manage all other lands as Visual Resource Management Class IV. 

57 | Page

designation would not conflict with sustained-yield timber harvest. Alternative B includes designation of 

Extensive Recreation Management Areas where the BLM has developed and currently manages 

recreation activities outside of developed facilities, primarily where the BLM has authorized motorized 

and non-motorized trails, and where the BLM currently manages dispersed recreation activities. In the 

rest of the decision area, the BLM would not manage specifically for recreation. 

Lands with Wilderness Characteristics
59 | P a g e

Sub-alternative B 

Sub-alternative B is identical to Alternative B, except that it includes protection of habitat within the 

home ranges of all northern spotted owl known and historic sites that would be within the Harvest Land 

Base. This single change in design increases the Late-Successional Reserve to 57 percent of the decision 

area, which is larger than any other alternative, and reduces the Harvest Land Base to 12 percent of the 

decision area, which is smaller than any other alternative (Figure 2-6, Table 2-6, and Map 2-4).
60 | P a g e

Figure 2-6. Sub-alternative B land use allocations 

Table 2-6. Sub-alternative B land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

1,422,933 57%

Structurally-complex Forest 463,910 19%

Late-Successional Reserve – Moist 371,305 15%

Late-Successional Reserve – Dry 223,399 9%

Northern Spotted Owl Sites 295,614 12%

Existing Occupied Marbled Murrelet Sites 41,633 2%

Predicted Marbled Murrelet Sites 13,738 <1%

Existing Red Tree Vole Sites* 297 <1%

Predicted Red Tree Vole Sites* 13,039 <1%

Riparian 

Reserve 382,805 15% Riparian Reserve – Moist 215,231 9%

Riparian Reserve – Dry 167,574 7%

Other 

Reserves 223,111 9% Congressionally Reserved 40,537 2%

District-Designated Reserves 182,574 7%

Harvest 

Land Base 298,121 12%

Moderate Intensity Timber Area 129,120 5%

Low Intensity Timber Area 30,761 1%

Uneven-aged Timber Area 138,239 6%

Eastside 

Management 

Area

151,885 6% - 151,885 6%

Totals 2,478,856 -

* Existing Red Tree Vole Sites and Predicted Red Tree Vole Sites means those sites of the North Oregon Coast Distinct 

Population Segment of the red tree vole north of Highway 20. 

Late-Successional 

Reserve 

Other Reserves 

9% 

st 

astside 

agement 

Area 

6% 

Riparian Reserve 

16% 

57%

Harve

Land

Base

12%

E

Man
61 | P a g e

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62 | Page

Map 2-4. Sub-alternative B land use allocations 
63 | Page

Map 2-4. Sub-alternative B land use allocations (continued) 
64 | P a g e

Alternative C

Alternative C has the largest Harvest Land Base of any of the action alternatives (Figure 2-7, Table 2-7, 

and Map 2-5). The Harvest Land Base is comprised of the Uneven-aged Timber Area and the High 

Intensity Timber Area. The High Intensity Timber Area includes regeneration harvest with no retention 

(i.e., clearcuts). Alternative C has the smallest acreage in the Riparian Reserve of the action alternatives.

A sub-alternative of Alternative C (hereafter Sub-alternative C) includes reserving all forests 80-years old 

and older, based on the current age of stands in the BLM Forest Operations Inventory. All other features 

of Sub-alternative C are the same as Alternative C. The description of Sub-alternative C, including the 

acreage of each land use allocation and a map, follows the description of Alternative C.
65 | P a g e

Figure 2-7. Alternative C land use allocations 

Table 2-7. Alternative C land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

949,279 38%

Structurally-complex Forest 428,522 17%

Late-Successional Reserve – Moist 331,224 13%

Late-Successional Reserve – Dry 148,776 6%

Existing Occupied Marbled Murrelet Sites 40,468 2%

Predicted Marbled Murrelet Sites 2,761 <1%

Existing Red Tree Vole Sites* 287 <1%

Riparian 

Reserve 372,739 15% Riparian Reserve – Moist 244,694 10%

Riparian Reserve – Dry 128,045 5%

Other 

Reserves 267,678 11% Congressionally Reserved 40,537 2%

District-Designated Reserves 227,141 9%

Harvest 

Land Base 741,332 30% High Intensity Timber Area 553,857 22%

Uneven-aged Timber Area 184,715 7%

Eastside 

Management 

Area

147,828 6% - 147,828 6%

Totals 2,478,856 -

* Existing Red Tree Vole Sites means those sites of the North Oregon Coast Distinct Population Segment of the red tree vole 

north of Highway 20.

Late-Successional 

Reserve 

38% 

Other Reserves 

arvest Land 

Base 

30% 

Eastside 

anagement 

Area 

6% 

Riparian Reserve 

15% 

11%

H

M
66 | Page

Map 2-5. Alternative C land use allocations
67 | Page

Map 2-5. Alternative C land use allocations (continued) 
68 | P a g e

Late-Successional Reserve 

The Late-Successional Reserve includes, primarily, Structurally-complex Forest, Large Block Forest 

Reserves (Late-Successional Reserve – Moist and Late-Successional Reserve – Dry), and much smaller 

acreages from existing occupied marbled murrelet sites and existing sites of the North Oregon Coast 

Distinct Population Segment of the red tree vole. In addition, Alternative C includes requirements for 

surveys for the marbled murrelet and the North Oregon Coast Distinct Population Segment of the red tree 

vole, as described below, and newly discovered sites would be included in the Late-Successional Reserve. 

Thus, this description of the Late-Successional Reserve includes predictions of the acreage of newly 

discovered marbled murrelet and red tree vole sites. Within the Late-Successional Reserve, the BLM 

would conduct timber salvage after disturbance to recover economic value, to protect public health and 

safety, or to keep roads and other infrastructure clear of debris. 

Structurally-complex Forest 

Alternative C includes within the Late-Successional Reserve all stands 160-years old and older, 

based on the current age of stands in the BLM forest operations inventory. 

Large Block Forest Reserves: Late-Successional Reserve – Moist and Late-Successional 

Reserve – Dry18

Alternative C includes within the Late-Successional Reserve blocks of functional and potential 

northern spotted owl habitat, sufficient to meet block size and spacing requirements (Thomas et 

al. 1990, pp. 24, 28) in all provinces. In moist forests, the BLM would conduct thinning to 

promote the development of structurally-complex forest, which may include commercial removal 

of cut trees. In dry forests, the BLM would conduct activities including thinning and prescribed 

burning to promote the development of structurally-complex forest and to improve resilience to 

disturbance, which may include commercial removal of cut trees. 

Riparian Reserve 

In Alternative C, the Riparian Reserve encompass lands within—

 150 feet on either side of fish-bearing and perennial streams; and 

 50 feet on either side of non-fish-bearing, intermittent streams. 

The Riparian Reserve includes an inner zone in which thinning is not permitted. Inner zone widths are—

 60 feet on either side of fish-bearing and perennial streams; and 

 50 feet on either side of non-fish-bearing, intermittent streams. 

Outside of the inner zone, the BLM would conduct thinning, which may include commercial removal, as 

needed to develop diverse and structurally-complex riparian stands. 

Harvest Land Base 

The Harvest Land Base is comprised of the High Intensity Timber Area and the Uneven-aged Timber 

Area. The allocation of the Uneven-aged Timber Area in Alternative C is based on very dry forest types 

identified by potential vegetation. Timber management in the High Intensity Timber Area includes 

thinning and regeneration harvest with no retention (i.e., clearcuts). The High Intensity Timber Area has 

no snag or down woody debris retention requirements. 

 

18 For the purpose of Late-Successional Reserve and Riparian Reserve management in Alternative C, dry forests are 

defined by very dry forest types identified by potential vegetation types. 
69 | P a g e

Wildlife

Within the Harvest Land Base, Alternative C includes—

 No specific protections for northern spotted owl known or historic sites;

 A requirement for surveys for the marbled murrelet prior to management actions in stands 120-

years and older and protection of habitat within 300 feet around newly discovered occupied sites;

 No specific management requirements for trees capable of providing marbled murrelet nesting 

structures in younger stands; and

 No requirement for surveys for North Oregon Coast Distinct Population Segment of the red tree 

vole prior to management actions.

Rare Plants and Fungi

The BLM would create new populations and augment existing populations of ESA-listed and other 

special status plants and fungi to meet recovery plan or conservation strategy objectives.

Invasive Species

Alternative C includes treatment at all sudden oak death infection sites.

Livestock Grazing

The BLM would manage allotments in compliance with Standards for Rangeland Health and Guidelines 

for Livestock Grazing Management for Public Lands in Oregon and Washington (USDI BLM 1997). The 

BLM would adjust grazing levels and management practices when needed to meet or make progress 

toward meeting the standards for rangeland health. The BLM would make unavailable to grazing those 

allotments that have been generally been vacant or inactive for 5 years or more and currently have no 

Section 3 or Section 15 grazing preference.

Minerals

Under Alternative C, the BLM would recommend for withdrawal from locatable mineral entry 171,584

acres (in addition to the 98,400 acres previously withdrawn) and would close 215,053 acres to salable 

mineral material disposal.

Areas of Critical Environmental Concern

Under Alternative C, the BLM would designate 101 Areas of Critical Environmental Concern.

Recreation Management Areas

Alternative C includes designation of Special Recreation Management Areas at currently developed 

recreation facilities, and on lands where designation does not conflict with sustained-yield timber harvest. 

Alternative C includes designation of Extensive Recreation Management Areas where the BLM has 

developed and currently manages recreation activities outside of developed facilities, primarily where the 

BLM has authorized motorized and non-motorized trails, and where the BLM currently manages 

dispersed recreation activities. In addition, the BLM would designate Special Recreation Management 

Areas and Extensive Recreation Management Areas to address specific recreation demand and scarcity. In 

the rest of the decision area, the BLM would not manage specifically for recreation.

Lands with Wilderness Characteristics

Alternative C includes management for wilderness characteristics of identified lands with wilderness 

characteristics that are not within the Harvest Land Base, and where they are within compatible existing 

and potential Recreation Management Areas.
70 | P a g e

Wild and Scenic Rivers

Under Alternative C, the BLM would recommend for inclusion in the National Wild and Scenic River

System six eligible river segments that the BLM found suitable during the BLM’s suitability study (as 

outlined in BLM Manual 6400, USDI BLM 2012b).

Visual Resource Management

Under Alternative C, the BLM would manage Congressionally Reserved lands where decisions have been 

made to preserve a natural landscape (e.g., designated Wilderness Areas and Wild sections of Wild and 

Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following as VRM 

Class II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; National 

Trail management corridors; District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics; and Special Recreation Management Areas that fall within the Primitive and Backcountry 

setting. The BLM would manage the following as VRM Class III: designated and recommended suitable 

Wild and Scenic Rivers classified as Recreational, and Special and Extensive Recreation Management 

Areas that fall within the Middle Country setting. The BLM would manage ACECs as a VRM class 

commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class III as VRM Class III). 

The BLM would manage all other lands as Visual Resource Management Class IV.

Sub-alternative C

Sub-alternative C is identical to Alternative C, except that the Late-Successional Reserve includes all 

stands 80 years old and older, based on the current age of stands in the BLM forest operations inventory. 

This single change in design increases the Late-Successional Reserve to 55 percent of the decision area 

and reduces the Harvest Land Base to 20 percent of the decision area (Figure 2-8, Table 2-8, and Map 2-

6).
71 | P a g e

Figure 2-8. Sub-alternative C land use allocations 

Table 2-8. Sub-alternative C land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

1,373,206 55%

Structurally-complex Forest 1,036,218 42%

Late-Successional Reserve – Moist 233,967 9%

Late-Successional Reserve – Dry 61,525 2%

Existing Occupied Marbled Murrelet Sites 40,468 2%

Predicted Marbled Murrelet Sites 740 <1%

Existing Red Tree Vole Sites* 287 <1%

Riparian 

Reserve 337,701 14% Riparian Reserve – Moist 253,674 10%

Riparian Reserve – Dry 84,026 3%

Other 

Reserves 172,232 7% Congressionally Reserved 40,537 2%

District-Designated Reserves 131,694 5%

Harvest 

Land Base 495,507 20%

High Intensity Timber Area 402,665 16%

Uneven-aged Timber Area 92,842 4%

Eastside 

Management 

Area

100,210 4% - 100,210 4%

Totals 2,478,856 -

* Existing Red Tree Vole Sites means those sites of the North Oregon Coast Distinct Population Segment of the red tree vole 

north of Highway 20.

Late-Successional 

Reserve

55%

Other Reserves

7%

Harvest

Land

Base

20%

Eastside 

Management 

Area

4%

Riparian Reserve

14%
72 | Page

Map 2-6. Sub-alternative C land use allocations 
73 | Page

Map 2-6. Sub-alternative C land use allocations (continued) 
74 | P a g e

Alternative D

Alternative D has the smallest Late-Successional Reserve of the action alternatives (Figure 2-9, Table 2-

9, and Map 2-7). The Harvest Land Base is comprised of the Uneven-aged Timber Area, Owl Habitat 

Timber Area, and Moderate Intensity Timber Area. The Owl Habitat Timber Area includes timber harvest 

applied in a manner that would maintain northern spotted owl habitat. The Moderate Intensity Timber 

Area includes regeneration harvest with retention. Alternative D has the largest acreage in the Riparian 

Reserve of the action alternatives.
75 | P a g e

Late-Successional 

Reserve

29%

Other

Reserves

10%

Harvest Land 

Base

26%

Eastside 

Management 

Area

6%

Riparian Reserve

29%

Figure 2-9. Alternative D land use allocations 

Table 2-9. Alternative D land use allocations 

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve

714,292 29%

Structurally-complex Forest 482,920 19%

Northern Spotted Owl Sites 96,666 4%

Existing Occupied Marbled Murrelet Sites 33,037 1%

Predicted Marbled Murrelet Sites 91,816 4%

Existing Red Tree Vole Sites* 245 <1%

Predicted Red Tree Vole Sites* 9,608 <1%

Riparian 

Reserve 714,629 29% Riparian Reserve – Moist 459,145 19%

Riparian Reserve – Dry 255,484 10%

Other 

Reserves 250,523 10% Congressionally Reserved 40,537 2%

District-Designated Reserves 209,986 8%

Harvest 

Land Base 650,382 26%

Moderate Intensity Timber Area 160,575 6%

Owl Habitat Timber Area 427,556 17%

Uneven-aged Timber Area 62,251 3%

Eastside 

Management 

Area

149,030 6% - 149,030 6%

Totals 2,478,856 -

* Existing Red Tree Vole Sites and Predicted Red Tree Vole Sites means those sites of the North Oregon Coast Distinct 

Population Segment of the red tree vole north of Highway 20.
76 | Page

Map 2-7. Alternative D land use allocations 
77 | Page

Map 2-7. Alternative D land use allocations (continued) 
78 | P a g e

Late-Successional Reserve

The Late-Successional Reserve includes, primarily, Structurally-complex Forest/Large Block Forest 

Reserves, and much smaller acreages from nest patches of known and historic northern spotted owl sites, 

existing occupied marbled murrelet sites, and existing sites of the North Oregon Coast Distinct Population 

Segment of the red tree vole. In addition, Alternative D includes requirements for surveys for the marbled 

murrelet and the North Oregon Coast Distinct Population Segment of the red tree vole, as described 

below, and newly discovered sites would be included in the Late-Successional Reserve. Thus, this 

description of the Late-Successional Reserve includes predictions of the acreage of newly discovered 

marbled murrelet and red tree vole sites. Within the Late-Successional Reserve, the BLM would conduct 

no timber salvage after disturbance, except when necessary to protect public health and safety, or to keep 

roads and other infrastructure clear of debris.

Structurally-complex Forest/Large Block Forest Reserves

Alternative D includes within the Late-Successional Reserve all stands 120 years old and older on 

high productivity sites, 140 years old and older on moderate productivity sites, and 160 years old 

and older on low productivity sites, based on the current age of stands in the BLM forest 

operations inventory. This Structurally-complex Forest also constitutes the Large Block Forest 

Reserves under Alternative D.

Riparian Reserve19

In Alternative D, the Riparian Reserve encompasses lands within one site-potential tree height on either 

side of all streams. The Riparian Reserve includes a no-thin inner zone of 120 feet on either side of all 

streams. Outside of the inner zone, the BLM would conduct thinning, which may include commercial 

removal, as needed to ensure that stands are able to provide stable wood to the stream.

Harvest Land Base

The Harvest Land Base is comprised of the Owl Habitat Timber Area, Uneven-aged Timber Area, and 

Moderate Intensity Timber Area. Alternative D includes the Owl Habitat Timber Area in all designated 

northern spotted owl critical habitat and within the home ranges of known and historic owl sites within 

the Harvest Land Base, (though the nest patches themselves are included in the Late-Successional 

Reserve). Timber harvest in the Owl Habitat Timber Area includes thinning and uneven-aged timber 

harvest applied in a manner that would maintain northern spotted owl habitat. The portion of the Harvest 

Land Base outside of designated northern spotted owl critical habitat is divided between the Uneven-aged 

Timber Area and the Moderate Intensity Timber Area. The allocation of the Uneven-aged Timber Area in 

Alternative D is based on very dry forest types identified by potential vegetation. The remainder of the 

Harvest Land Base in Alternative D is in the Moderate Intensity Timber Area. Timber harvest in the 

Moderate Intensity Timber Area includes thinning and regeneration harvest with retention of 5–15 

percent of the stand.

Wildlife

Within the Harvest Land Base, Alternative D includes—

 Specific protections to maintain habitat within the home ranges of all northern spotted owl known 

and historic sites;

 A requirement for surveys for the marbled murrelet prior to management actions in marbled 

murrelet Zones 1 and 2 and protection of habitat within 0.5 mile around newly discovered 

occupied sites;

 Protection of trees capable of providing marbled murrelet nesting structures in younger stands in 

marbled murrelet Zones 1 and 2; and 

 

19 For the purpose of Riparian Reserve management in Alternative D, dry forests are defined by very dry forest types 

identified by potential vegetation types.
79 | P a g e

 A requirement for surveys for North Oregon Coast Distinct Population Segment of the red tree 

vole prior to management actions and protection of habitat areas around newly discovered nest 

sites.

Rare Plants and Fungi

Under Alternative D, the BLM would protect known Bureau Sensitive species sites from adverse impacts 

where protection does not conflict with sustained-yield forest management in the Harvest Land Base.

Invasive Species

Alternative D includes treatment at all sudden oak death infection sites.

Livestock Grazing

Under Alternative D, the BLM would eliminate livestock grazing by terminating existing livestock 

grazing authorizations and making the allotments unavailable for livestock grazing.

Minerals

Under Alternative D, the BLM would recommend for withdrawal from locatable mineral entry 208,478

acres (in addition to the 98,400 acres previously withdrawn) and would close 207,655 acres to salable 

mineral material disposal.

Areas of Critical Environmental Concern

Under Alternative D, the BLM would designate 107 Areas of Critical Environmental Concern.

Recreation Management Areas

Alternative D includes designation of Special Recreation Management Areas at currently developed 

recreation facilities, and on lands where designation does not conflict with sustained-yield timber harvest. 

Alternative D would include designation of Extensive Recreation Management Areas on all lands within 

the decision area where existing recreation use is occurring and the BLM has legal public access. In 

addition, the BLM would designate Special and Extensive Recreation Management Areas where known 

historic recreation use has occurred, and where the BLM is seeking to address activity-specific demands. 

The BLM would designate these to the maximum extent possible without precluding sustained-yield 

timber harvest.

Lands with Wilderness Characteristics

Alternative D would not include management for wilderness characteristics of any identified lands with 

wilderness characteristics.

Wild and Scenic Rivers

Under Alternative D, the BLM would recommend all 51 eligible river segments for inclusion in the 

National Wild and Scenic River System.

Visual Resource Management

Under Alternative D, the BLM would manage Congressionally Reserved lands where decisions have been 

made to preserve a natural landscape (e.g., designated Wilderness Areas and the Wild sections of Wild 

and Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following as 

VRM Class II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; 

National Trail management corridors, and Special Recreation Management Areas that fall within the 

Primitive and Backcountry setting. The BLM would manage the following as VRM Class III: designated 

and recommended suitable Wild and Scenic Rivers classified as Recreational, and Special and Extensive 

Recreation Management Areas that fall within the Middle Country setting. The BLM would manage 

ACECs as a VRM class commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class 
80 | P a g e

III as VRM Class III). The BLM would manage all other lands as a VRM class commensurate to their 

assigned Visual Inventory Class (e.g., VRI Class III as VRM Class III), except that in the Harvest Land 

Base, lands inventoried as Visual Resource Inventory Class II would be managed as Visual Resource 

Management Class III.
81 | P a g e

Proposed RMP 

The BLM has developed the Proposed RMP as a variation on Alternative B, which the BLM identified in 

the Draft RMP/EIS as the preferred alternative. The Proposed RMP has a Late-Successional Reserve that 

is a refinement of the Late-Successional Reserve design in Alternative B (see Figure 2-10, Table 2-10, 

and Map 2-8). The Harvest Land Base is comprised of the Uneven-aged Timber Area, Low Intensity 

Timber Area, and Moderate Intensity Timber Area, as in Alternative B. The geographic extent of the 

portion of the Harvest Land Base in Uneven-aged Timber Area in the Proposed RMP is intermediate 

between Alternative B and Alternative C. As in Alternative B, the Low Intensity Timber Area and 

Moderate Intensity Timber Area include regeneration harvest with varying levels of retention. 

Figure 2-10. Proposed RMP land use allocations 

Reserve 

38% 

Other Reserves 

Harvest Land 

Base 

nt 

Riparian Reserve 

26% 

Late-Successional 

19% 11%

Eastside

Manageme

Area

6%
82 | P a g e

Table 2-10. Proposed RMP land use allocations and suballocations

Land Use 

Allocation Acres

Total 

Acres 

(Percent)

Sub-allocation Acres

Total 

Acres 

(Percent)

LateSuccessional 

Reserve*

948,466 38%

Structurally-complex Forest 427,881 17%

Large Block Forest Reserve – Moist 250,546 10%

Large Block Forest Reserve – Dry 186,949 8%

Existing Occupied Marbled Murrelet Sites 42,174 2%

Predicted Marbled Murrelet Sites†31,242 1%

Existing Red Tree Vole Sites#128 <1%

Predicted Red Tree Vole Sites#9,546 <1%

Riparian 

Reserve‡ 635,717 26%

Riparian Reserve (Class I Subwatersheds) 497,331 20%

Riparian Reserve (Class II 

Subwatersheds) 107,453 4%

Riparian Reserve (Class III 

Subwatersheds) 30,933 1%

Other 

Reserves 263,647 11% Congressionally Reserved Lands 40,505 2%

District-Designated Reserves§223,142 9%

Harvest 

Land Base** 469,215 19%

Moderate Intensity Timber Area 180,549 7%

Low Intensity Timber Area 89,126 4%

Uneven-aged Timber Area 199,541 8%

Eastside 

Management 

Areaǀǀ

161,810 7%

Eastside Management Area 149,971 6%

Eastside Management Area – Riparian 

Reserve 11,838 <1%

Totals 2,478,856 -

* The acreage of the different components of the Late-Successional Reserve in this table is presented for comparison to the 

information for the action alternatives. The different components describe areas that are included in the Late-Successional 

Reserve for different reasons, including analytical projections of areas that the BLM would identify in the future as part of the 

Late-Successional Reserve. These different components are not sub-allocations, in that they do not have differing management 

objectives or management direction. The only sub-allocations of the Late-Successional Reserve, as detailed in Appendix B, are 

Late-Successional Reserve – Dry and Late-Successional Reserve – Moist.

† For the Proposed RMP, the BLM used updated detection rates to calculate acres of predicted marbled murrelet sites, which 

increased the acreage of predicted marbled murrelet sites compared to the alternatives (see the Forest Management and Wildlife 

sections of Chapter 3).

‡ The design of the Riparian Reserve (west of Highway 97) varies among three classes of subwatersheds. In addition, the 

Riparian Reserve (west of Highway 97) includes sub-allocations of Riparian Reserve – Moist and Riparian Reserve – Dry, which 

overlap the three classes of subwatershed. This table only presents the Riparian Reserve (west of Highway 97) by subwatershed 

class for simplicity of presentation.

§ District-Designated Reserves include several sub-allocations, as detailed in Appendix B, which are grouped together in this 

table.

ǀǀ The acreage for the Eastside Management Area in this table includes both forested and non-forested lands and Eastside 

Management Area – Riparian Reserve.

# Existing Red Tree Vole Sites and Predicted Red Tree Vole Sites means those sites of the North Oregon Coast Distinct 

Population Segment of the red tree vole north of Highway 20.

** Acres mapped to the Harvest Land Base would be greater than shown here due to acres of Harvest Land Base that the BLM 

would shift to Late-Successional Reserve in the future based on surveys and discovery of sites for marbled murrelets and red tree 

voles during implementation of the Proposed RMP (shown as “predicted marbled murrelet sites” and “predicted red tree vole 

sites” in the Late-Successional Reserve).
83 | P a g e

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84 | Page

Map 2-8. Proposed RMP land use allocations 
85 | Page

Map 2-8. Proposed RMP land use allocations (continued) 
86 | P a g e

The BLM identified Alternative B as the preferred alternative in the Draft RMP/EIS because of the 

outcomes associated with most resources. However, Alternative B does not provide the best possible 

response to the purpose and need for action and the guidance for the formulation of alternatives

concerning the management of every resource. Recognizing this, the Draft RMP/EIS explained that the 

BLM would seek to develop a Proposed RMP that would, in comparison to Alternative B—

 Reduce the risk of adverse effects to ESA-listed fish and water quality;

 Increase protection of unique recreation settings and increase recreation use;

 Increase protection of identified lands with wilderness characteristics; and

 Minimize the spread of sudden oak death.

Based on the analysis in the Draft RMP/EIS and comments the BLM received on the Draft RMP/EIS, the 

BLM has modified the management approach of Alternative B for riparian management, recreation 

management, protection of identified lands with wilderness characteristics, and treatment of sudden oak 

death in the development of the Proposed RMP, as summarized below.

To reduce the risk of adverse effects to ESA-listed fish and water quality compared to Alternative B, the 

Proposed RMP includes a Riparian Reserve design that is intermediate among the alternatives and 

incorporates elements of each of the alternatives. The Proposed RMP carries forward the concept of key 

watersheds from the No Action alternative, in that it varies riparian management based on the importance 

of the subwatershed to the conservation and recovery of ESA-listed fish. For fish-bearing streams and 

perennial streams in all subwatersheds, the Riparian Reserve design is similar to Alternative D. For nonfish-bearing intermittent streams, the Riparian Reserve design in Class I and II subwatersheds is a slight 

modification of Alternative A, and the Riparian Reserve design in Class III subwatersheds is similar to

Alternative C (see more detailed description below under Riparian Reserve).

To increase protection of unique recreation settings and increase recreation use compared to Alternative 

B, the Proposed RMP includes an approach to the management of recreation resources modified from 

Alternative C.

To increase protection of identified lands with wilderness characteristics compared to Alternative B, the 

Proposed RMP includes an approach to the management of identified lands with wilderness 

characteristics from Alternative A.

To minimize the spread of sudden oak death compared to Alternative B, the Proposed RMP includes the

sudden oak death treatment approach of the No Action alternative, Alternative C, and Alternative D.

In designing the Proposed RMP to best meet all of the purposes for the RMP revision, the BLM 

considered the effects disclosed in the Draft RMP/EIS as well as the comments received from the public 

and cooperating agencies. The BLM made many of the modifications to Alternative B to mitigate further 

the adverse effects to resources through the land use allocations and the management direction. 

Specifically, the BLM modified the Riparian Reserve design and management direction of Alternative B 

for the Proposed RMP to reduce the risk of adverse effects to ESA-listed fish and water quality. The BLM 

increased the protection of identified lands with wilderness characteristics under the Proposed RMP 

compared to Alternative B to reduce the loss of wilderness characteristics. The BLM adopted the most 

aggressive sudden oak death treatment approach among the alternatives for the Proposed RMP to 

minimize the spread of sudden oak death. Additionally, the Proposed RMP included specific management 

direction intended to reduce or avoid adverse effects. For example, as described below, and in Appendix 

B and Appendix X, the Proposed RMP would prohibit the incidental take of northern spotted owls from 

timber harvest until implementation of a barred owl management program has begun, and would 

participate in, cooperate with, and provide support for an interagency program for barred owl 
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management when the U.S. Fish and Wildlife Service determines the best manner in which barred owl 

management can contribute to the recovery of the northern spotted owl.

The Proposed RMP would prohibit the incidental take20 of northern spotted owls from timber harvest 

until implementation of a barred owl management program has begun (Appendix B and Appendix X). 

This design feature of the Proposed RMP is a refined and focused version of the management approaches 

for northern spotted owl sites in Alternative D and Sub-alternative B. Alternative D allocated the home 

ranges of all known and historic northern spotted owl sites in the Harvest Land Base to the Owl Habitat 

Timber Area (see above; also USDI BLM 2015, pp. 74, 938–939). Sub-alternative B allocated the home 

ranges of all known and historic northern spotted owl sites to the Late-Successional Reserve (see above; 

also USDI BLM 2015, pp. 53, 938–939). In both the Owl Habitat Timber Area in Alternative D and the 

Late-Successional Reserve in Sub-alternative B, management direction would prohibit timber harvest that 

would not maintain northern spotted owl nesting-roosting habitat. This management direction in 

Alternative D and Sub-alternative B would effectively prohibit incidental take of northern spotted owls 

from timber harvest by prohibiting timber harvest that would remove nesting-roosting habitat in occupied 

northern spotted owl sites. Beyond this, and in contrast to the management direction in the Proposed 

RMP, this management direction in Alternative D and Sub-alternative B would also prohibit timber 

harvest that would not cause incidental take of northern spotted owls (such as removal of nesting-roosting 

habitat in unoccupied northern spotted owl sites). Finally, this management direction in Alternative D and 

Sub-alternative B would be permanent, in contrast to the management direction in the Proposed RMP, 

which would prohibit the incidental take of northern spotted owls from timber harvest until 

implementation of a barred owl management program has begun. Thus, the management approach for 

northern spotted owl sites in the Proposed RMP is a temporary and more limited refinement of the 

approaches in Alternative D and Sub-alternative B, which were described and analyzed in the Draft 

RMP/EIS.

The design of the Proposed RMP included all reasonable measures to avoid and minimize adverse effects 

to natural resources while meeting the statutory requirements under the O&C Act for a sustained yield of 

timber and the other purposes of the action. The Proposed RMP would not eliminate all adverse effects. 

Some level of residual adverse effects would be necessary to accomplish all of the purposes for the action. 

For example, the application of management direction and best management practices for road 

construction would reduce, but not eliminate, the potential for sediment delivery to streams. Some amount 

of road construction and consequent potential sediment delivery would be necessary to accomplish the 

purpose of providing for a sustained yield of timber and management objectives such as providing access 

to BLM-administered lands and facilities to support resource management programs. The management 

direction in the Proposed RMP intended to reduce or avoid adverse effects are too numerous to catalog 

here, but the effectiveness of such management direction in mitigating adverse effects and residual 

adverse effects are addressed by the issues and analysis contained in Chapter 3.

This section contains bulleted lists of the management objectives for the land use allocations and resource 

programs for the Proposed RMP. For some allocations and programs, this section also contains brief 

descriptions of the allocation and abbreviated descriptions of the management direction. Appendix B

contains the management objectives and management direction in their entirety for all land use 

allocations, sub-allocations, and resource programs of the Proposed RMP.

 

20 The ESA defines ‘take’ as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt 

to engage in any such conduct.” 16 U.S.C. 1532(19). The definition of harm is “an act which actually kills or injures 

wildlife. Such an act may include significant habitat modification or degradation where it actually kills or injures 

wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering.” 50 CFR

17.3; Babbitt v. Sweet Home Chapter of Cmtys. for a Greater Or., 515 U.S. 687, 696-700 (1995).
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Congressionally Reserved Lands and National Landscape 

Conservation System

 Conserve, protect, and restore the identified outstanding cultural, ecological, and scientific values of 

the National Landscape Conservation System and other congressionally designated lands.

 Preserve the wilderness character of designated Wilderness Areas.

 Preserve wilderness characteristics in Wilderness Study Areas in accordance with non-impairment 

standards as defined under the management policy for Wilderness Study Areas (BLM Manual 6330 –

Management of BLM Wilderness Study Areas; USDI BLM 2012), until Congress either designates 

these lands as Wilderness or releases them for other purposes.

 Protect and enhance the free-flowing condition, water quality, and outstandingly remarkable values of 

eligible, suitable, and designated Wild and Scenic River corridors.

21

 Provide protection to Wild and Scenic River corridors that are suitable for inclusion as components of 

the National Wild and Scenic Rivers system until Congress makes a decision on designation.

 Provide protection to Wild and Scenic River corridors that are eligible but have not yet been studied 

for suitability as components of the National Wild and Scenic Rivers system pending suitability 

evaluations.

Under the Proposed RMP, the BLM would recommend for inclusion in the National Wild and Scenic 

River System the six eligible Wild and Scenic River segments that the BLM found suitable during its 

administrative process (as outlined in BLM Manual 6400 – Wild and Scenic Rivers – Policy and Program 

Direction for Identification, Evaluation, Planning and Management, USDI BLM 2012b).

District-Designated Reserves

 Maintain the values and resources for which the BLM has reserved these areas from sustained-yield 

timber production.

The Proposed RMP includes management for wilderness characteristics of all identified lands with 

wilderness characteristics that are outside of the Harvest Land Base.

Eastside Management Area – Forested Lands

 Manage forested lands on a sustainable basis for multiple uses including wildlife habitat, recreational 

needs, riparian habitat, cultural resources, community stability, and commodity production, including 

commercial timber and other forest products.

 Promote development of fire-resilient forests.

 Offer for sale the probable sale quantity of 350 Mbf of timber per year.

Eastside Management Area – Non-forested Lands

 Manage non-forested lands with the intent of maintaining or improving wildlife habitat and rangeland 

conditions based on ecological site parameters. Where conditions are currently late-seral or potential 

natural community, maintain these conditions. Where conditions are early or mid-seral, improve 

conditions towards late-seral or potential natural community.

 Manage non-forested lands for multiple uses in addition to those listed above including: recreational 

needs, community stability, and commodity production. Commodities include firewood, logs, 

biomass, chips, and other products and byproducts from juniper woodlands and rangelands.

 

21 Wild and Scenic River corridors include all of the river classifications – Wild, Scenic, and Recreational.
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 Promote development of fire-resilient woodlands and rangelands.

 Provide for the conservation of Bureau Special Status Species.

Eastside Management Area – Riparian Reserve

 Provide for conservation of Bureau Special Status fish and other Bureau Special Status riparianassociated species.

 Provide for the riparian and aquatic conditions that supply stream channels with shade, sediment

filtering, leaf litter and large wood sources, and stream bank stability.

 Maintain and restore water quality and hydrologic functions.

 Maintain and restore access to stream channels for all life stages of aquatic species.

 Maintain and restore the proper functioning condition and ecological site potential of riparian and 

wetland areas.

Harvest Land Base

 Manage forests to achieve continual timber production that can be sustained through a balance of 

growth and harvest.

 Offer for sale the declared Allowable Sale Quantity of timber.

 Recover economic value from timber following disturbances, such as fires, windstorms, disease, or 

insect infestations.

 In harvested or disturbed areas, ensure the establishment and survival of desirable trees appropriate to 

the site and enhance their growth.

 Enhance the economic value of timber in forest stands.

In the Proposed RMP, the Harvest Land Base is comprised of the Uneven-aged Timber Area, Low 

Intensity Timber Area, and Moderate Intensity Timber Area.

The Uneven-aged Timber Area is located in—

 Dry and very dry forest types identified by potential vegetation types in the Klamath Falls Field 

Office;

 Dry forest types within northern spotted owl critical habitat designated in the 2012 final rule (77 

FR 71908) and very dry forest types in the Medford District; and

 Very dry forest types in the South River Field Office of the Roseburg District.

The Low Intensity Timber Area is located in areas within the Harvest Land Base outside of the Unevenaged Timber Area, in which the BLM identified that higher level of retention within regeneration harvest 

units would better integrate the management of multiple resources. Timber harvest in the Low Intensity 

Timber Area includes thinning and regeneration harvest with retention of 15–30 percent of the stand. In 

delineating these areas, the BLM included—

 Northern spotted owl critical habitat designated in the 2012 final rule (77 FR 71908) in the 

Harvest Land Base outside of the Uneven-aged Timber Area;

 Dry forest types outside of designated northern spotted owl critical habitat in the Harvest Land 

Base in the Medford District; and

 Special Recreation Management Areas that overlap the Harvest Land Base outside of the 

Uneven-aged Timber Area where increased tree retention in regeneration harvests would 

facilitate recreation management.
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The Moderate Intensity Timber Area is located in the remaining portions of the Harvest Land Base.

Timber harvest in the Moderate Intensity Timber Area includes thinning and regeneration harvest with 

retention of 5–15 percent of the stand.

In contrast to Alternative B, the Proposed RMP includes either natural tree regeneration or replanting 

after timber harvest in both the Low Intensity Timber Area and Moderate Intensity Timber Area.

Late-Successional Reserve

 Maintain nesting-roosting habitat for the northern spotted owl and nesting habitat for the marbled 

murrelet.

 Promote the development of nesting-roosting habitat for the northern spotted owl in stands that do not

currently support northern spotted owl nesting and roosting.

 Promote the development of nesting habitat for the marbled murrelet in stands that do not currently 

meet nesting habitat criteria.

 Promote the development and maintenance of foraging habitat for the northern spotted owl, including 

creating and maintaining habitat to increase diversity and abundance of prey for the northern spotted 

owl.

In the Proposed RMP, the Late-Successional Reserve includes, primarily, Structurally-complex Forest, 

Large Block Forest Reserves (Late-Successional Reserve – Moist and Late-Successional Reserve – Dry), 

and much smaller acreages from existing occupied marbled murrelet sites and existing sites of the North 

Oregon Coast Distinct Population Segment of the red tree vole north of Highway 20. In addition, the 

Proposed RMP includes requirements for surveys for the marbled murrelet and the North Oregon Coast 

Distinct Population Segment of the red tree vole, as described below; newly discovered sites would be 

included in the Late-Successional Reserve. Thus, this description of the Late-Successional Reserve 

includes predictions of the acreage of newly discovered marbled murrelet and red tree vole sites. Within 

the Late-Successional Reserve, the BLM would not conduct timber salvage after disturbance, except 

when necessary to protect public safety, or to keep roads and other infrastructure clear of debris.

Structurally-complex Forest

The Proposed RMP includes within the Late-Successional Reserve all stands identified by 

existing, district-specific information on Structurally-complex Forests.22

Large Block Forest Reserves: Late-Successional Reserve – Moist and Late-Successional

Reserve – Dry23

The Proposed RMP includes within the Late-Successional Reserve blocks of functional and 

potential northern spotted owl habitat, sufficient to meet block size and spacing requirements 

(Thomas et al. 1990, pp. 24, 28) in all provinces except the Coast Range province, where reserves 

include blocks of habitat without limitations for size and spacing. In comparison to Alternative B, 

the Proposed RMP includes additional areas of Late-Successional Reserve in the Eugene and 

Roseburg Districts to facilitate east/west northern spotted owl movement and survival between 

the Coast Range and Cascade Mountains. In moist forests, the BLM would conduct thinning to 

promote the development of structurally-complex forest, which may include commercial removal 

 

22 The BLM has updated this information since the preparation of Alternative B in the Draft RMP/EIS, which used 

the district-specific information on structurally-complex forests available at that time.

23 The Late-Successional Reserve – Dry and Riparian Reserve – Dry sub-allocations in the Proposed RMP are 

delineated as those portions of the Late-Successional Reserve and Riparian Reserve, respectively, which are in dry 

and very dry forest types identified by potential vegetation types within the Klamath Falls Field Office, the Medford 

District, and the South River Field Office of the Roseburg District.
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of cut trees. In dry forests, the BLM would conduct activities including thinning and prescribed 

burning to promote the development of structurally-complex forest and to improve resilience to 

disturbance, which may include commercial removal of cut trees. 

Riparian Reserve (west of Highway 97) 

 Contribute to the conservation and recovery of ESA-listed fish species and their habitats and provide 

for conservation of Bureau Special Status fish and other Bureau Special Status riparian-associated 

species. 

 Maintain and restore natural channel dynamics and processes, and the proper functioning condition of 

riparian areas, stream channels, and wetlands by providing forest shade, sediment filtering, wood 

recruitment, stability of stream banks and channels, water storage and release, vegetation diversity, 

nutrient cycling, and cool and moist microclimates. 

 Maintain water quality and streamflows within the range of natural variability, to protect aquatic 

biodiversity, provide quality water for contact recreation and drinking water sources. 

 Meet ODEQ water quality criteria. 

 Maintain high quality water and contribute to the restoration of degraded water quality for 303(d)-

listed streams.

 Maintain high quality waters within ODEQ designated Source Water Protection watersheds.

In the Proposed RMP, the Riparian Reserve encompasses lands along streams and other waterbodies. The 

design of the Riparian Reserve (west of Highway 97) varies among three classes of subwatersheds,24

based on the importance of the subwatershed to the conservation and recovery of ESA-listed fish (see 

Figure 2-11). The BLM evaluated the importance of subwatersheds to the conservation and recovery of 

ESA-listed fish primarily based on designated critical habitat25 and the presence of streams with a highintrinsic potential for salmon. Class I subwatersheds are those that include both designated critical habitat 

and high-intrinsic potential streams.26 Class II subwatersheds are those that include designated critical 

habitat or high-intrinsic potential streams. Class III subwatersheds are those that include neither 

designated critical habitat nor high-intrinsic potential streams. In identifying subwatershed classes, the 

BLM considered primarily the information in critical habitat designations and data on high intrinsic 

potential streams to indicate the importance of subwatersheds to the conservation and recovery of ESAlisted fish. However, future changes in designated critical habitat or data on high intrinsic potential 

streams would not alter the identification of subwatershed classes for the purpose of Riparian Reserve 

design and management direction (Appendix X). 

 

24 The BLM defined the three classes for Riparian Reserve design in the Proposed RMP based on ‘6th field 

watersheds’ (Hydrologic Unit Code 12). Hydrologic Unit Codes (HUC) are a U.S Geological Survey classification 

based on a hierarchy of nested watersheds. HUC 12 subwatersheds are typically 10,000–40,000 acres in size. 

25 For subwatersheds on the east side of the Willamette River, the BLM included core-genetic and core-legacy 

populations in addition to designated critical habitat. 

26 The ‘intrinsic potential’ is the set of habitat features that most influence whether that habitat is likely to be used or 

selected (or not) by an individual fish species. ‘High intrinsic potential’ streams are those streams with the habitat 

features that are known to be highly productive for an individual fish species (BLM 2015b, pp. 2–3). 
92 | Page

Figure 2-11. Proposed RMP subwatershed classes 
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Class I Subwatersheds

The Riparian Reserve encompasses lands within one site-potential tree height on either side of all 

streams. 

The Riparian Reserve includes an inner zone in which thinning is generally not permitted. Inner 

zone widths are—

 120 feet on either side of perennial streams and fish-bearing intermittent streams, and 

 50 feet on either side of non-fish-bearing, intermittent streams.

The Riparian Reserve includes a middle zone from 50 to 120 feet on either side of non-fishbearing, intermittent streams. No middle zone is delineated on perennial streams and fish-bearing 

intermittent streams. In the middle zone, the BLM would conduct thinning as needed to ensure 

that stands are able to provide trees to form stable instream structures. In the middle zone in moist 

forests, the BLM would conduct thinning without commercial removal of timber (i.e., down

woody debris and snag creation only). In the middle zone in the Riparian Reserve – Dry, 

activities would include prescribed burning and thinning that would include removal of cut trees, 

including commercial removal, as needed to reduce the risk of stand-replacing, crown fires.

The outer zone of the Riparian Reserve would be from 120 feet to one site-potential tree height 

on either side of all streams. In the outer zone, the BLM would conduct thinning, which may 

include commercial removal, as needed to ensure that stands are able to provide stable wood to 

the stream.

Class II Subwatersheds

The Riparian Reserve encompasses lands within one site-potential tree height on either side of all 

streams.

The Riparian Reserve includes an inner zone in which thinning is generally not permitted. Inner 

zone widths are—

 120 feet on either side of perennial streams and fish-bearing intermittent streams, and

 50 feet on either side of non-fish-bearing, intermittent streams.

In the outer zone, the BLM would conduct thinning, which may include commercial removal, as 

needed to develop diverse and structurally-complex riparian stands.

Class III Subwatersheds

The Riparian Reserve encompasses lands within—

 One site-potential tree height on either side of perennial streams and fish-bearing 

intermittent streams, and

 50 feet on either side of non-fish-bearing, intermittent streams.

The Riparian Reserve includes an inner zone in which thinning is generally not permitted. Inner 

zone widths are—

 120 feet on either side of perennial and fish-bearing intermittent streams, and

 50 feet on either side of non-fish-bearing, intermittent streams.

In the outer zone, the BLM would conduct thinning, which may include commercial removal, as 

needed to develop diverse and structurally-complex riparian stands.
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Administrative Actions

 Provide for the orderly and efficient management of resources.

Air Quality

 Protect air quality-related values in Federal mandatory Class I areas.

 Prevent exceedances of national, State, or local ambient air quality standards.

Areas of Critical Environmental Concern

 Maintain or restore relevant and important values in Areas of Critical Environmental Concern, 

including Research Natural Areas and Outstanding Natural Areas.

Under the Proposed RMP, the BLM would designate 108 Areas of Critical Environmental Concern.

Cultural Resources

 Preserve and protect significant cultural resources and ensure that they are available for appropriate 

uses by present and future generations.

 Reduce imminent threats and resolve potential conflicts from natural or human-caused deterioration 

or potential conflict with other resources by ensuring that all authorizations for land and resource use 

will comply with Section 106 of the National Historic Preservation Act.

Fire, Fuels, and Wildfire Response

 Respond to wildfires in a manner that provides for public and firefighter safety while meeting land 

management objectives by utilizing the full range of fire management options.

 Fire management strategies would be risk-based decisions that consider firefighter and public safety, 

values at risk, management objectives, and costs that are commensurate with the identified risk.

 Actively manage the land to restore and maintain resilience of ecosystems to wildfire and decrease 

the risk of uncharacteristic, large, high-intensity/high-severity wildfires.

 Manage fuels to reduce wildfire hazard, risk, and negative impacts to communities and infrastructure, 

landscapes, ecosystems, and highly valued resources.

 Manage fire, fuels, and wildfire response consistent with the National Cohesive Wildland Fire 

Management Strategy.

 Participate with communities bordering Federal lands in partnership with local, State, and Federal 

stakeholders to reduce the risks and threats from wildland fire.

Fisheries

 Improve the distribution and quantity of high-quality fish habitat across the landscape for all life 

stages of ESA-listed, Bureau Special Status Species, and other fish species.

 Maintain and restore access to stream channels for all life stages of aquatic species.

Forest Management

 Enhance the health, stability, growth, and vigor of forest stands.

 In harvested or disturbed areas, ensure the establishment and survival of desirable vegetation 

appropriate to the site.
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 Facilitate safe and efficient forestry operations for the BLM, reciprocal right-of-way agreement 

holders, and permittees.

Hydrology

 Maintain water quality within the range of natural variability that meets ODEQ water quality 

standards for drinking water, contact recreation, and aquatic biodiversity.

Invasive Species

 Prevent the introduction of invasive species and the spread of existing invasive species infestations.

 Prevent the introduction and the spread of sudden oak death (Phytophthora ramorum) infections.

The Proposed RMP includes treatment at all sudden oak death infection sites.

Lands, Realty, and Roads

 Make land tenure adjustments to facilitate the management of resources and enhance public resource 

values.

 Provide legal access to BLM-administered lands and facilities to support resource management 

programs.

 Provide needed rights-of-way, permits, leases, and easements over BLM-administered lands in a 

manner that is consistent with Federal and State laws.

 Protect lands that have important resource values or substantial levels of investment by withdrawing 

them, where necessary, from the implementation of nondiscretionary public land and mineral laws.

 Provide a road transportation system that serves resource management needs 

(administrative/commercial) and casual use needs (recreational/domestic) for both BLM-administered 

lands and adjacent privately owned lands.

Livestock Grazing

 Provide for livestock grazing consistent with other resource objectives while maintaining or 

improving the health of the public rangelands.

 Prevent livestock from causing trampling disturbance to fish spawning beds where ESA-listed and 

Bureau Sensitive species occur.

Under the Proposed RMP, the BLM would manage allotments in compliance with Standards for 

Rangeland Health and Guidelines for Livestock Grazing Management for Public Lands in Oregon and 

Washington (USDI BLM 1997). The BLM would adjust grazing levels and management practices when 

needed to meet or make progress toward meeting the standards for rangeland health. The BLM would 

make unavailable to grazing those allotments, as listed in Appendix B, that have been generally been 

vacant or inactive for 5 years or more and currently have no Section 3 or Section 15 grazing preference.

Minerals

 Manage the development of leasable (including conventional and non-conventional hydrocarbon 

resources) minerals, locatable mineral entry, and salable mineral material disposal in an orderly and 

efficient manner.
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 Maintain availability of mineral material sites needed for development and maintenance of access 

roads for forest management, timber harvest, local communities, rights-of-way for energy production 

and transmission, and other uses.

Under the Proposed RMP, the BLM would recommend for withdrawal from locatable mineral entry 

208,912 acres (in addition to the 98,400 acres previously withdrawn) and would close 217,711 acres to 

salable mineral material disposal.

Paleontological Resources

 Protect and preserve significant localities from natural or human-caused deterioration or potential

conflict with other resources.

 Provide appropriate scientific, educational, and recreational use, such as research and interpretive 

opportunities for paleontological resources.

Rare Plants and Fungi

 Provide for conservation and contribute toward the recovery of plant species that are ESA-listed or 

candidates.

 Support the persistence and resilience of natural communities, including those associated with forests, 

oak woodlands, shrublands, grasslands, cliffs, rock outcrops, talus slopes, meadows, and wetlands. 

Support ecological processes and disturbance mechanisms to allow for a range of seral conditions.

 Provide for the conservation of Bureau Special Status plant and fungi species.

 Support the persistence and resilience of oak species within oak woodlands and within mixed 

hardwood/conifer communities.

Under the Proposed RMP, the BLM would manage mixed hardwood/conifer communities to maintain 

and enhance oak persistence and structure and manage mixed conifer communities to maintain and 

enhance pine persistence and structure.

Recreation and Visitor Services

 Provide a diversity of quality recreational opportunities.

 Meet legal requirements for visitor health and safety and mitigate resource user conflicts.

 Mitigate recreational impacts on natural and cultural resources. In land use allocations where 

management of other resources is dominant, provide recreational opportunities where they can be 

managed consistent with the management of these other resources.

 Develop new recreation opportunities to address recreation activity demand created by growing 

communities, activity groups, or recreation-tourism if—

o Recreation development is consistent with interdisciplinary land use plan objectives; and

o The BLM has secured commitments from partners (e.g., a cooperative management agreement, 

adopt-a-trail agreement, and memorandum of understanding).

The Proposed RMP includes designation of Special Recreation Management Areas at currently developed 

recreation facilities, and on lands where designation does not conflict with sustained-yield timber harvest. 

The Proposed RMP includes designation of Extensive Recreation Management Areas where the BLM has 

developed and currently manages recreation activities outside of developed facilities, primarily where the 

BLM has authorized motorized and non-motorized trails, and where the BLM currently manages 

dispersed recreation activities. In addition, the BLM would designate Special Recreation Management 

Areas and Extensive Recreation Management Areas to address specific recreation demands and scarcity, 
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or address where unique opportunities for activity-specific demands exist. In the rest of the decision area, 

the BLM would not manage specifically for recreation, but recreation could occur to the extent that the 

BLM has legal public access and recreation is not in conflict with the primary uses of these lands. The 

Proposed RMP would designate 241 RMAs (see Appendix O). The BLM would manage RMAs to 

achieve the management objectives and management direction described for Recreation and Visitor 

Services in Appendix B, and in accordance with their RMA Frameworks.27

Soil Resources

 Maintain or enhance the inherent soil functions (e.g., ability of soil to take in water, store water,

regulate outputs for vegetative growth and stream flow, and resist erosion or compaction) of managed 

ecosystems.

 Provide landscapes that stay within natural soil stability failure rates during and after management 

activities.

Sustainable Energy

 Develop sustainable energy resources to the maximum extent possible without precluding other land 

uses.

Trails and Travel Management

 Maintain a comprehensive travel network that best meets the full range of public use, resource 

management, and administrative access needs.

 Protect fragile and unique resource values from damage by public motorized vehicle use.

 Provide public motorized vehicle use opportunities where appropriate.

Tribal Interests

Under the Proposed RMP, the BLM would consult with affected Tribes early in project planning in order 

consider effects to, and appropriately avoid or mitigate impacts to all cultural resources of concern, 

including both archaeological and natural resources. The BLM would identify opportunities to partner 

with Tribes on restoration projects and other land management activities that include resources and areas 

of interest to the Tribes. The BLM would accommodate access to and ceremonial use of sacred sites and 

places of traditional cultural importance to Tribes as well as avoid adversely affecting their physical 

integrity to the extent practicable, permitted by law, and not clearly inconsistent with other agency 

functions.

Visual Resource Management

 Protect scenic values on public lands where visual resources are an issue or where high-value visual 

resources exist.

 Prohibit activities that would disrupt the existing character of the landscape in Visual Resource 

Management Class I areas.

 Retain the existing character of the landscape in Visual Resource Management Class II areas.

 Partially retain the existing character of the landscape in Visual Resource Management Class III 

areas.

 

27 Recreation Management Frameworks for the Proposed RMP are located at 

http://www.blm.gov/or/plans/rmpswesternoregon/feis.php.
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 Allow for major modification of the existing character of the landscape in Visual Resource 

Management Class IV areas.

Under the Proposed RMP, the BLM would manage Congressionally Reserved lands where decisions have 

been made to preserve a natural landscape (e.g., designated Wilderness Areas and the Wild segments of 

Wild and Scenic Rivers) as Visual Resource Management Class I. The BLM would manage the following 

as VRM Class II: designated and recommended suitable Wild and Scenic Rivers classified as Scenic; 

National Trail management corridors; District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics; and Special Recreation Management Areas that fall within the Primitive and Backcountry 

setting. The BLM would manage the following as VRM Class III: designated and recommended suitable 

Wild and Scenic Rivers classified as Recreational, and Special and Extensive Recreation Management 

Areas that fall within the Middle Country setting. The BLM would manage ACECs as a VRM Class 

commensurate to the assigned Visual Resource Inventory class (e.g., VRI Class III as VRM Class III), 

except that the BLM would manage ACECs within the Harvest Land Base that are VRI Class II as VRM 

Class III. The BLM would manage all other lands as Visual Resource Management Class IV.

Wildlife

 Conserve and recover species that are ESA-listed, proposed, or candidate, and the ecosystems on 

which they depend.

 Implement conservation measures that reduce or eliminate threats to Bureau Sensitive species to 

minimize the likelihood of and need for the ESA-listing of these species.

 Conserve or create habitat for species addressed by the Migratory Bird Treaty Act and the Bald and 

Golden Eagle Protection Act and the ecosystems on which they depend.

Under the Proposed RMP, the BLM would implement the mitigation measure described in the Draft 

RMP/EIS for BLM participation in barred owl management (see Appendix X). As described in the Draft 

RMP/EIS, the BLM would cooperate with the U.S. Fish and Wildlife Service and provide financial 

support for their experimental removal of barred owls. Further, when the U.S. Fish and Wildlife Service 

determines the best manner in which barred owl management can contribute to the recovery of the 

northern spotted owl, the BLM would participate in, cooperate with, and provide support for an 

interagency program for barred owl management to implement Recovery Action 30. Barred owl 

management actions on BLM-administered lands within the range of the northern spotted owl could 

include BLM participation in scheduling, funding, and implementing such actions.

The Proposed RMP includes a requirement to avoid the incidental take of northern spotted owls from 

timber harvest until implementation of a barred owl management program has begun. As part of the 

process to determine whether a planned timber harvest would result in take of northern spotted owls, the 

BLM would establish whether the northern spotted owl is actually present in the area that would be 

affected by the timber harvest using the best available science at that time, such as through pre-project 

northern spotted owl surveys.

Management for the marbled murrelet under the Proposed RMP includes—

 A requirement for survey of nesting habitat in all land use allocations in marbled murrelet Zone 1 

and in reserve land use allocations in marbled murrelet Zone 2;

 A requirement for protection of habitat within 300 feet around newly discovered occupied 

marbled murrelet sites; and

 The protection of trees capable of providing marbled murrelet nesting structures in younger 

stands within the Harvest Land Base in marbled murrelet Zone 1.
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The Proposed RMP also includes a requirement for surveys for North Oregon Coast Distinct Population 

Segment of the red tree vole prior to management actions north of Highway 20 and protection of habitat 

areas around known sites and newly discovered nest sites north of Highway 20, and protection of known 

sites in the Late-Successional Reserve and Riparian Reserve south of Highway 20.

Wild Horses

 Manage and maintain a healthy population of wild and free-roaming horses in the Pokegama Herd 

Management Area of the Klamath Falls Field Office.

Mitigation

The Council on Environmental Quality regulations state that mitigation includes avoiding, minimizing, 

rectifying, reducing, eliminating, or compensating for adverse environmental impacts (40 CFR 1508.20). 

The BLM NEPA Handbook explains that measures or practices should only be termed mitigation 

measures if they have not been incorporated into the proposed action or alternatives. If they are 

incorporated into the proposed action or alternatives, they are called design features, not mitigation 

measures (BLM Handbook 1790-1 – National Environmental Policy Act, USDI BLM 2008, p. 61). Most 

of the measures that would avoid, rectify, or reduce environmental impacts are integral to the design of 

the alternatives and the Proposed RMP, such as the size, location, and extent of the Late-Succession 

Reserve, and therefore these design features cannot be addressed as discrete mitigation measures. 

Throughout Chapter 3, this Proposed RMP/Final EIS describes the varying effects of these different 

design features and their effectiveness at avoiding, minimizing, rectifying, reducing, eliminating, or 

compensating for adverse environmental impacts. These different design features and their effects are too 

numerous and too thoroughly integrated into the analysis in Chapter 3 to enumerate here. 

Best Management Practices (BMPs) are practices that have been determined to be the most effective and 

practicable in preventing or reducing the amount of pollution generated by diffuse sources to a level 

compatible with water quality goals (40 CFR 130.2 [m]). The BMPs are measures or practices that would 

avoid, rectify, or reduce environmental impacts, and are included in the approved RMP. Appendix J lists 

the BMPs and provides a detailed discussion of the role and application of BMPs. Under all alternatives 

and the Proposed RMP, project-level planning and analysis would identify the appropriate and applicable 

BMPs needed to achieve management objectives.

The Draft RMP/EIS identified one potential mitigation measure common to all action alternatives: BLM 

participation in barred owl management. This measure has been incorporated into the Proposed RMP, as

described above and in Appendix X.

Alternatives Considered but not Analyzed in Detail

An EIS must rigorously explore and objectively evaluate all reasonable alternatives. The BLM may 

eliminate from detailed analysis alternatives that are not reasonable. As explained in the BLM NEPA 

Handbook (USDI BLM 2008, p. 52), an alternative need not be analyzed in detail if–

 It does not meet the purpose and need (see Chapter 1 for the purpose and need);

 It is technically or economically infeasible;

 It is inconsistent with the basic policy objectives for the management of the area (see Chapter 1 

for the guidance for the formulation of alternatives);

 Its implementation is remote or speculative;

 It is substantially similar to an alternative being considered in detail; or

 It would have substantially similar effects to an alternative being considered in detail.
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The BLM considered the following alternatives but eliminated them from detailed analysis, as explained 

below.

No Timber Harvest

This alternative would prohibit all timber harvesting on BLM-administered lands. The BLM eliminated 

this alternative from detailed analysis because it would not meet the purpose and need, which includes 

providing a sustained yield of timber in accordance with the O&C Act.

This Proposed RMP/Final EIS does make use of a reference analysis of no timber harvest on BLMadministered lands. This reference analysis is not a reasonable alternative. Instead, this Proposed

RMP/Final EIS includes discussion of this reference analysis to provide context and a point of 

comparison as needed to analyze and interpret the effects of the alternatives.

Continuation of the Current Practices

This management approach would seek to continue the varying current practices that the BLM has been 

implementing since the adoption of the 1995 RMPs. The BLM cannot analyze continuation of the current 

practices as the No Action alternative. Additionally, the BLM has eliminated from detailed analysis the 

continuation of the current practices as an action alternative.

As discussed earlier in this chapter, the No Action alternative in this Proposed RMP/Final EIS is 

implementation of the 1995 RMPs as written (in contrast to using one of the variable years representing 

how the BLM has been implementing the 1995 RMPs). It is not possible to analyze continuation of the 

current practices within the decision area as the No Action alternative for two reasons. First, 

implementation of the timber management program has departed substantially from the outcomes 

predicted in the 1995 RMPs, and the manner and intensity of this departure has varied substantially over 

time and among districts (USDI BLM 2012, pp. 6–12). There is no apparent basis on which the BLM 

might select and project into the future the continuation of practices from a specific year (or set of years) 

since 1995. Second, continuing to harvest timber at the current declared annual productive capacity level 

for multiple decades into the future would not be possible using the current practices of predominately 

thinning harvests (USDI BLM 2012, pp. 6–12). The No Action alternative provides a benchmark to 

compare outputs and effects, even though this alternative does not meet the purpose and need of the 

project. Because of the inherent unsustainability and variability of current practices, the BLM cannot 

project their implementation into the future; thus, analyzing continuation of the current practices would 

not serve the essential function of the No Action alternative of providing a baseline for comparison of 

outputs and effects. In contrast, it is possible for the BLM to project the implementation of the 1995 

RMPs as written for multiple decades into the future and provide a baseline for comparison to the action 

alternatives.

The BLM will not present the implementation of the 1995 RMPs as written and continuation of the 

current practices as two separate No Action alternatives. The BLM developed two separate No Action 

alternatives in a previous planning effort to amend the 1995 RMPs, and the District Court for the Western 

District of Washington determined this approach was inconsistent with NEPA. The District Court for the 

Western District of Washington stated that agencies are “...obligated to provide a single, comprehensive 

no-action alternative that accurately represented the status quo...” Conservation NW. v. Rey, 674 F. Supp. 

2d 1232, 1251 (W.D. Wash. 2009). The status quo at this time is that the BLM must implement actions in 

conformance with the 1995 RMPs, consistent with 43 CFR 1610.5–3. Therefore, implementation of the 

1995 RMPs as written, amended, and modified by court orders, represents the single No Action 

alternative for this RMP revision.
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The BLM also eliminated continuation of the current practices from detailed analysis as an action 

alternative, because it would not be a reasonable alternative, in that it would not meet the purpose and 

need for this planning effort. The purpose and need includes providing a sustained yield of timber, which 

requires that the management of the forest provide a continuous volume of timber at the current intensity 

of management without decline. The current implementation practices in the timber program are not 

sustainable (USDI BLM 2012, pp. 6–12).

Timber harvest practices have varied since the adoption of the 1995 RMPs. Nevertheless, in recent years, 

all districts have implemented a timber harvest program that has been predominately thinning. The level 

of regeneration harvest has been substantially less than assumed in the 1995 RMPs for all districts, 

ranging from 4 percent to 16 percent of the assumed levels during the period from 2004 to 2010 (USDI 

BLM 2012, p. 7, Appendices 3–8). Thus, a management approach that would limit timber harvest to 

thinning would approximate the continuation of the practices of the past decade.

The 2008 FEIS analyzed a sub-alternative of Alternative 1 that would limit timber harvest to thinning, 

which provides an approximation of the effects of continuation of the current practices. That analysis 

evaluated how long thinning alone could provide at least 90 percent of the annual productive capacity for 

Alternative 1. That analysis concluded that none of the sustained-yield units could maintain that harvest 

level for a decade. As concluded in that analysis, “This sub-alternative demonstrates that high levels of 

thinning cannot be maintained for extended periods to sustain an allowable sale quantity”

28 (USDI BLM 

2007, p. 561). That analysis is incorporated here by reference (USDI BLM 2007, pp. 560–561). The 

timber harvest level of Alternative 1 would have been higher than the timber volume being produced 

under current practices. Thus, at the slower pace of harvesting under the current practices, compared to 

the harvest rates assumed under Alternative 1 in the 2008 FEIS, it could be inferred that thinning might be 

able to support the current harvest volume for approximately one to two decades. However, during the 

years since the BLM conducted that analysis, the BLM has continued to harvest predominately with 

thinning, exhausting much of the thinning opportunities considered in that analysis. As a result, the 

overall analytical conclusion from the 2008 FEIS that high levels of thinning can only be sustained for 

less than a decade is still applicable.

This analytical conclusion is consistent with the plan evaluations that the BLM conducted in 2012, which 

determined that the current timber harvest practices are “not sustainable at the declared ASQ level” due to 

reliance on predominately thinning (USDI BLM 2012, pp. 10–11).

In summary, the BLM cannot analyze continuation of the current practices as the No Action alternative, 

because the current practices have been variable and are not sustainable, preventing the projection of the 

current practices into the future. The BLM has eliminated from detailed analysis the continuation of the 

current practices as an action alternative, because it would not be a reasonable alternative, in that it would 

not provide for a sustained yield of timber over the long term. The analysis of a thinning only subalternative in the 2008 FEIS provides an approximation of the effects of this management approach, 

concluding that thinning levels can only be sustained for less than a decade.

 

28 As noted in Chapter 1, the terms ‘annual productive capacity,’ ‘annual sustained yield capacity,’ and ‘allowable 

sale quantity’ are synonymous.
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Implement the 1995 RMPs at the Sustained-yield Timber Harvest Levels 

Declared in the 1995 RMPs

This alternative would implement the 1995 RMPs as written with the annual productive capacity for 

sustained-yield timber fixed at the level declared in the 1995 RMPs. The BLM eliminated this alternative 

from detailed analysis because—

 It is reasonably foreseeable that the BLM would adjust the annual productive capacity based on 

new information and analysis;

 Ignoring new information and analysis on annual productive capacity would produce a flawed 

and incomplete analysis of environmental effects;

 The 1994 RMP/EISs already analyzed a management approach with an annual productive 

capacity at the currently declared levels; and

 A management approach with an annual productive capacity at the currently declared levels does 

not represent a benchmark among the range of alternatives in this Proposed RMP/Final EIS.

As discussed earlier in this chapter, the No Action alternative in this Proposed RMP/Final EIS is 

implementation of the 1995 RMPs as written. The 1995 RMPs determined and declared the annual 

productive capacity to be 211 MMbf, based on information and analysis available at that time. In response 

to new information described in plan evaluations, the BLM adjusted the annual productive capacity in 

1999 in some sustained-yield units through plan maintenance, resulting in a total annual productive 

capacity of 203 MMbf. As part of the analysis of the No Action alternative in this RMP/EIS, the BLM has 

calculated the annual productive capacity under the management described in the 1995 RMPs (i.e., the 

land use allocations and management direction), in light of the most current information available to the 

BLM on the condition of forests within the decision area. That analysis demonstrates that the annual 

productive capacity under the management described in the 1995 RMPs, based on current conditions and 

current information, would be 277 MMbf. The discussion in Chapter 3 in the Forest Management section 

explains the reasons for this increase in the determination of the annual productive capacity. This 

conclusion is consistent with the conclusion in the 2008 FEIS, which calculated the annual productive 

capacity for the No Action alternative to be 268 MMbf at that time. If the BLM were to adopt the No 

Action alternative at the conclusion of this planning process, it is reasonably foreseeable that the BLM 

would adjust the declaration of the annual productive capacity through plan maintenance based on this 

new information, as the BLM did in 1999 following plan evaluations. Even if the BLM were to eschew 

any amendment or revision of the 1995 RMPs, the regulations at 43 CFR 1610.5–4 would still compel the 

BLM to maintain the 1995 RMPs and refine the previously approved decision based on a change in data. 

Therefore, it is not reasonably foreseeable that, under the No Action alternative, the BLM would continue 

in the future to determine the annual productive capacity to be 203 MMbf (or the originally declared 211 

MMbf).

For the purpose of RMP analysis, the determination of the amount of sustained-yield timber harvest that 

the BLM could produce under an alternative is indirectly determinative of a host of environmental effects, 

as documented throughout Chapter 3 of this Proposed RMP/Final EIS. To ignore new information and 

inaccurately analyze the amount of sustained-yield timber harvest under an alternative, (i.e., to fix the 

annual productive capacity for the No Action alternative at either 203 or 211 MMbf) would provide a 

flawed and incomplete analysis of environmental effects.

The BLM presented analysis of the 1995 RMP with an annual productive capacity of 211 MMbf in the 

RMP/EISs for the 1995 RMPs (USDI BLM 1994 a, b, c, d, e, f). For many effects, that analysis remains a 

reasonably accurate depiction of the effects of an alternative with that level of sustained-yield timber 

harvest. The plan maintenance prepared by the BLM for the adjustments of the annual productive 

capacity to 203 MMbf documented that the adjustment was simply a refinement of the previously 

approved decision and did not require additional NEPA analysis (e.g., USDI BLM 2003a, p. 108).
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Finally, omitting detailed analysis of an alternative with an annual productive capacity of 203 MMbf (or 

the originally declared 211 MMbf) from this RMP/EIS does not deprive the BLM of a benchmark in its 

analysis. The alternatives and sub-alternatives in the Proposed RMP/Final EIS would result in an annual 

productive capacity that ranges from 119 to 486 MMbf. Both Sub-alternative B and Alternative D would 

result in an annual productive capacity lower than 203 MMbf. Thus, an alternative with an annual 

productive capacity of 203 MMbf (or the originally declared 211 MMbf) represents an intermediate level 

of resource development and an intermediate outcome. Regardless of whether the BLM analyzes the 

continued implementation of the 1995 RMPs with an annual productive capacity calculated based on the 

current information or fixed at the previous declared level, the range of alternatives analyzed in the 

Proposed RMP/Final EIS spans “the full spectrum of alternatives,” and the action alternatives include 

management approaches with “greater and lesser levels of resource development,” consistent with 

guidance from the Council on Environmental Quality (“Forty Most Asked Questions...” 46 FR 18027).

‘Natural Selection Alternative’ – Harvest Only Dead and Dying Trees

This alternative would remove only “naturally selected dead and dying trees, conditioned upon meeting 

the needs of other species.” Timber harvesting of such trees would be accomplished with small equipment 

from a network of narrow roads. The BLM eliminated this alternative from detailed analysis because it 

would not meet the purpose and need and the basic policy objectives described in the guidance for 

development of all action alternatives, in that it would not make a substantial and meaningful contribution 

to providing a sustained yield of timber. As explained in the Purpose and Need for Action in Chapter 1, 

O&C Act states that “[t]he annual productive capacity for such lands shall be determined and declared...” 

and that volume of timber “...shall be sold annually.” To limit the harvest of timber to trees that die or are 

dying would not reflect the annual productive capacity for such lands. Furthermore, the timber volume in 

dead and dying trees from year to year would be inherently unpredictable and variable, and thus would 

not support sustained-yield timber production because the annual volume for sale would fluctuate 

unpredictably based on annual conditions. Therefore, limiting the harvest of timber to trees that die or are 

dying would not be consistent with the requirements of the O&C Act and would not respond to the 

purpose for the action.

Harvest Only Small-diameter Trees with a One-time Entry 

This alternative would limit timber harvest to small diameter trees cut for restoration treatments. Timber 

harvest would be conducted only as a one-time entry into stands for timber volume. The BLM eliminated 

this alternative from detailed analysis because it would not meet the purpose and need and the basic 

policy objectives described in the guidance for development of all action alternatives, in that it would not 

make a substantial and meaningful contribution to providing a sustained yield of timber. An alternative 

designed for “one-time entry” with restoration as the primary objective would not provide sustained yield 

of timber. Limiting timber harvest to “one-time entry” and establishing restoration of some resource 

condition as the primary objective would preclude producing a given volume of timber in perpetuity at a 

given intensity of management, as required by the O&C Act and specifically described in the purpose for 

the action. Therefore, such an alternative would not be a reasonable alternative.

Maximize Carbon Storage

This alternative would maximize the storage of carbon on BLM-administered lands. The Draft RMP/EIS 

analyzed the effects of the alternatives on carbon storage. The BLM considered those effects on carbon 

storage, as well as the effects on other resources, in the development of the Proposed RMP. However, the 

BLM has no specific legal or regulatory mandate or policy direction to manage BLM-administered lands 
104 | P a g e

for carbon storage, and carbon storage is not part of the purpose and need for action. Therefore, the BLM 

has not developed alternatives specifically and explicitly intended to maximize carbon storage.

The BLM has various climate-related policies, including the following:

 Executive Order 13514, which directs agencies to measure, manage, and reduce greenhouse gas 

emissions toward agency-defined targets for agency actions such as vehicle fleet and building 

management

 Executive Order 13653, which directs agencies to assess climate change related impacts on and 

risks to the agency’s ability to accomplish its missions, operations, and programs and consider the 

need to improve climate adaptation and resilience

 Secretarial Order 3289, which establishes a Department of the Interior approach for applying 

scientific tools to increase understanding of climate change and to coordinate an effective 

response to its impacts

 Departmental Manual 523 DM 1, which directs the Department of the Interior agencies to 

integrate climate change adaptation strategies into programs, plans, and operations

These policies address topics related to greenhouse gas emissions and climate change, but none directs the 

BLM to manage BLM-administered lands specifically for carbon storage. This Proposed RMP/Final EIS 

is consistent with these policies to the extent they address topics within the scope of this planning effort.

Protect All Nesting, Roosting, and Foraging Habitat for the Northern 

Spotted Owl

The BLM eliminated this alternative from detailed analysis because it would be substantially similar in 

design and effects to Sub-alternative C, which would reserve all forests 80 years of age and older. 

Although an age threshold of 80 years old does not function as a de facto definition of nesting, roosting, 

and foraging habitat, the majority of forests over 80 years of age provide nesting, roosting, and foraging 

habitat for the northern spotted owl, and the majority of forests less than 80 years of age do not provide 

nesting, roosting, and foraging habitat. At the scale of analysis of the decision area, an alternative that 

would reserve all nesting, roosting, and foraging habitat for the northern spotted owl would not be 

sufficiently different from Sub-alternative C to warrant separate analysis.

Reserve All Forests 200 Years of Age and Older

The BLM eliminated this alternative from detailed analysis because it would not meet the purpose and

need and the basic policy objectives described in the guidance for development of all action alternatives, 

in that it would not make a substantial and meaningful contribution to maintaining older, more 

structurally-complex multi-layered conifer forest. Forests 200 years of age and older only constitutes 

about two-thirds of the structurally-complex forest, according to the structural stage descriptions used in 

this Proposed RMP/Final EIS. This alternative would leave too much older, more structurally-complex 

multi-layered conifer forest available for timber harvest to constitute a substantial and meaningful 

contribution to maintaining older, more structurally-complex multi-layered conifer forest.

Maintain the 50 Percent of the Landscape with the Highest Structural 

Complexity

This alternative, which was suggested in public comments on the Draft RMP/EIS, would identify the 50 

percent of the moist forest landscape with the highest structural complexity and manage those stands to 

promote and enhance their structural complexity. The remainder of the landscape would be available for 

variable retention regeneration harvest. This alternative would include monitoring the development of 

structural complexity and re-designating the most valuable 50 percent every 10 years. 
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The proponent of this alternative does not provide enough detail or explanation for the BLM to develop 

this proposal into an alternative. Specifically, the proponent does not specify if the retention of 50 percent 

of the landscape in a reserve system would include reserves for other objectives, such as Riparian 

Reserve, District-Designated Reserves, and Congressionally Reserved lands, or if the 50 percent of the 

landscape that would be managed for structural complexity would be in addition to these reserves for 

other objectives.

If the proponent intends that the 50 percent of the landscape that would be managed for structural 

complexity includes reserves for other objectives, such as Riparian Reserve, District-Designated 

Reserves, and Congressionally Reserved lands, then the resultant reserve network as a whole would 

include approximately 11–24 percent of the decision area managed for structural complexity, depending 

upon the approach for these other reserves. For comparison, the action alternatives would allocate a LateSuccessional Reserve network of 29–46 percent of the decision area. The BLM eliminated this alternative 

from detailed analysis because such a small reserve network would be insufficient to meet the purpose of 

contributing to the conservation and recovery of threatened and endangered species.

If the proponent intends that the 50 percent of the landscape that would be managed for structural 

complexity in addition to reserves for other objectives, such as Riparian Reserve, District-Designated 

Reserves, and Congressionally Reserved lands, then the resultant Harvest Land Base would be 

approximately 5–18 percent of the decision area, depending upon the approach for these other reserves. In 

comparison, the Harvest Land Base ranges from 14 percent to 40 percent of the decision area for the 

alternatives. However, the approach for formulation of the other reserves would be critical in evaluating 

an alternative that proposes 50 percent of the landscape to be managed for structural complexity in 

addition to reserves for other objectives, both in the alternative’s ability to meet the purpose and need and 

the effects of the alternatives. Without further information on the approach for the other reserves, 

especially the Riparian Reserve, the BLM cannot fully formulate such an alternative.

In addition to more detail being necessary in order to consider for detailed analysis, the proponent’s 

alternative at face value would not meet the purpose and need, which includes contributing to the 

conservation and recovery of threatened and endangered species. As the purpose and need explains, 

contributing to the conservation and recovery of the spotted owl necessarily includes maintaining a 

network of large blocks of forest to be managed for late-successional forests. Retaining 50 percent of the 

moist forest landscape with the highest structural complexity does not provide for the maintenance of 

large blocks of forest to be managed for late-successional forest and therefore is not a reasonable 

alternative. It would instead reserve forest based on its current structural condition. Setting a simple 

landscape target for forest structural conditions would not provide an effective conservation strategy for 

threatened and endangered species. The BLM eliminated this alternative from detailed analysis because it 

would not meet the purpose and need.

Do Not Reserve Older, More Structurally-complex Forest

The BLM eliminated this alternative from detailed analysis because it would not meet the purpose and 

need, which includes contributing to the conservation and recovery of ESA-listed species. As the purpose 

and need explains, contributing to the conservation and recovery of the spotted owl necessarily includes 

maintaining older and more structurally-complex multi-layered conifer forests. As such, any alternative 

that does not maintain older, more structurally-complex forest is not a reasonable alternative.
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Increase Riparian Reserve Widths

This alternative would include a Riparian Reserve that would be wider than the Riparian Reserve in the 

No Action alternative (i.e., more than two site-potential tree heights on fish-bearing streams and more 

than one site-potential tree height on non-fish-bearing streams). Such an alternative would be 

substantially similar to the Riparian Reserve in the No Action alternative, because of its effect on the 

conservation and recovery of ESA-listed fish and the protection of clean water. Based on the results in the 

interagency Aquatic and Riparian Effectiveness Monitoring Program, which evaluated watershed 

condition and trend in the Northwest Forest Plan area, the protections provided, in part, by the Riparian 

Reserve, are improving watershed conditions (Miller et al. 2015, Lanigan et al. 2012). Additional width 

of the Riparian Reserve would not provide additional protections for fish habitat or water quality. 

Furthermore, the Riparian Reserve in the No Action alternative was designed to meet an array of 

objectives, including broad ecological objectives and riparian and terrestrial species habitat. In contrast, 

the Riparian Reserve in the action alternatives is designed to meet narrower objectives: conservation and 

recovery of ESA-listed fish and protection of clean water, consistent with the purpose and need for action. 

Because of these narrower objectives, the action alternatives considered in detail do not include widening 

the Riparian Reserve widths. The action alternatives address the broad ecological objectives and 

terrestrial species habitat objectives from the Aquatic Conservation Strategy of the No Action alternative 

through a variety of approaches, such as larger Late-Successional Reserve, maintaining older, more 

structurally-complex forest, and specific management direction for protection of habitat components in 

the Harvest Land Base. Because the action alternatives include a range of such approaches, it would be 

unwarranted to add these broad ecological objectives and terrestrial species habitat objectives to the 

Riparian Reserve in the action alternatives.

2008 BLM RMPs (Western Oregon Plan Revisions)

This alternative would manage BLM-administered lands consistent with the 2008 Records of 

Decision/RMPs. The U.S. District Court, District of Oregon (Pacific Rivers Council et al. v. Shepard, 

03:11-CV-442-HU, 2012 WL 950032 (D. Or. March 20, 2012)) vacated the 2008 Records of 

Decision/RMPs on May 16, 2012. The BLM eliminated this alternative from detailed analysis because it 

would not meet the purpose and need and therefore is not a reasonable alternative. As the purpose and 

need explains, contributing to the conservation and recovery of the spotted owl necessarily includes 

maintaining older and more structurally-complex multi-layered conifer forests. As such, any alternative 

that does not maintain older, more structurally-complex forest is not a reasonable alternative. Specifically, 

the 2008 RMPs would not maintain older and more structurally-complex multi-layered conifer forests, 

because they would only defer the harvest of older forests for 15 years, after which such stands would be 

available for timber harvest. On the face of it, an alternative that would plan the harvest of these older, 

more structurally-complex forests after 15 years would not be consistent with maintaining these forests, 

as the purpose for the action specifically requires. Therefore, an alternative that would manage BLMadministered lands consistent with the 2008 Records of Decision/RMPs would not meet the purpose of 

the action to contribute to the conservation and recovery of ESA-listed species.

Oregon Forest Practices Act

This alternative would manage BLM-administered lands with only those protections required by the 

Oregon Forest Practices Act, such as riparian protections and retention requirements during timber 

harvest. The BLM eliminated this alternative from detailed analysis because it would not meet the 

purpose and need for action and therefore is not a reasonable alternative.

In the 2008 FEIS, the BLM used a reference analysis of managing most commercial forest lands for 

timber production, which considered the effects of managing “...in a manner similar to private industrial 

lands” and that analysis is incorporated here by reference (USDI BLM 2008b, p. 484). The 2008 FEIS 
107 | P a g e

used this reference analysis to provide context and a point of comparison where needed to analyze the 

effects of the alternatives, rather than as a reasonable alternative itself. Nevertheless, the information in 

the 2008 FEIS on the effects of this reference analysis is sufficient to demonstrate that this management 

approach would not meet the purpose and need for action, in that it would not provide a substantial and 

meaningful contribution to the conservation and recovery of ESA-listed species, including the northern 

spotted owl, marbled murrelet, and numerous fish species. It would not meet the purpose and need for 

action because it would not provide a network of large blocks of forest to be managed for latesuccessional forests and maintain older and more structurally-complex multi-layered conifer forests and 

would not maintain marbled murrelet habitat (USDI BLM 2008b, p. 532). It would not meet the purpose 

and need for action because this management approach or similar management approaches would result in 

stream temperature increases after timber harvest, increased risk of sediment delivery to streams, and 

increased susceptibility to peak flows and subsequent adverse effects to fish habitat (USDI BLM 2008b, 

pp. 755–759, 762–764, 765).

Provide “Not Less than One-half Billion Feet Board Measure” of Timber

This alternative would include providing an annual productive capacity of at least 500 million board feet 

of timber. Several commenters have asserted during the planning process that the O&C Act makes this 

requirement of the BLM. The O&C Act directs, “The annual productive capacity for such lands shall be 

determined and declared as promptly as possible after August 28, 1937, but until such determination and 

declaration are made the average annual cut therefrom shall not exceed one-half billion feet board 

measure: Provided, that timber from said lands in an amount not less than one-half billion feet board 

measure, or not less than the annual sustained yield capacity when the same has been determined and 

declared, shall be sold annually, or so much thereof as can be sold at reasonable prices on a normal 

market.”

The purpose and need for action includes providing a sustained yield of timber but does not specify a 

target volume of timber. The basic policy objectives described in the guidance for development of all 

action alternatives stipulate that the alternatives must make a substantial and meaningful contribution to 

each of the purposes for action to be considered reasonable. The BLM has not specified a quantitative 

threshold for the amount of timber harvest that would constitute a substantial and meaningful contribution 

to sustained-yield timber production, and does not accept that “one-half billion feet board measure” (that 

is, 500 million board feet) is a relevant or appropriate threshold.

Moreover, the BLM does not accept that the O&C Act requires that this RMP provide an annual 

productive capacity of “not less than one-half billion feet board measure” of timber. The O&C Act 

requires that the BLM offer for sale annually “...not less than one-half billion feet board measure, or not 

less than the annual sustained yield capacity when the same has been determined and 

declared...”(emphasis added). Previous BLM planning efforts, including the 1995 RMPs, determined and 

declared the annual sustained yield capacity, rendering obsolete the requirement to offer for sale “...not 

less than one-half billion feet board measure.” This RMP revision will likewise determine and declare the 

annual sustained yield capacity based on the eventual RMP selected, again rendering obsolete the 

requirement to offer for sale “...not less than one-half billion feet board measure.”

Change the O&C Act

This alternative would change or repeal the O&C Act, changing or removing the mandate for the BLM to 

manage the O&C lands “for permanent forest production, and the timber thereon shall be sold, cut, and 

removed in conformity with the principle of sustained yield for the purpose of providing a permanent 

source of timber supply, protecting watersheds, regulating stream flow, and contributing to the economic 

stability of local communities and industries, and providing recreational facilities.” Changes to existing 
108 | P a g e

laws or repeal of existing laws are not within the authority of the BLM and would be beyond the scope of 

this action, which is to revise the current RMPs with management objectives, land use allocations, and 

management direction that best meet the purpose and need. The purpose and need specifically includes 

providing a sustained yield of timber as required by the O&C Act.

Bills have recently been introduced to Congress that would change or repeal the O&C Act, including H.R. 

1526 (O&C Trust, Conservation, and Jobs Act, passed House September 20, 2013) and S. 1784 (Oregon 

and California Land Grant Act of 2013, introduced December 9, 2013). Neither of these bills has yet 

become law. If Congress passes and the President signs into law any legislation that would change or 

repeal the O&C Act, the BLM would reconsider the purpose and need for action in this RMP revision, as 

appropriate. However, any such changes to the O&C Act or the purpose and need at this time would be 

speculative.

Comparison of Alternatives and the Proposed RMP

Table 2-11 summarizes key features of the alternatives and the Proposed RMP. This table is not 

comprehensive and focuses on design features that vary substantially among the alternatives and the 

Proposed RMP and are easily quantified and summarized. Appendix B of the Proposed RMP/Final EIS 

provides detailed descriptions of the management objectives and management direction for the Proposed 

RMP. Appendix B of the Draft RMP/EIS provides detailed descriptions of the management objectives 

and management direction for each action alternative.
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Table 2-11. Key features of the alternatives and the Proposed RMP

Alternative/

Proposed RMP

Total LateSuccessional

Reserve

(Acres)

Protection of

Structurallycomplex Forest

Riparian Reserve

Total Width

Riparian Reserve

Inner Zone Width

Marbled Murrelet

Survey and Protection

No Action 478,860 None specified

2 SPTH* on fish-bearing streams;

1 SPTH* on non-fish-bearing 

streams

None specified

Survey in Zones 1 and 2;

protect contiguous recruitment 

and existing habitat within 1/2

mile of sites

Alt. A 1,147,527 ≥ 120 years 1 SPTH* on all streams

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

None

Alt. B 1,127,320 District-defined map 

based on existing, 

district-specific 

information

1 SPTH* on perennial and fishbearing streams;

100’ on debris-flow-prone nonfish-bearing intermittent streams;

50’ on other non-fish-bearing 

intermittent streams

60’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

Survey in Zone 1;

protect contiguous habitat within 

300’ of sites Sub. B 1,422,933

Alt. C 949,279 ≥ 160 years 150’ on perennial and fishbearing streams;

50’ on non-fish-bearing streams

60’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

Survey stands >120 years;

protect contiguous habitat within 

300’ of sites

Sub. C 1,373,206 ≥ 80 years None

Alt. D 714,292

≥ 120/140/160 years 

on high/moderate/low 

productivity sites

1 SPTH* on all streams 120’ on all streams

Survey in Zones 1 and 2;

protect habitat within 1/2 mile of 

sites

PRMP 948,466

District-defined map 

based on existing, 

district-specific 

information (updated 

from Alternative B)

Class I and II subwatersheds:

1 SPTH* on all streams

Class I subwatersheds:

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams;

Middle zone from 50’ to 120’ on non-fishbearing intermittent streams

Survey nesting habitat in all land 

use allocations in Zone 1, survey 

nesting habitat in reserve land use 

allocations in Zone 2;

protect contiguous habitat within 

300’ of sites

Class III subwatersheds:

1 SPTH* on perennial and fishbearing streams;

50’ on non-fish-bearing 

intermittent streams

Class II and III subwatersheds:

120’ on perennial and fish-bearing streams;

50’ on non-fish-bearing intermittent 

streams

* Site-potential tree height
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Alternative/

Proposed RMP

Total

Harvest 

Land Base

(Acres)

Green Tree Retention

Areas of Critical

Environmental

Concern

(Number

Designated)

Recreation Management Areas

DistrictDesignated

ReserveLands

Managed for

their

Wilderness

Characteristics

(Acres)

Wild and Scenic Rivers

Recommended for National

System Inclusion

(Number of River Segments)

Special

Recreation

Management

Area

(Acres)

Extensive

Recreation

Management

Area

(Acres)

No Action 691,998

GFMA†: 6–8 TPA‡

Connectivity/Diversity:

12–18 TPA‡

Southern GFMA†:

16–25 TPA

86

(and 55 potential) 168,968 2,397,460 -

-

(all 51 eligible would continue 

receiving interim protections)

Alt. A 343,900 No retention 107 20,065 - 79,709 -

Alt. B 556,335 Low Intensity Timber Area:

15–30% retention

Moderate Intensity Timber 

Area: 5–15% retention

105 24,972 139,320 76,525 6

Sub. B 298,121

Alt. C 741,332

No retention 101 59,046 357,771 66,190 6

Sub. C 495,507

Alt. D 650,382

Owl Habitat Timber Area: 

maintain owl habitat

Moderate Intensity Timber 

Area: 5–15% retention

107 86,693 580,458 - 51

PRMP 469,215

Low Intensity Timber Area:

15-30% retention

Moderate Intensity Timber 

Area: 5–15% retention

108 70,730 420,311 79,107 6

† GFMA = General Forest Management Area

‡ TPA = Trees per acre
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Table 2-12 summarizes key effects of the alternatives and the Proposed RMP. This table is not 

comprehensive and focuses on effects that vary substantially among the alternatives and the Proposed 

RMP and are easily quantified and summarized. Inclusion or omission of effects from this table does not 

indicate the importance of the effects to the decision-making process. For example, the table does not 

include summarization of effects to northern spotted owls, because differences among the effects of 

alternatives and the Proposed RMP cannot be summarized briefly or quantitatively. Nevertheless, the 

effects on northern spotted owls are directly related to the purpose for the action, and these effects will be 

relevant in the decision-making process. Chapter 3 provides detailed analysis of the environmental 

consequences of the alternatives and the Proposed RMP.
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Table 2-12. Key effects of the alternatives and the Proposed RMP

Current 

Conditions

Payments to 

Counties Jobs

Allowable 

Sale Quantity 

of Timber

(MMbf/Year)

Total Timber 

Volume

(MMbf/Year)

Carbon Storage

(Teragrams)

Greenhouse Gas 

Emissions

(Megagrams of 

CO2e/Year)

Current (2012) $11.7 million* 7,403 203 205†367 123,032

Alternative/

Proposed RMP

Payments to 

Counties, Mid-Point 

of First Decade

(2012 dollars/Year)

Jobs, Mid-Point of 

First Decade

Allowable 

Sale Quantity 

of Timber

(MMbf/Year)

Total Timber 

Volume, Average of

First Decade

(MMbf/Year)

Carbon Storage

in 50 years

(Teragrams)

Greenhouse Gas 

Emissions in 10 Years

(Megagrams of 

CO2e/Year)

No Action $46.5 million 10,152 277 400 467 277,667

Alt. A $28.1 million 7,909 234 249 484 260,126

Alt. B $36.4 million 9,127 234 332 478 300,719

Alt. C $67.4 million 12,245 486 555 440 383,957

Alt. D $18.7 million 7,083 176 180 501 223,824

PRMP $25.6 million 8,549 205 278 482 230,759

Current 

Conditions

High Fire Hazard

in Interior/South

(Acres)

Marbled Murrelet 

High-quality Nesting 

Habitat

(Acres)

Existing 

Roads

(Miles)

Existing Sediment

Delivery to Streams 

(Tons/Year)

Potential Wood 

Supply to Streams

(TPA > 20” DBH)

Existing Detrimental 

Soil Disturbance

(Acres)

Current (2012) 194,690 233,219 14,330 60,265 19.0 139,299

Alternative/

Proposed RMP

High Fire Hazard

in Interior/South

in 50 Years

(Acres)

Marbled Murrelet 

High-quality Nesting 

Habitat in 50 Years

(Acres)

New Road 

Construction

in 10 Years

(Miles)

Additional Sediment 

Delivery to Streams, 

Average of First 

Decade

(Tons/Year)

Potential Wood

Supply to Streams

in 100 Years

(TPA > 20” DBH)

Additional Detrimental 

Soil Disturbance in 10 

Years

(Acres)

No Action 150,618 294,666 637 369 36.3 32,986

Alt. A 117,870 305,620 299 116 39.2 18,433

Alt. B 108,698 308,023 531 201 34.0 34,171

Alt. C 129,124 276,789 699 269 31.5 40,961

Alt. D 107,717 310,055 240 93 39.4 27,407

PRMP 116,172 308,863 437 165 37.0 31,563

* Payments counties would have received in 2012 if payments had been based on timber receipts instead of Secure Rural Schools payments

† Total timber volume offered for sale in 2012

DBH = Diameter at breast height

TPA = Trees per acre

MMbf = Million board feet
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References

Council on Environmental Quality (CEQ). 1981. Forty Most Asked Questions Concerning CEQ’s NEPA Regulations. 46 Fed. 

Reg. 18026 (March 23, 1981) as amended. http://energy.gov/sites/prod/files/G-CEQ-40Questions.pdf.

Lanigan, S. H., S. N. Gordon, P. Eldred, M. Isley, S. Wilcox, C. Moyer, and H. Andersen. 2012. Northwest Forest Plan–the first 

15 years (1994–2008): Watershed Condition Status and Trend. Gen. Tech. Rep. PNW-GTR-856. USDA Forest Service, 

Pacific Northwest Research Station, Portland, OR. 155 pp.

Miller, S. A., S. N. Gordon, P. Eldred, R. M. Beloin, S. Wilcox, M. Raggon, H. Andersen, and A. Muldoon. 2015. Northwest 

Forest Plan–the first 20 years (1994–2013): watershed condition status and trend. Gen. Tech. Rep. PNW-GTR-932. USDA

Forest Service, Pacific Northwest Research Station, Portland, OR.

Thomas, J. W., E. D. Forsman, J. B. Lint, E. C. Meslow, B. R. Noon, and J. Verner. 1990. A conservation strategy for the 

northern spotted owl. Interagency Scientific Committee to Address the Conservation of the Northern Spotted Owl. USDA 

FS, USDI BLM, USFWS, and USDI NPS, Portland, OR.

USDA FS and USDI BLM. 1994. Record of Decision for Amendments to Forest Service and Bureau of Land Management 

Planning Documents Within the Range of the Northern Spotted Owl, and Standards and Guidelines for Management of 

Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl. 

USDA Forest Service, USDI Bureau of Land Management. Portland, Oregon. Forest Service, Region 6 and U.S. Bureau of 

Land Management, Portland, OR.

USDI BLM. 1997. Standards for rangeland health and guidelines for livestock grazing management for public lands administered 

by the Bureau of Land Management in the states of Oregon and Washington. Oregon State Office, Portland, OR. 19 pp.

---. 2003a. 2002 Annual Program Summary for the BLM – Coos Bay District. April 2003. 

http://www.blm.gov/or/districts/coosbay/plans/files/2003_APS_draft.pdf.

---. 2007. Draft Environmental Impact Statement for the Revision of the Resource Management Plans of the Western Oregon 

Bureau of Land Management Districts. http://www.blm.gov/or/plans/wopr/deis/index.php.

---. 2008a. National Environmental Policy Act Handbook. H-1790-1. Release 1-1710, 20 January 2008. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_handbook.Par.24487.File.dat/

h1790-1-2008-1.pdf.

---. 2008b. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western Oregon 

Bureau of Land Management Districts. Oregon State Office. Portland, OR. Vol. I–IV. 

http://www.blm.gov/or/plans/wopr/final_eis/index.php.

---. 2012. Resource Management Plan Evaluation Report: Western Oregon. Portland, OR. 

http://www.blm.gov/or/plans/files/RMPEvaluation.pdf.

---. 2015b. BLM Western Oregon Aquatic Restoration Strategy. Bureau of Land Management Oregon/Washington. 41 pp.
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Chapter 3 – Affected Environment and 

Environmental Consequences

Introduction

This chapter describes the environment that the RMPs are likely to affect and the environmental 

consequences of the alternatives. Many EISs present the affected environment and environmental 

consequences in separate chapters. The BLM has combined these two topics into this single chapter to 

provide all of the relevant information on a resource in a single discussion.

This chapter includes sections on each resource that the RMPs are likely to affect. Each resource section 

begins with a summary of the methods used to analyze the effects of the alternatives and the Proposed 

RMP on this resource. Each section includes one or more subsections that address a particular question 

about how the alternatives would affect the resource (the BLM refers to these questions as ‘Issues’). 

Under each Issue, the BLM describes the status and trends of the pertinent resource and then answers the 

question by describing the environmental consequences to the resource of the Proposed RMP and all 

alternatives analyzed in detail, including the No Action alternative.

Summary of Notable Changes from the Draft RMP/EIS

Chapter 3 of this Proposed RMP/Final EIS—

 Updated information on other broad-scale analyses currently underway that the BLM considers as 

reasonably foreseeable actions for analyzing cumulative effects; 

 Revised the discussion of ‘Analytical Assumptions about RMP Implementation’ to address the 

Proposed RMP; 

 Updated baseline forest age and structural conditions resulting from 2013/2014 wildfires; and

 Added analysis of the effects of the Proposed RMP for each of the issues.

The Proposed RMP/Final EIS identifies changes to specific sections of this chapter in those sections.

The Planning Area

The planning area includes approximately 2.5 million acres of Federal surface ownership and an 

additional 68,600 acres of Federal minerals with private surface ownership in western Oregon managed 

by the BLM’s Coos Bay, Eugene, Medford, Roseburg, and Salem Districts, and the Klamath Falls Field 

Office of the Lakeview District (Map 1-1). The entire planning area includes approximately 22 million 

acres, but only 2.5 million acres, or 11 percent, are Federal lands administered by the BLM.29 Private 

landowners own and manage the majority of lands within the planning area (Figure 3-1).

 

29 As noted in Chapter 1, the BLM uses the term ‘planning area’ to refer to all lands within the geographic boundary 

of this planning effort regardless of jurisdiction and uses the term ‘decision area’ to refer to the lands within the 

planning area for which the BLM has authority to make land use and management decisions. Within the western 

Oregon districts, three BLM-administered areas are not included in the decision area: the Cascade Siskiyou National 

Monument (Medford District), the Upper Klamath Basin and Wood River Wetland (Klamath Falls Field Office), 

and the West Eugene Wetlands (Eugene District).
116 | P a g e

Private/Other

54%

BLM

11%

Forest Service

30%

Other Federal

1%

State/Local

4%

Figure 3-1. Major ownerships within the planning area 

There are five physiographic provinces within the planning area: Coast Range, Willamette Valley, West 

Cascades, Klamath, and East Cascades (Figure 3-2). The physiographic provinces vary in vegetation, 

hydrology, geology, and other processes (e.g., fire-return intervals) (FEMAT 1993). 
117 | Page

Figure 3-2. Physiographic provinces within the planning area as described in the FEMAT report (1993) 

The decision area includes O&C lands, Coos Bay Wagon Road lands, public domain lands, and acquired 

lands (Map 1-2, Table 3-1). The section ‘Major Authorizing Laws and Regulations’ in Chapter 1 

provides a description of the differing legal mandates that apply to these lands. The O&C lands are mostly 

scattered and intermingled with private, industrial forestlands. The O&C land pattern has a checkerboard 

character that results from the grid of the Public Land Survey System. The O&C lands are generally 

located in the odd-numbered sections, and the intermingled private lands are in the even-numbered 

sections. A section in the checkerboard is typically one mile on a side and encloses approximately 640 

acres. About half of the public domain lands are scattered and intermingled with O&C lands, and the 

other half exist as larger blocks in the Salem, Coos Bay, and Lakeview BLM Districts (with the majority 

being concentrated in the Klamath Falls Field Office of the Lakeview District). 
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Table 3-1. Land status of the decision area 

Land Status Acres Decision Area

(Percent)

O&C Lands 2,025,826 81.2%

Coos Bay Wagon Road Lands 74,598 3.0%

Public Domain Lands 384,273 15.4%

Acquired Lands 8,958 0.4%

Totals 2,493,655 100%

Analytical Methodologies and Assumptions 

This section describes the overall scope and analytical approach for this Proposed RMP/Final EIS, as well 

as key analytical assumptions that are common to all analyses. The individual resource sections of this 

chapter and accompanying appendices include assumptions that are specific to that resource or program. 

In addition, Section C of the 2013 Planning Criteria for the RMPs for Western Oregon (hereinafter 

Planning Criteria), which is incorporated here by reference, includes detailed descriptions of the 

assumptions that are specific to individual resources or programs (USDI BLM 2013, pp. 27–204). The 

individual resource sections in this chapter describe any notable changes that the BLM has made to the 

methods and assumptions in the Planning Criteria since its publication. 

Scope of the Analysis 

The Council on Environmental Quality’s regulations for implementing NEPA direct that “NEPA 

documents must concentrate on the issues that are truly significant to the action in question, rather than 

amassing needless detail” (40 CFR 1500.1[b]). Issues are “truly significant to the action in question” if 

they are necessary to make a reasoned choice between alternatives (i.e., the issue relates to how the 

alternatives respond to the purpose and need). Issues are also “truly significant to the action in question” 

if they relate to significant direct, indirect, or cumulative impacts caused by the alternatives. For this 

analysis, each resource section identifies the issues that are “significant to the action in question” and 

focuses the analysis on those issues. 

The Council on Environmental Quality’s regulations for implementing NEPA requires that an EIS 

disclose both the direct and indirect effects on the quality of the human environment of a proposed action 

or alternative. 

Direct effects are those effects that are caused by the action and occur at the same time and place (40 CFR 

1508.8(a)). For the most part, RMPs in and of themselves have minimal direct effects. This is because an 

RMP is typically implemented only through the approval of future proposed projects and activities 

consistent with the management direction of the RMP, and because there are numerous steps that must 

occur before any on-the-ground activities can actually occur. There are exceptions to this, in which an 

RMP could have direct effects on resources. For example, an RMP may designate an area as open for 

public motorized access, and thus the BLM would have no further decision-making before on-the-ground 

activities and effects on resources could occur. Additionally, an RMP may sometimes include 

implementation decisions within the RMP Record of Decision. 

Indirect effects are those effects that are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable (40 CFR 1508.8(b)). With few exceptions as described 

above, the effects of an RMP represent indirect effects. That is, an RMP is designed to guide and control 
119 | P a g e

future management actions (43 CFR 1601.0–2), but those actions and their effects are later in time than 

the RMP Record of Decision. Although the specific timing, size, location, and design of future actions 

that would occur under each alternative and the Proposed RMP are not certain, the BLM can project a 

reasonable forecast of future actions consistent with the management direction of the alternatives and the 

Proposed RMP for the analysis in this Proposed RMP/Final EIS. The section below on Vegetation 

Modeling includes a more detailed description of this projection of future actions.

Cumulative effects result from the incremental impact of an action when added to past actions, other 

present actions, and reasonably foreseeable actions (40 CFR 1508.7). Due to the nature of the analysis in 

this large-scale and long-term planning effort, all environmental effects described in this Proposed 

RMP/Final EIS would have incremental impacts that would have a cumulative effect together with past 

actions, other present actions, and reasonably foreseeable actions. Therefore, there is not a discrete and 

separate section labeled as cumulative effects. The discussion of effects on each resource incorporates the 

effects of past actions, and describes other present actions and reasonably foreseeable actions to provide 

context in which the incremental effects are examined, thus revealing the cumulative effects of the 

alternatives and the Proposed RMP.

As the Council on Environmental Quality points out, in guidance issued on June 24, 2005, the 

“environmental analysis required under NEPA is forward-looking,” a review of past actions is required 

only “to the extent that this review informs agency decision making regarding the proposed action.” Use 

of information on the effects of past actions may be valuable in two ways according to the Council on 

Environmental Quality guidance: for consideration of the proposed action’s cumulative effects and as a 

basis for identifying the proposed action’s direct and indirect effects.

The Council on Environmental Quality stated in this guidance that “[g]enerally, agencies can conduct an 

adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without 

delving into the historical details of individual past actions.” This is because a description of the current 

state of the environment inherently includes the effects of past actions. The Council on Environmental 

Quality guidance specifies that the “[Council on Environmental Quality] regulations do not require the 

consideration of the individual effects of all past actions to determine the present effects of past actions.” 

The existing baseline information used in this analysis is a result of the aggregation of all past actions. 

The information on the current conditions is more comprehensive and more accurate for establishing a 

useful starting point for a cumulative effects analysis than attempting to establish such a starting point by 

adding up the described effects of individual past actions to some environmental baseline condition in the 

past, which unlike current conditions can no longer be verified by direct examination.

The second area in which the Council on Environmental Quality guidance states that information on past 

actions may be useful is in “illuminating or predicting the direct and indirect effects of a proposed 

action.” The basis for predicting the direct and indirect effects of this proposed action and its alternatives 

is published empirical research, the general accumulated experience of the resource professionals in the 

agency with similar actions, and using models based on current scientific knowledge regarding 

relationships of the proposed management directions and effects that are generally accepted by the 

scientific community in the various specialized fields.

Scoping for this project did not identify any need to list individual past actions nor to analyze, compare, 

or describe environmental effects of individual past actions in order to complete an analysis that would be 

useful for illuminating or predicting the effects of the proposed action.

In this Proposed RMP/Final EIS, the BLM incorporated the effects of present actions into the description 

of the current condition, consistent with Council on Environmental Quality guidance and Department of

Interior NEPA regulations at 43 CFR 46.115. For the purpose of this analysis, the BLM assumed that 
120 | P a g e

projects implementing the 1995 RMPs for which the BLM had made a decision prior to October 2012 

have been implemented. For example, a timber sale sold prior to that date has been displayed and 

analyzed as harvested, whether or not that harvest has yet been completed. This assumption may 

overestimate the actual acreage harvested from sold sales, because some sales have not yet been 

harvested. This analytical assumption does not constitute a decision in principle about the disposition of 

these sales. The BLM integrated the effects of present actions on other ownerships into the broader 

analysis of current condition and assumptions about continued management consistent with existing plans 

or current trends.

For BLM-administered lands, reasonably foreseeable future actions are those actions that would occur as 

described under the various alternatives and the Proposed RMP. For other ownerships within the planning 

area, reasonably foreseeable actions are those actions that would occur with the continuation of present 

management, also from a broad-scale perspective. It would be speculative for the BLM to presume 

knowledge of site-specific actions that would occur in the future on lands managed by others over the 

time period analyzed in the Proposed RMP/Final EIS. The BLM based these assumptions about future 

management on other ownerships on existing plans or current trends, and these assumptions are broad and 

general in nature. However, the broad assumptions are sufficient to provide context for evaluating the 

incremental effect of the alternatives.

There are other broad-scale analyses currently underway that the BLM considers as reasonably 

foreseeable actions for analyzing cumulative effects, including the U.S. Forest Service revision of the 

Okanagan-Wenatchee Forest Plans and the Oregon, Mormon Pioneer, California, and Pony Express 

National Historic Trails Feasibility Study Revision. The Jordan Cove Energy and Pacific Connector 

Pipeline Project, which the BLM had identified in the Draft RMP/EIS as a reasonably foreseeable future 

action, is no longer reasonably foreseeable, as discussed below.

Revision of the Okanogan-Wenatchee Forest Plans

The U.S. Forest Service is revising the land and resource management plans for the Okanogan-Wenatchee 

National Forests. The U.S. Forest Service released their Forest Plan Revision proposed actions on June 

30, 2011, followed by a 90-day comment period that closed on September 28, 2011. The Proposed Action 

is the first formal step to developing the revised plans. The U.S. Forest Service has not yet released a draft 

EIS or published an expected timeline for release of a draft EIS. At the time of preparation of this 

Proposed RMP/Final EIS, the U.S. Forest Service states that the Okanogan-Wenatchee Forest Plan 

Revision is on hold. The revisions of these plans are reasonably foreseeable future actions, in that there 

are formal proposals for these plan revisions. However, it would be speculative of the BLM to project any 

specific effects related to these plan revisions, given the early stage of the planning process and the 

undefined timetable for completion of the plan revisions.

The Oregon, Mormon Pioneer, California, and Pony Express National 

Historic Trails Feasibility Study Revision

The National Park Service is revising the original feasibility studies of the Oregon, Mormon Pioneer, 

California, and Pony Express National Historic Trails. The trail routes under consideration in this 

feasibility study include the Applegate Trail, which lies within the planning area and includes lands 

within the decision area. The National Park Service conducted external scoping in 2011. The National 

Park Service is currently collecting route data and will then prepare a combination feasibility study and 

environmental assessment. The feasibility study will evaluate the eligibility of the study routes for all four 

trails. Upon completion of the study, the National Park Service will submit the final documents with a 

recommendation to Congress. Congress could set them aside or pass legislation to add all, some, or none 

of the study routes to the Oregon, California, Mormon Pioneer, and Pony Express National Historic 
121 | P a g e

Trails. Although the National Park Service has begun the revision of the feasibility study, it is uncertain 

what recommendation the National Park Service will make regarding the Applegate Trail, or how 

Congress will act on the National Park Service recommendation. If Congress passes legislation to add the 

Applegate Trail to the National Historic Trails, the BLM may need to change the land use allocation or 

management direction along the trail segments in the decision area. However, at this early stage in the 

feasibility study, such an outcome is speculative.

Jordan Cove Energy and Pacific Connector Pipeline Project

The Federal Energy Regulatory Commission released the Jordan Cove Energy and Pacific Connector 

Pipeline Project Draft EIS in November 2014 (FERC 2014) and the Final EIS in September 2015 (FERC 

2015). The BLM was a cooperating agency in the preparation of that Final EIS. Jordan Cove Energy 

Project, L.P. proposes to construct and operate a liquefied natural gas export terminal at Coos Bay, 

Oregon. Pacific Connector proposes to construct and operate an approximately 232-mile-long, 36-inch 

diameter underground welded-steel pipeline between interconnections with the existing interstate natural 

gas systems of Ruby Pipeline LLC and Gas Transmission Northwest LLC near Malin, Oregon, and the 

Jordan Cove terminal. Implementation of the Pacific Connector pipeline would require a right-of-way

grant from the BLM to cross BLM-administered lands. The FERC-prepared Final EIS considered RMP 

amendments to the Coos Bay, Medford, and Roseburg Districts and the Klamath Falls Field Office 1995 

RMPs where the proposed action does not conform to those RMPs. The Draft RMP/EIS for this RMP 

revision identified that if the BLM were to make decisions on the proposed plan amendments and the 

Pacific Connector Pipeline right-of-way subsequent to the adoption of this RMP revision, the BLM would

make additional determinations regarding plan conformance for the Pacific Connector Pipeline Project.

The proposed pipeline would cross portions of Klamath, Jackson, Douglas, and Coos Counties, Oregon, 

including approximately 40 miles of BLM-administered lands. The construction of the pipeline would 

affect vegetation and habitat on approximately 803 acres of BLM-administered lands: 669 acres of forest, 

60 acres of rangeland, 54 acres of transportation-utility lands, less than 0.1 acre of agricultural land, 0.8 

acre of wetlands, 1 acre of water, and about 2 acres of barren lands/quarries. The construction of the 

pipeline would require the temporary clearing of vegetation within a 75-foot to 95-foot-wide construction 

right-of-way. During operation of the pipeline, a 30-foot-wide corridor centered on the pipeline would be 

kept in an herbaceous state, resulting in a permanent loss of forest. Across all ownerships, the 

construction of the pipeline would result in the clearing of 2,055 acres of forest and the permanent loss of 

528 acres of forest. The potential effects of this proposed action on vegetation and habitat are described in 

more detail in the Jordan Cove Energy and Pacific Connector Pipeline Project Final EIS, which is 

incorporated here by reference (FERC 2015, pp. 4-12 – 4-731).

No Federal lands would be utilized for the Jordan Cove liquefied natural gas terminal. Construction of the 

liquefied natural gas terminal and associated facilities would affect a total of approximately 397 acres, of 

which 178 acres are currently industrial land, 111 acres forest land, 76 acres open land (including shrubs 

and grasslands), and 32 acres of open water. Permanent operation of the facilities would affect 

approximately 251 acres, of which 68 acres are open land, 76 acres industrial, 76 acres forest, and 32 

acres open water. The potential effects of the construction and operation of the Jordan Cove liquefied 

natural gas terminal are described in more detail in the Jordan Cove Energy and Pacific Connector 

Pipeline Project Final EIS, which is incorporated here by reference (FERC 2015, pp. 4-2 – 4-11).

The Draft RMP/EIS for this RMP revision identified the Jordan Cove Energy and Pacific Connector 

Pipeline Project as a reasonably foreseeable future action, in that there was a formal proposal for the 

project at that time. The Draft RMP/EIS addressed the cumulative effects of the Jordan Cove Energy and 

Pacific Connector Pipeline Project together with the effects of the alternatives in those specific resource 

sections for which analysis at the scale of the Draft RMP/EIS would provide meaningful information. 
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However, the BLM did not explicitly incorporate potential future effects of the project, such as removal 

of vegetation and habitat along the proposed pipeline route, into the modeling for the Draft RMP/EIS

analysis, because the modeling would not be able to detect or parse out any cumulative or synergistic 

effect due to the small acreage and localized effects of the proposed pipeline project. The vegetation 

clearing for the proposed pipeline would affect less than 0.1 percent of the BLM-administered lands in the 

planning area, which represents an exceedingly small portion of the decision area as a whole. 

Furthermore, the area that the pipeline would affect would be spread out across the Klamath Falls Field 

Office, Medford, Roseburg, and Coos Bay Districts, further attenuating the potential effects on vegetation 

and habitat that could be detected at this scale of analysis. Finally, the vegetation clearing for the 

proposed pipeline would occur as a narrow feature on the landscape, cutting across forest stands, rather 

than removing forest stands. Such a small overall acreage, spread out over multiple administrative units, 

as a narrow feature on the landscape would not reflect any meaningful differences in the vegetation 

modeling at the scale of analysis for the Draft RMP/EIS and would not have the potential to alter any of 

the analytical conclusions related to vegetation and habitat in the Draft RMP/EIS analysis. If constructed 

as described in the proposed action, the Jordan Cove Energy and Pacific Connector Pipeline Project 

would disturb and remove too little acreage of vegetation and habitat and therefore would not generate 

any relevant information that could be meaningfully included in the vegetation and habitat modeling of 

approximately 2.5 million acres on BLM-administered lands in the Draft RMP/EIS.

The FERC-prepared Final EIS has addressed the cumulative effects of the proposed Jordan Cove Energy 

and Pacific Connector Pipeline Project. The Draft RMP/EIS identified that the BLM would address the 

cumulative effects of BLM implementation actions under this RMP in future project-level NEPA analysis 

where the effects of the Jordan Cove Energy and Pacific Connector Pipeline Project would be within the 

geographic and temporal scope of the effects of those implementation action(s), as appropriate (see 

generally USDI BLM 2008, pp. 57–61). The Draft RMP/EIS identified that the BLM would be better able 

to address the cumulative effects of the Jordan Cove Energy and Pacific Connector Pipeline Project 

together with BLM actions in project-level NEPA analysis than in the Draft RMP/EIS, given the small 

acreage and localized effects of the Jordan Cove Energy and Pacific Connector Pipeline Project in the 

context of this RMP revision and the analyses in the Draft RMP/EIS.

At this time, the Jordan Cove Energy and Pacific Connector Pipeline Project is no longer a reasonably 

foreseeable future action, because the FERC denied the certificate for construction of the Jordan Cove 

Energy and Pacific Connector Pipeline Project on March 11, 2016 (Jordan Cove Energy Project, L.P. and 

Pacific Connector Gas Pipeline, L.P., 154 FERC ¶ 61,190 (2016)).

Irreversible and Irretrievable Commitment of Resources

The Council on Environmental Quality’s regulations for implementing NEPA require that an EIS 

discussion of environmental consequences include “any adverse environmental effects which cannot be 

avoided should the proposal be implemented, the relationship between short-term uses of man’s 

environment and the maintenance and enhancement of long-term productivity, and any irreversible or 

irretrievable commitments of resources which would be involved in the proposal should it be 

implemented” (40 CFR 1502.16). Irreversible or irretrievable commitments of resources are those that 

cannot be reversed or that are lost for a long period. Examples include the extraction of minerals or the 

commitment of land to permanent roads. Although not specifically labeled, adverse environmental 

effects, the relationship between short-term uses and long-term productivity, and the irreversible and 

irretrievable commitment of resources are described, by resource, throughout the discussion of 

environmental consequences in this chapter.
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Spatial and Temporal Scales of Analysis

The spatial and temporal scale of analysis varies by resource and by issue. Consistent with the BLM 

NEPA Handbook, the spatial and temporal scale of analysis should be bounded by the extent and duration 

of the direct and indirect effects of the proposed action (USDI BLM 2008, p. 58).

For some issues in this Proposed RMP/Final EIS, the spatial scale is broader than the planning area. For 

other issues, the spatial scale is highly limited because of the nature of the resource and the potential 

effects of the proposed action on the resource. The individual resource sections of this chapter and 

accompanying appendices include descriptions of the spatial scales of analysis that are specific to that 

resource or program.

Specifying the temporal scale of analysis for an RMP/EIS is more challenging than for a discrete, sitespecific action. Analysis of the effects of an RMP includes projecting future implementation actions. 

Because it is not possible to forecast the duration of the RMP itself, it is not possible to determine the 

duration of the effects of implementing the RMP. Instead, most analyses in this Proposed RMP/Final EIS 

set the temporal scale of analysis based on a time frame that illuminates differences in the outcomes under 

the alternatives and the Proposed RMP. For most analyses, this temporal scope extends beyond any 

reasonable anticipation of RMP implementation, because analysis of effects of different land management 

on many resources must be extended for many decades to show any discernable differences. Limiting the 

temporal scope of analysis to the anticipated duration of the RMP, such as one or two decades, would 

obscure differences in effects among the alternatives and the Proposed RMP and thus fail to provide a 

clear basis for choice among alternatives. The individual resource sections of this chapter and 

accompanying appendices include descriptions of the temporal scales of analysis that are specific to that 

resource or program.

The temporal scope for the determination of the annual productive capacity for sustained-yield timber 

production for each alternative and the Proposed RMP is somewhat different that for the other analyses, 

in light of the BLM’s mandate for sustained-yield timber production under the O&C Act, as discussed in 

Chapter 1. The determination of the annual productive capacity for each alternative and the Proposed 

RMP extends for 200 years, far beyond any reasonable anticipation of RMP implementation. The 

temporal scope for this determination extends beyond the other analyses to ensure that the BLM could 

produce the determined annual productive capacity of timber without any decline, even in future decades.

Data Used in this Analysis

The analyses in this Proposed RMP/Final EIS use multiple data sources. Acreage totals for the planning 

area and the decision area vary based on how the BLM assembles the data to address the specific issue in 

question. The precise acreage of the planning area depends on what area the BLM includes within the 

geographic boundary of this planning effort, such as offshore areas within the official BLM district 

boundaries or areas within the geographic boundaries of separate BLM RMPs, ranging from 22,096,899 

acres to 22,928,632 acres. In addition, the differing data sources for BLM-administered lands and other 

lands complicate combining acreage totals across ownerships. Similarly, the precise acreage of the 

decision area depends on the data source for defining BLM-administered lands within the planning area, 

ranging from 2,478,856 acres to 2,493,655 acres. Because of these varying acreages from various data

sources, the acreage totals are not precisely the same in all resource sections of this analysis. The 

individual resource sections of this chapter and accompanying appendices include descriptions of the data 

sources that are specific to that resource or program.

The data that the BLM used in this analysis is at a far finer resolution than was available for the 

Northwest Forest Plan and the 1995 RMPs. The data for most of the analyses in this Proposed RMP/Final 
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EIS (such as the vegetation modeling described below) is at a resolution of units of 100 square meters in 

size, which is more than 1,600 times finer in resolution than the data available for the Northwest Forest 

Plan. As a result, this analysis can more precisely map resource conditions and accurately include finescale features, such as streams and roads, which the BLM could not previously consider. The data 

summaries in the analyses in the Proposed RMP/Final EIS do not always reflect the precision of the 

underlying data. In many of the analyses, the BLM rounded acreage numbers to ensure that the precision 

of analytical results does not exceed the accuracy associated with the analytical assumptions. The BLM 

only requires sufficient precision of the analytical results to illustrate the comparative effects caused by 

the alternatives to support reasoned decision-making.

Analytical Assumptions about RMP Implementation

For the purpose of this analysis, the BLM assumed full and immediate implementation of each of the 

alternatives and the Proposed RMP. That is, the BLM has modeled and analyzed implementation of 

actions at the level directed by each alternative based on vegetation data from January 2013,30 as 

discussed further in the following section. 

The necessary organization transition from the current implementation of the 1995 RMPs to the Proposed 

RMP may take time before the BLM will be able to implement the Proposed RMP fully. None of the 

changes from the 1995 RMPs to the Proposed RMP are sufficiently large to require a lengthy transition 

period, such as the five-year transition suggested in the Draft RMP/EIS. However, the BLM will need 

time to restructure resources, budget, and staff, making full implementation of the Proposed RMP 

unlikely for some programs in some districts during the first few years of RMP implementation. Specific 

sections of this chapter address where the BLM would require extended periods of time for full 

implementation of the Proposed RMP or alternatives.

For the purpose of this analysis, the BLM assumed adequate funding and staffing to implement the 

Proposed RMP and alternatives as described.

Vegetation Modeling

The BLM used the Woodstock model as part of the Remsoft Spatial Planning System 2012.12.0 to 

simulate the management and development of the forested BLM-administered lands over time. The 

alternatives and the Proposed RMP outline a range of approaches for managing BLM-administered lands 

by varying the land allocations and intensity with which the BLM manages these forests. These different 

approaches would result in a range of outcomes, habitat characteristics, and timber harvest levels. The 

Woodstock model simulated the application of management practices and forest development 

assumptions to characterize the forest in 10-year increments into the future. The Planning Criteria 

includes a description of the vegetation modeling in detail, including an explanation of why the BLM 

chose the Woodstock model over other types of models to conduct this analysis, and that discussion is 

incorporated here by reference (USDI BLM 2014, pp. 28–33). In addition, Appendix C provides detailed 

and technical information on the vegetation modeling.

The BLM mapped lands that would be allocated for sustained-yield timber production and lands that 

would be allocated to reserve land use allocations under each alternative and the Proposed RMP. For each 

land use allocation, the BLM described treatments to reflect the management direction for each 

 

30 The vegetation modeling analyzed implementation of alternatives from January 2013, which provided the most 

current comprehensive vegetation data available for modeling the effects of the alternatives considered in the Draft 

RMP/EIS. Use of this data facilitated the decade-scale vegetation modeling and provided an approximation of the 

effects of implementation actions between January 2013 and the eventual adoption of the RMP.
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alternative and the Proposed RMP. Within the Woodstock model, these treatments define the forest 

management activities that could occur for an individual stand. The BLM used the ORGANON growth 

model, version 9.1 (http://www.cof.orst.edu/cof/fr/research/organon/) to simulate the growth of stands 

through time.

The Woodstock model used starting conditions of the forest vegetation, treating January 2013 as analysis 

year zero.31 The BLM used information on forest conditions in the Woodstock model from three sources. 

The first is the Forest Operations Inventory, which contains information on forest stand condition for 

approximately 69,600 stands. The second source of vegetation information is the Current Vegetation 

Survey, which is a systematic, permanent plot grid inventory that has installed one plot every 1.7 miles on 

forested BLM-administered lands. The third source is the BLM geographic information system, which 

contains information describing aspects of the environment that affect where timber harvest could take 

place. These include the productive capacity of the land, as well as Bureau Special Status plant species 

locations.

For the Draft RMP/EIS, the BLM used data frozen in 2012 to establish a baseline of forest conditions 

used to describe the affected environment and from which to model forest development and harvest levels 

for the No Action alternative and the action alternatives. After the preparation of the Draft RMP/EIS, the 

BLM recognized that wildfire activity in the decision area in 2013 and 2014 produced measurable 

changes to these baseline forest age and structural conditions. For the Proposed RMP/Final EIS, the BLM 

updated baseline forest age and structural conditions resulting from 2013/2014 wildfires, which has 

resulted in changes to affected environment descriptions throughout this document, when compared to the 

Draft RMP/EIS. The BLM used the updated baseline forest conditions to feed into the Woodstock model 

to account for potential changes in environmental effects, and to refine timber harvest estimates for the 

Proposed RMP. The BLM did not re-run vegetation modeling or analysis completed for the No Action 

alternative or the action alternatives due to the relatively minor nature of the changes. Therefore, there 

may be minor discrepancies in acreage values when comparing first decade data from the Proposed RMP 

to the No Action alternative or the action alternatives.

The BLM incorporated into the Woodstock model a scenario for future wildfires in the planning area. 

Appendix D provides a detailed and technical description of the development of the wildfire scenario. To 

model the locations of these future wildfires, the BLM used the wildfire suitability model developed as 

part of the 15-year monitoring report for the Northwest Forest Plan (Davis et al. 2011). This model was 

based on the occurrence of large wildfires from 1970–2002, and represents a probability surface for large 

wildfire occurrence within the northern spotted owl range.

The BLM modelled this future wildfire scenario consistently for all alternatives and the Proposed RMP. It 

is possible that management actions such as timber harvest and fuels treatments would alter the likelihood 

or severity of future wildfires and those management actions would vary by alternative and the Proposed 

RMP. Nevertheless, it is not possible to model different future wildfire scenarios under different 

alternatives and the Proposed RMP, given the following:

 

31 The vegetation modeling does not account timber harvest that has occurred between January 2013 and the 

preparation of this Proposed RMP/Final EIS. The vegetation modeling generally overestimated timber harvest 

during that period, because the vegetation modeling projected implementation of the alternatives starting in January 

2013. For most alternatives, the modeled implementation of the alternatives would have resulted in slightly more 

timber harvest than the BLM actually implemented during that period. During that period, the BLM has sold and 

awarded timber sales on approximately 34,000 acres. These timber sales have been predominately thinning. Of the 

34,000 acres sold, approximately 29,000 acres were thinning/partial harvest, while 5,000 acres were regeneration 

harvest, road clearing, and salvage harvest. The difference between the timber harvest that the BLM has 

implemented and the timber harvest modeled for each alternative during that period is too small to alter the basic 

analytical results of the vegetation modeling.
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 The inherent challenges in predicting the location and timing of future stochastic events

 The inability at this scale of analysis to forecast the site-specific location and conditions of future 

management actions

 The uncertainty around the site-specific effects of individual management actions on the 

likelihood of wildfire occurrence and severity

Although it is possible that the alternatives and the Proposed RMP would differentially affect how future 

wildfires would occur, such differences are not reasonably foreseeable at this scale of analysis. Therefore, 

it would be speculative to forecast different future wildfire scenarios under different alternatives and the 

Proposed RMP. Appendix D provides more detailed discussion of the role of forest management actions 

in modeling the future wildfire scenario.

The BLM also modelled this future wildfire scenario based on past wildfire occurrence and did not 

incorporate projections of the effects of climate change on future wildfire occurrence and severity. As 

discussed later in this chapter, there is evidence that the fire season is becoming longer, potential fire 

severity is increasing in the planning area, and that climate change may be contributing to these trends. 

However, the inherent challenges in predicting future stochastic events coupled with the uncertainties in 

climate change predictions make it impossible to forecast specifically when and where future wildfires 

would occur differently than they have occurred in the recent past. Appendix D provides more detailed 

discussion of the role of climate change predictions in modeling the future wildfire scenario.

The BLM did not incorporate projections of future windstorms, disease outbreaks, or insect infestations 

into the simulation of the growth of stands through time within the Woodstock model. These disturbances 

will occur in the future under all alternatives and the Proposed RMP, but predicting their location, timing, 

severity, and extent would be speculative. Unlike the wildfire suitability model reference above, there are 

no available theoretical approaches for estimating the location, timing, or severity of future windstorms, 

disease outbreaks, or insect infestations at the scale of the planning area over the time frame of this 

analysis.

The BLM did not incorporate projections of climate change into the simulation of the growth of stands 

through time within the Woodstock model. That is, the BLM modelled the management and development 

of the forested BLM-administered lands over time assuming that forest stands will continue to grow and 

respond to treatments in the future the same as they do now. There are substantial uncertainties in 

predicting how and when climate conditions will change at the regional scale, as discussed in detail later 

in this chapter. In addition to the uncertainty in climate change predictions, the available climate 

predictions cannot be downscaled to a meaningful level for use in forest stand growth and harvesting 

models. To translate these broad regional predictions with substantial uncertainties to projections of how 

and when specific groups of forest stands would change in their patterns of growth and response to 

treatment over the next several decades would be so speculative as to be arbitrary. Separate from the 

vegetation modeling with Woodstock, the BLM did review bioclimatic envelope model projections and 

evaluate the potential effects and associated uncertainty of projected climate changes on a variety of 

forest management outcomes for the planning area conducted using the Climate extension of the Forest 

Vegetation Simulator model. The Climate Change section in this chapter includes detailed discussions of 

these specific analytical efforts.

The BLM used the Woodstock model to simulate forest development within the decision area. On other

land ownerships within the planning area, the BLM used an estimation of future forest conditions by 

applying assumptions to the 2006 version of the gradient nearest neighbor (GNN) imputation and Landsat 

time-series data (Ohmann et al. 2012). The BLM estimated future forest conditions on other land 

ownerships assuming that other landowners would continue to implement their present management.
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The BLM did not use the Woodstock model to model vegetation change on the Eastside Management 

Area land use allocation (i.e., BLM-administered lands in the Klamath Falls Field Office east of Highway 

97), because most of these lands are not in a forested condition. These lands do not include any O&C 

lands and are outside of the range of the northern spotted owl.

Vegetation Modeling Products

For each alternative and the Proposed RMP, the Woodstock model projected development of the forest 

for many decades into the future. The model tracked the types of forest management treatments over time 

(short- and long-term), both numerically and spatially. The modeling utilized both numeric and spatially 

explicit displays of development of the forest over time.

Within the modeling, the BLM described all land in the decision area as non-forest, woodland, or 

forested. The non-forested land includes sagebrush, grassland, water and other areas that are not expected 

to have forests within the time of the analysis. The woodland includes juniper and Oregon white oak plant 

associations, and other areas that have trees, but the BLM does not expect them to maintain a closed 

forest canopy.

Forest conditions at the scale of the planning area are discussed in terms of the structural stages of forests. 

Various interdisciplinary team members in their analysis used this common definition. The structural 

stage definitions rely heavily on the structural stage definitions that the BLM developed in the 2008 EIS, 

with one addition. The 2008 analysis divided the forest structure into four classifications (Stand 

Establishment, Young, Mature, and Structurally-complex). The forest structure definitions used in this 

analysis include all of the 2008 definitions, as well as the new category of Early Successional (see the 

Forest Structural Stage Classification section of Appendix C).

The BLM defined each of the structural stages for ‘moist’ and ‘dry’ forests. The BLM developed a map 

that labels all lands in the decision area as either moist or dry. The final groupings have incorporated 

recommendations from BLM staff, and are similar to, but do not always correspond exactly to mapped 

plant series, or plant association groupings. In general, the moist forest includes western hemlock, Sitka 

spruce, Pacific silver fir, Shasta red fir, and tanoak plant associations. The dry forest includes Douglas-fir, 

Jeffery pine, grand fir, white fir, and ponderosa pine plant associations.

The structural stage definition further differentiates Early Successional, Stand Establishment, and Young 

structural stages by the presence or absence of structural legacies. For the purpose of this definition, a 

structural legacy is a tree that is ≥ 20” DBH and is larger and older than other trees in the stand. In 

addition to Appendix C, the 2008 EIS provides detailed information on the Stand Establishment, Young, 

Mature, and Structurally-complex structural stages and is incorporated here by reference (USDI BLM 

2008, pp. 206–211 and Appendix B, pp. 12–15). 

The BLM defined the Early Successional category to describe forested land that has low canopy cover 

and younger, shorter trees than the Stand Establishment stage. The Early Successional structural stage has 

trees that are less than 50 feet tall and less than 30 percent canopy cover. Some combination of shrubs, 

grasses, and forbs appear visually dominant and are ecologically dominant at the beginning of this stage. 

The Stand Establishment structural stage has similar characteristics but has greater than 30 percent 

canopy cover, such that trees are both visually and ecologically dominant.

The following outline shows the different structural stages that the BLM used in this analysis:

 Non-forest

 Woodland

 Forest
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o Early Successional

 With Structural Legacies

 Without Structural Legacies

o Stand Establishment

 With Structural Legacies

 Without Structural Legacies

o Young High Density

 With Structural Legacies

 Without Structural Legacies

o Young Low Density

 With Structural Legacies

 Without Structural Legacies

o Mature

 Single Canopy

 Multiple Canopy

o Structurally-complex

 Existing Old Forest

 Existing Very Old Forest

 Developed Structurally-complex

The BLM used the modeling output from this five-tiered structural stage definition to help assess changes 

in the forested landscape over time, including evaluating habitat conditions for most wildlife species other 

than the northern spotted owl.

The modeling also provided species-specific outputs on habitat conditions for the northern spotted owl.

The BLM used these outputs in species-specific modeling as inputs for other models to analyze the effects 

of the alternatives and the Proposed RMP on northern spotted owl habitat and populations, as discussed in 

detail later in this chapter.

The modeling also provided outputs related to timber production, including calculation of the annual 

productive capacity for sustained-yield timber production (the Allowable Sale Quantity (ASQ)) under 

each alternative and the Proposed RMP (ASQ harvest). The BLM calculated the annual productive 

capacity for each of the six sustained yield units, which match the five western Oregon BLM district 

boundaries and the western portion of the Klamath Falls Field Office in the Lakeview District. The BLM 

constrained the calculation of the annual productive capacity to the volume of timber that could be 

produced continuously for 200 years with the management practices described in the alternatives and the 

Proposed RMP from those lands allocated to the Harvest Land Base. Both the management practices and 

the lands allocated to the Harvest Land Base would vary among the alternatives and the Proposed RMP, 

and, consequently, the calculated annual productive capacity varies as well.

The modeling also provided outputs related to timber production from the reserve land use allocations 

under each alternative and the Proposed RMP (non-ASQ harvest). Both the management direction for 

reserve land use allocations and the lands allocated to the reserve land use allocations would vary among 

the alternatives and the Proposed RMP, and, consequently, the calculated timber production from the 

reserve land use allocations varies as well. Unlike the ASQ, this timber production would also vary over 

time for each alternative, because timber harvest would occur as a by-product of forest management 

treatments for purposes other than sustained-yield timber production.

The BLM used these modeling outputs related to timber production as inputs for other models to analyze 

the effects of the alternatives and the Proposed RMP on socioeconomic conditions, including employment
129 | P a g e

and earnings, payments to the counties, and implementation costs to the BLM, as discussed in detail later 

in this chapter.

Analysis of Sub-alternatives

As explained in Chapter 2, sub-alternatives are variations of an action alternative that modify an 

individual component of the alternative to explore how the changes would alter certain outcomes. In the 

Draft RMP/EIS, the BLM developed Sub-alternatives B and C, which are sub-alternatives of Alternative 

B and Alternative C, respectively. Both of these sub-alternatives vary the design of the Late-Successional 

Reserve to explore how the changes would modify outcomes for forest management and northern spotted 

owls. Because these sub-alternatives vary only this component of the alternatives and all other 

components of the alternative remain unchanged, the analysis of the sub-alternatives in the Draft 

RMP/EIS only included the effects on forest management and northern spotted owls.

Reference Analysis

A reference analysis of No Timber Harvest is included in this Proposed RMP/Final EIS. The BLM 

includes this reference analysis to provide additional information for interpreting the effects of one or 

more of the alternatives. The No Timber Harvest reference analysis is not a reasonable alternative, 

because it would not meet the purpose and need for action. However, this reference analysis provides 

information about the biological capabilities of the decision area in the absence of timber harvest and 

affords a point of comparison in the effects analysis of the alternatives and the Proposed RMP. The 

discussion of the reference analysis is not comprehensive, as it is not a reasonable alternative. Instead, the 

BLM described outcomes under the No Timber Harvest reference analysis only for those issues for which 

it is useful in interpreting the effects of one or more of the alternatives and the Proposed RMP.

References

Davis, R. J., K. M. Dugger, S. Mohoric, L. Evers, and W. C. Aney. 2011. Status and trends of northern spotted owl populations 

and habitats. General Technical Report PNW-GTR-850. USDA Forest Service, Pacific Northwest Research Station, 

Portland, OR. 147 pp. http://www.fs.fed.us/pnw/pubs/pnw_gtr850.pdf.

FEMAT. 1993. Forest ecosystem management: an ecological, economic, and social assessment. Report of the Forest Ecosystem 

Management Assessment Team (FEMAT). 1993-793-071. Washington, DC: GPO.

Federal Energy Regulatory Commission (FERC). 2014. Draft Environmental Impact Statement for the Jordan Cove Liquefaction 

and Pacific Connector Pipeline Projects. Vol. I–II. November 7, 2014. Washington, D. C. 

http://www.ferc.gov/industries/gas/enviro/eis/2014/11-07-14-eis.asp.

---. 2015. Final Environmental Impact Statement for the Jordan Cove Liquefaction and Pacific Connector Pipeline Projects.

September 30, 2015. Washington, D.C. http://www.ferc.gov/industries/gas/enviro/eis/2015/09-30-15-eis.asp.

---. 2016. Order denying applications for certificate and Section 3 authorization. March 11, 2016. Washington, D.C. 25 pp. 

http://www.ferc.gov/CalendarFiles/20160311154932-CP13-483-000.pdf.

Ohmann, J. L., and M. J. Gregory. 2002. Predictive mapping of forest composition and structure with direct gradient analysis and 

nearest-neighbor imputation in coastal Oregon, U.S.A. Canadian Journal of Forest Research 32(4): 725–741. 

http://dx.doi.org/10.1139/X02-011.

USDI BLM. 2008. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western 

Oregon Bureau of Land Management Districts. Oregon State Office. Portland, OR. Vol. I–IV.

---. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, Oregon/Washington 

State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.
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Areas of Critical Environmental Concern

Key Points

 The No Action alternative would provide special management attention or interim special 

management attention to all 140 existing and potential Areas of Critical Environmental Concern.

 The action alternatives and the Proposed RMP consider the designation of 131 potential 

(designated, previously nominated, and 14 newly nominated) Areas of Critical Environmental 

Concern, totaling up to 104,824 acres or about 4 percent of the planning area.

 The Proposed RMP would include the designation of the largest number (108) and Alternative C 

the least (101) Areas of Critical Environmental Concern.

 All action alternatives and the Proposed RMP would maintain 92–99 percent of the relevant and 

important values within the potential Areas of Critical Environmental Concern.

 Across the planning area, the potential Areas of Critical Environmental Concern represent a high 

level of diversity in both the values protected and the number and categories of values within any 

one Area of Critical Environmental Concern.

Summary of Notable Changes from the Draft RMP/EIS

The BLM has updated acres to account for refined boundaries of Areas of Critical Environmental 

Concern (ACECs). The BLM conducted boundary refinements to prevent resource management conflicts, 

and correct where previous boundaries did not accurately capture the landscapes with relevant and 

important values. The BLM also updated considerations for designation under the alternatives and the 

Proposed RMP based on management provided for, or directed by, underlying land use allocations and 

special management areas, considerations of management in favor of other priorities, or because 

management of the ACEC would not be consistent with other land management activities.

Issue 1

How would the alternatives affect the relevant and important resource values of existing and proposed 

Areas of Critical Environmental Concern?

Summary of Analytical Methods

The BLM defined special management needed to protect or maintain the relevant and important values of 

each potential ACEC. The BLM then determined if the management direction for other resources under 

each alternative and the Proposed RMP protects or maintains the relevant and important resource values 

associated with each potential ACEC. The BLM also considered whether the application of special 

management needed to protect relevant and important values would not preclude sustained-yield timber 

harvest in the Harvest Land Base. The presence or amount of O&C Harvest Land Base within the 

potential ACECs varies by alternative and the Proposed RMP. The BLM would not designate ACECs 

under alternatives or the Proposed RMP where the needed special management would preclude O&C 

Harvest Land Base sustained-yield production.

Appendix F lists all potential ACECs within the decision area. For every alternative and the Proposed 

RMP, the BLM assigned each potential ACEC to one of following categories:

 Yes, the BLM would designate the entire potential ACEC. The area requires special management 

to maintain relevant and important values and management would not preclude O&C sustained-
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yield timber harvest at the stand level in the Harvest Land Base, recreation management in 

Special Recreation Management Areas, or meeting the management objectives of underlying 

lands with special designations.32 Special management may condition, but not preclude, O&C 

sustained-yield timber production and recreation management.

 Yes_a, the BLM would designate a portion of the potential ACEC. The BLM removed portions 

of the potential ACEC where special management would conflict with O&C sustained-yield 

timber harvest or recreation management in Special Recreation Management Areas. The BLM 

determined that the remaining area still supports relevant and important values needing special 

management.

 No, the BLM would not designate the potential ACEC because the area does not require special 

management to maintain the relevant and important values. Other land designations or land use 

allocations provide management necessary to retain the relevant and important values.

 No1, the BLM would not designate the potential ACEC because of conflicts with other 

management priorities.

 No_a, BLM would not designate the potential ACEC because the special management required to 

maintain the relevant and important values would preclude O&C sustained-yield timber harvest in 

the Harvest Land Base.

The BLM assumed that the relevant and important values associated with an ACEC designated under any 

particular alternative or the Proposed RMP would be adequately protected by the special management 

direction.

The Planning Criteria provides detailed information on authorities, guidance for ACEC designation on 

O&C lands, analytical assumptions, methods and techniques, which the BLM incorporates here by 

reference (USDI BLM 2014, pp. 35–36).

Background

Areas of Critical Environmental Concern (ACECs), defined in the Federal Land Policy and Management 

Act (FLPMA), represent areas within the public lands where special management attention is required to 

protect or to prevent irreparable damage to any of the following categories:

 Important historic, cultural, or scenic values

 Fish and wildlife resources

 Other natural processes or systems

 Safety from natural hazards

The BLM develops special management direction to protect relevant and important values, but does not 

apply special management when other management mechanisms adequately protect the relevant and 

important values or where designation is not warranted.

The BLM designs some special management attention to move the relevant and important value onto a 

trajectory to reach a desired condition. The BLM designs other special management attention to protect 

the relevant and important values from management actions or other human activities. This may include 

prohibiting or modifying certain management activities.

 

32 Lands with special designations include Wild and Scenic Rivers, National Trails, District Designated Reserve –

Lands Managed for their Wilderness Characteristics, Wilderness Areas, and Wilderness Study Areas.
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ACEC Characteristics

An area must meet relevance and importance criteria, and require special management attention to qualify 

for consideration for designation as an ACEC. An area meets the relevance criterion if it contains any of 

the categories of values listed above.

The value, resource, process or system, or hazard described above must have substantial significance to 

satisfy the importance criteria. This generally means that any of the following characterize the value, 

resource, process or system, or hazard:

 It has qualities that give it special worth, consequence, meaning, distinctiveness, or cause for 

concern, especially compared to any similar resource, are more than locally significant.

 It has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, 

unique, endangered, threatened, or vulnerable to adverse change.

 It has been recognized as warranting protection to satisfy national priority concerns or to carry 

out the mandates of the FLPMA.

 It has qualities that warrant highlighting to satisfy public or management concerns about safety or 

public welfare.

 It poses a significant threat to human life or property.

The BLM describes relevant and important values in four categories as shown in Table 3-2. These 

categories are:

 Historic, cultural, or scenic values include, but are not limited to, rare or sensitive archeological 

resources and religious or cultural resources that are important to Native Americans.

 Fish and wildlife resources include, but are not limited to, habitat needed for ESA-listed and 

Bureau Sensitive species, or habitat essential for maintaining species diversity.

 Natural processes or systems include, but are not limited to, endangered, sensitive, or threatened 

plant species; rare, endemic, or relic plants or plant communities that are terrestrial, aquatic, or 

riparian; or rare geological features.

 Natural hazards include, but are not limited to, areas of avalanche, areas with potential for high 

flooding, landslide-prone areas, and areas with unstable soils, seismic activity, or dangerous 

cliffs. The BLM may consider human caused hazards a natural hazard if the BLM determines 

through the resource management planning process that it has become part of a natural process.

Table 3-2. Value categories for designated and previously nominated potential ACECs

District/

Field Office

Historic, Cultural, 

or Scenic Fish and Wildlife Natural Processor System Natural Hazard

Coos Bay 2 14 17 -

Eugene 2 12 20 1

Klamath Falls 3 3 4 -

Medford 5 7 31 -

Roseburg 1 3 11 -

Salem 9 22 36 1

Totals 22 61 120 2

Although it is only necessary for an area to meet the relevance and importance criteria for one value to 

qualify as an ACEC, many potential ACECs meet the criteria for several values. However, the number of 

values that meet the relevance and importance criteria can vary widely, as can the combination of values 

that meet these criteria within an ACEC. For example, the Sterling Mine Ditch potential ACEC contains a 

historical gold mining ditch, where the Table Rocks ACEC contains a combination of unique geologic 
134 | P a g e

features, vernal pools, Bureau Special Status plants, ESA-listed fairy shrimp, a developed interpretive 

educational area, and scenic and cultural values.

Research Natural Areas (RNAs) represent a specific type of ACEC. These areas are established and 

maintained for the primary purpose of research and education because the area has one or more of the 

following characteristics:

 Typical representation of a common plant or animal association

 Unusual plant or animal association

 ESA-listed plant or animal species

 Typical representation of common geologic, soil, or water feature

 Outstanding or unusual geologic, soil, or water feature

The Research Natural Area network in the Pacific Northwest represents a wide range of elevation, 

geology, topography, soils, and vegetation communities throughout the region. The BLM manages these 

in partnership with the U.S. Forest Service, state natural resource agencies, and key private organizations. 

This network allows for evaluation of differential responses to environmental change in comparison to 

forests managed for sustained yield.

Outstanding Natural Areas (ONAs) are also specific types of ACECs. Outstanding Natural Area 

designations aim to protect unique scenic, scientific, educational, and recreational values of certain areas 

within the public lands. It is important to note that, when applied by Congress, the term ‘outstanding 

natural area’ has a different meaning than when the BLM applies it through a planning decision to create 

a type of ACEC. A congressionally designated ‘outstanding natural area’ provides permanent protection 

for the values for which Congress designated the area.

ACEC Designation and Analysis

The BLM only designates ACECs through the land use planning process. During planning, the BLM must 

identify and fully consider for designation and management all designated and nominated areas meeting 

the relevance and importance criteria. The BLM reviews ACEC nominations for identification of relevant 

and important values upon receipt. When reviews find areas to meet relevance and importance criteria, 

the BLM identifies them as ‘potential ACECs’ and evaluates them to determine if they warrant special 

management attention. If so, the BLM provides interim protective management for the potential ACECs 

until the BLM can consider them for designation under a land use planning process.

In accordance with regulations, the BLM reconsidered areas within the planning area designated as 

ACECs in the 1995 RMPs and previously nominated potential ACECs. The previously nominated 

potential ACECs include nominated areas evaluated late in the development of the 1995 RMPs, 

nominations received after 1995, and nominations solicited during the 2008 planning effort. The BLM 

also solicited and received new ACEC nominations in 2012 for this planning process.

The BLM found that 81 of the 86 of the designated ACECs and 34 of the 38 previously nominated 

potential ACECs meet the relevance and importance criteria and are carried forward for further analysis. 

The reviews of these designated and previously nominated potential ACECs resulted in refinements to 

boundaries and determinations of which values met relevance and importance criteria. For example, this 

reconsideration resulted in a boundary expansion to an existing RNA, Beatty Creek, in the Roseburg 

District and removal of the ONA status from the following potential ACECs: McGowan Meadow, Table 

Rocks, and Valley of the Giants. In addition, the Salem District determined the Little Grass Mountain 

ONA no longer met the ACEC criteria. The BLM analyzed 4 of the 8 designated and potential ONAs and 

all 32 designated RNAs in this plan revision.
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The BLM evaluated 3433 new ACEC nominations; 16 meet criteria for relevance and importance. Where 

necessary, the BLM is providing special management attention to these 16 areas while analyzing them as 

part of this plan revision. Included in these 16 new potential ACECs is the West Fork Illinois River on the 

Medford District, which the BLM found to qualify for consideration as a new potential RNA.

In summary, under the action alternatives and the Proposed RMP, the BLM is considering for designation 

areas within:

 81 currently designated ACECs

 34 previously nominated potential ACECs that are currently under interim management

 16 newly nominated potential ACECs that are currently under interim management 

 32 designated and 1 new potential ACECs that are also RNAs34

 4 designated and 1 previously nominated potential ACECs that are also ONAs

In preparation for this plan revision, the districts evaluated designated ACECs, previously nominated 

potential ACECs, and newly nominated potential ACECs. During these evaluations, the districts 

combined areas into new potential ACECs when the areas had similar values and were over-lapping or in 

close proximity to one another. Many of the nominated potential ACECs are additions to designated 

ACECs. While the BLM found 16 of the new nominations to meet the relevance and importance criteria, 

7 were merged with designated or previously nominated potential ACECs, leaving 9 new potential 

ACECs.

Previously Designated and Previously Nominated Potential ACECs 

No Longer Meeting ACEC Criteria

The BLM determined that 10 existing and previously nominated potential ACECs no longer meet the 

ACEC designation criteria. The BLM made these determinations on the basis that the relevant and 

important values no longer exist within the ACEC boundary, or that the values would be protected 

without additional special management. The following areas no longer meet the ACEC criteria:

 Long Gulch in the Medford District

 China Ditch, Stouts Creek, North Umpqua River, and Umpqua River Wildlife Area in the Roseburg 

District

 Little Grass Mountain, North Santiam, Sheridan Peak, Wells Island, and Yampo in the Salem 

District 

The Medford District determined that special management associated with ACEC designation would not 

be required to protect or maintain the unique trellised drainage pattern at Long Gulch because Riparian 

Reserve management direction would provide all of the needed protection. 

The Roseburg District determined management consistent with the requirements of the Endangered 

Species Act would adequately protect the relevant and important values at China Ditch and Stouts Creek 

without additional special management. In addition, Congress designated the North Umpqua River as a 

Wild and Scenic River in 1992. This designation provides the special management needed for scenic and 

fisheries relevant and important values of the North Umpqua ACEC.

 

33 This total number includes two ACEC nominations received after the solicitation period for this planning process. 

Interdisciplinary staffs for the respective districts evaluated both ACECs at the time they were received. Neither 

were found to meet the relevance and importance criteria. As such, these were not forwarded for further 

consideration.

34 RNAs and ONAs are designations in addition to the ACEC designation. As such, the 33 RNAs and 5 ONAs listed 

here are a part of the total number of ACECs considered, not in addition to the numbers in the first 3 bullets.
136 | P a g e

The bald eagle was the single relevant and important value needing special management for the Umpqua 

River Wildlife Area ACEC. The bald eagle population has grown and the species has been delisted from 

the ESA, but continues to be protected under the BLM’s Special Status Species program and the Bald and 

Golden Eagle Protection Act. This bald eagle population no longer meets the relevance and importance 

criteria. 

The Salem District determined there were no relevant and important values present at the Little Grass 

Mountain, North Santiam, Sheridan Peak, and Yampo ACECs. The BLM found that the grassy bald at 

Little Grass Mountain does not contain any values to set it apart from other Coast Range grassy balds. 

The North Santiam area’s highly valued river meander channels and associated alluvial forest habitat are 

not on BLM-administered lands. The adjacent BLM-administered lands do not have these relevant and 

important values. A large population of former Bureau Special Status botanical species, Poa marcida

occupies Sheridan Peak, but it does not meet the relevance and importance criteria. Two Bureau Special 

Status botany species occurred at the Yampo ACEC. Tall bugbane (Cimicifuga elata) is no longer a 

Bureau Special Status Species, and the BLM has not observed thin-leaved peavine (Lathyrus holochlorus) 

on this small parcel since the 1980s. Therefore, relevant and important values no longer exist at Yampo.

The Salem District determined that while the Wells Island ACEC’s values continue to meet the relevance 

and importance criteria, their maintenance does not require special management associated with ACEC 

designation. Wells Island, in the Willamette River, has no road access, which protects the relevant and 

important values from threatening activities. Any special management that the district would prescribe for 

Wells Island would be the same as what is already in place with designation of those lands as Riparian 

Reserve.

Affected Environment

There are 86 ACECs currently designated in the decision area, 38 previously nominated ACECs 

(nominated areas evaluated late in the development of the 1995 RMPs, nominations received after 1995, 

and nominations solicited during the 2008 planning effort) that have been under interim protective 

management (Table 3-3), and 16 new potential ACECs nominated after the 2008 RMP planning effort 

(Table 3-4).35 Designated and previously nominated ACECs comprise 3.7 percent, and new potential 

ACECs comprise 0.7 percent of the decision area. The BLM currently protects the relevant and important 

values, whether identified in a plan decision or in a nomination, for areas in all of these categories.

 

35 The Medford District is currently preparing an RMP amendment and environmental assessment to change the 

boundary of the Table Rocks ACEC to include newly acquired federal lands and to encompass lands administered 

by The Nature Conservancy. If The Nature Conservancy parcels are acquired in the future by the BLM, The Nature 

Conservancy lands would become part of the ACEC (see the Existing Decisions section of Chapter 1). 
137 | P a g e

Table 3-3. Designated and previously nominated potential ACECs and corresponding RNA or ONA if 

applicable

District/

Field Office

Designated 

ACECs

(Number)

Potential 

ACECs

(Number)

RNAs*

(Number)

ONAs

(Number)

Designated 

and 

Potential 

ACECs

(Acres)

BLMadministered 

Lands

(Acres)

Potential ACEC 

Percentage of 

District/Field 

Office or Total 

BLM Acres 

Coos Bay 11 5 1 - 14,258 325,824 4.4%

Eugene 13 9 5 1 14,841 313,705 4.7%

Klamath 

Falls 3 3 1 - 7,385 215,077 3.4%

Medford 24 7 10 1 21,125 810,261 2.6%

Roseburg 9 3 7 - 10,504 425,805 2.5%

Salem 26 11 8 6 24,713 402,983 6.1%

Totals 86 38 32 8 92,826 2,493,655 3.7%

* The RNAs and ONAs are also designated as ACECs, and their numbers are already counted within the designated and potential 

numbers.

Table 3-4. New potential ACECs and corresponding RNA or ONA if applicable

District/

Field Office

New 

Potential 

ACECs 

(Number)

RNAs

(Number)

ONAs

(Number)

New 

Potential 

ACECs 

(Acres)

BLMadministered 

Lands

(Acres)

Percentage of 

District/Field 

Office or Total 

BLM Acres in 

New Potential 

ACECs

Coos Bay 1 - - 45 325,824 < 0.01%

Eugene 7 - - 10,788 313,705 3.4%

Klamath Falls 2 - - 319 215,077 0.14%

Medford 4 1 - 5,177 810,261 0.06%

Roseburg 1 - - 368 425,805 < 0.01%

Salem 1 - - 805 402,983 0.20%

Totals 16 1 - 17,502 2,493,655 0.7%

The BLM restructured all of the areas considered (designated, and previously and newly nominated 

potential ACECs) in the planning process into a new set of 121 potential ACECs totaling 97,053 acres as 

shown in Appendix F (Table F-1). Table 3-5 displays the number of potential ACECs evaluated under 

this analysis with relevant and important values by district.
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Table 3-5. Value categories for potential ACECs evaluated in this analysis

District/

Field Office

Historic, Cultural, 

or Scenic Fish and Wildlife Natural Processor System Natural Hazard

Coos Bay 6 11 17 -

Eugene 1 8 24 1

Klamath Falls 3 5 6 -

Medford 7 7 31 -

Roseburg 1 2 9 1

Salem 12 16 27 1

Totals* 30 49 114 3

* Many ACECs contain more than one qualifying relevant and important value and therefore the sum of the totals exceeds 121.

Environmental Consequences

This analysis examines the designation of ACECs and the effects on relevant and important values.

Under the alternatives and the Proposed RMP, the varying designations of ACECs would have differing 

effects on the relevant and important values that the designations protect. Appendix F provides the names 

of the ACECs that the BLM would designate under the various alternatives and the Proposed RMP by 

district, the associated acres, and the relevant and important values (Table 3-5 and Table F-1). This 

analysis provides a broad discussion of the various resources that the BLM would protect through ACEC 

designations.

The BLM’s removal of areas from the potential ACECs to avoid precluding O&C Harvest Land Base 

sustained-yield production or Special Recreation Management Area management creates variation in the 

number and acres of ACEC designations under the action alternatives and the Proposed RMP. Another 

factor contributing to this variation is that management direction for the underlying land use allocations or 

lands with special designations provides for the relevant and important values for some of the potential 

ACECs. Some ACECs included in this analysis contain portions that overlap with Congressionally 

Reserved Lands and lands under the National Landscape Conservation System, such as Wild and Scenic 

Rivers, National Recreation Trail Management Corridors, District-Designated Reserve – Lands Managed 

for their Wilderness Characteristics, Wilderness Areas, and Wilderness Study Areas (Appendix F). For 

this analysis, the BLM includes acres managed for these other designations as part of the described 

potential ACEC boundary’s acreage because these landscapes also contain relevant and important values. 

However, the BLM would manage these acres foremost for the management needs under the 

congressional designation or National Landscape Conservation System needs. These overlapping areas 

have been included in the analysis of ACEC acres considered, because the associated management needs 

would support the maintenance and improvement of the relevant and important values identified within 

these landscapes, and it is important to account for the total acreage of maintained values on BLMadministered lands.

Although the BLM considers areas for designation, the BLM retains discretionary authority as to whether 

or not to designate potential ACECs as described later in ‘Potential ACECs not Designated Under the 

Action Alternatives and the Proposed RMP.’ The BLM’s assessments of the need for continuing 

protective management of existing and proposed ACECs are the primary driver of differences between 

the action alternatives and the Proposed RMP, and the No Action alternative.
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In all cases, where the BLM would designate ACECs or continue the protection of potential ACECs, the 

effect of the application of special management attention would continue the persistence of the relevant 

and important values, or affect change to those values towards a desired condition.

No Action

Under the No Action alternative, there would be no change to the designation of 86 existing ACECs or 

the application of interim protective management to the 39 previously nominated and 16 newly nominated 

potential ACECs. The districts would continue to implement special management attention in these areas. 

The effect of the application of interim special management attention on the resource values in these areas 

would be to maintain those values, or to change those values towards a desired condition.

Potential ACECs Designated Under the Action Alternatives and the 

Proposed RMP

The BLM would designate the most ACECs (108) and acres (93,515) under the Proposed RMP and the 

fewest ACECs (101) and acres (87,044) under Alternative C (Table 3-6). Alternative A and the Proposed 

RMP would provide special management attention to the largest number of relevant and important values; 

Alternative C would provide the least.

Table 3-6. All potential ACECs designations

District/

Field 

Office

Alt. A Alt. B Alt. C Alt. D PRMP

ACECs

(Number) Acres ACECs(Number) Acres ACECs(Number) Acres ACECs(Number) Acres ACECs(Number) Acres

Coos Bay 15 10,922 15 10,814 15 10,814 15 10,814 15 10,814

Eugene 22 14,661 23 14,826 22 14,476 23 14,736 23 14,736

Klamath 

Falls 6 7,332 4 1,253 4 1,253 6 7,332 6 6,383

Medford 27 25,499 27 25,499 27 25,499 27 25,499 28 25,527

Roseburg 9 10,197 9 10,197 9 10,197 9 10,197 9 10,197

Salem 28 25,934 27 25,859 24 24,806 27 25,798 27 25,859

Totals 107 94,545 105 88,448 101 87,044 107 94,376 108 93,515

Not precluding O&C Harvest Land Base sustained-yield production would require boundary revisions for 

4 (Alternative A), 5 (Alternative B), 6 (Alternative C), 11 (Alternative D), and 7 (Proposed RMP) of the 

potential ACECs. The effect of the application of special management attention on the relevant and 

important values in the remaining portions of these potential ACECs would be to maintain those values, 

or to change those values toward a desired condition. The relevant and important values in the areas 

removed from the potential ACECs would not receive the special management attention needed to 

maintain or protect them and would eventually experience a loss or degradation of those values.

Under the action alternatives and the Proposed RMP, three ACECs would require boundary revisions to 

exclude small Special Recreation Management Areas (North Bank, Upper Willamette Valley Margin, and 

Willamette Valley Prairie Oak and Pine Area), and two ACECs would require boundary revisions to 

remove existing quarries (Dakubetede and East Fork Whiskey Creek RNA). The areas that would be 

removed do not contain relevant and important values. The effect of the application of special 
140 | P a g e

management attention on the relevant and important values in the remaining portions of these potential 

ACECs would be to maintain those values, or to change those values toward a desired condition.

The BLM would designate all 33 of the RNAs, and 3 of the 4 ONAs considered under the action 

alternatives and the Proposed RMP.

Potential ACECs Not Designated Under the Action Alternatives and the 

Proposed RMP

Identification of an area as having relevant and important values does not require designation of that area 

as an ACEC. To be considered for designation, the potential ACEC must also need special management 

to retain the relevant and important values. However, the presence of relevant and important values and 

the identification that special management would be needed to maintain those values does not require 

designation of that area as an ACEC. Under the FLPMA, the BLM is only required to consider these areas 

for designation in the land use planning process. The BLM retains discretionary authority to consider 

through analysis as to whether or not to designate an ACEC in favor of management for other priorities or 

because management of the ACEC would not be consistent with other land management activities.

Most of the areas the BLM would not designate do not warrant special management attention. Under the 

Proposed RMP, 11 potential ACECs do not warrant special management attention, 1 potential ACEC 

would not be designated because of conflicts with other management priorities, and 1 potential ACEC 

would not be designated because of conflicts with direction for managing the O&C Harvest Land Base.

The BLM would not designate between 13 and 20 of the areas under action alternatives and the Proposed 

RMP (Table 3-7). The potential ACECs not designated due to conflicts with management of the O&C 

Harvest Land Base and other management direction would not receive the special management attention 

needed to maintain or protect their relevant and important values, which would eventually experience a 

loss or degradation of these values.

Table 3-7. Potential ACECs not designated under the action alternatives or the Proposed RMP

District/

Field 

Office

Alt. A Alt. B Alt. C Alt. D PRMP

ACECs

(Number) Acres ACECs(Number) Acres ACECs(Number) Acres ACECs(Number) Acres ACECs(Number) Acres

Coos Bay 2 1,136 2 1,136 2 1,136 2 1,136 2 1,136

Eugene 2 243 1 76 2 427 1 167 1 167

Klamath 

Falls 2 318 4 5,449 4 5,449 2 318 2 318

Medford 5 1,610 5 1,610 5 1,610 5 1,610 4 1,582

Roseburg - - - - - - - - - -

Salem 3 259 4 334 7 1,387 4 395 4 334

Totals 14 3,566 16 8,605 20 10,009 14 3,626 13 3,537

In several instances, the BLM integrated existing and potential ACECs in the formation of potential 

ACECs for consideration under the action alternatives and the Proposed RMP. While this changed the 

number of ACECs considered under the action alternatives and the Proposed RMP, it did not remove 

acres or relevant and important values from potential protection.
141 | P a g e

The following table (Table 3-8) shows the summary of the values categories that would not receive 

special management attention by each action alternative or the Proposed RMP.

Table 3-8. Relevant and important value categories that would not receive special management attention

Value Category Alt. A

(Number)

Alt. B

(Number)

Alt. C

(Number)

Alt. D

(Number)

PRMP

(Number)

Historic, Cultural, and Scenic - 2 3 1 -

Fish and Wildlife - 4 6 1 -

Natural Process or System 2 5 6 3 2

Natural Hazard - - - - -

Totals 2 11 15 5 2

Areas Not Warranting Special Management

The BLM would not designate between 9 (Alternative B) and 12 (Alternative A) of the potential ACECs 

because they would not warrant special management (Table 3-9). The BLM would not designate 11 

potential ACECs under the Proposed RMP for this same reason. There would be no loss of relevant and 

important values associated with not designating these as ACECs. The management attention needed for 

their values comes through the management direction for the underlying land use allocations or for 

specific resource programs.

Table 3-9. Reasons for not designating potential ACECs

Reason For Non-designation Alt. A

(Number)

Alt. B

(Number)

Alt. C

(Number)

Alt. D

(Number)

PRMP

(Number)

Areas not warranting special 

management 12 9 10 11 11

Areas not designated due to 

conflicts with O&C Harvest 

Land Base

1 7 10 2 1

Areas not designated due to 

conflicts with other 

management priorities

1 - - 1 1

Totals 14 16 20 14 13

The Coos Bay District would not designate the North Spit Addition potential ACEC under all action 

alternatives or the Proposed RMP because the district would maintain the relevant and important values 

under the BLM’s Special Status Species program. For Steel Creek, the combination of management 

direction for the Late-Successional Reserve, Riparian Reserve, and management for ESA-listed species 

would protect the relevant and important values.

The Klamath Falls Field Office would not designate the Spencer Creek potential ACEC under Alternative 

A and the Proposed RMP or the Surveyor potential ACEC under all action alternatives and the Proposed 

RMP because management direction for the Late-Successional and Riparian Reserve would protect the 

relevant and important values.

The Medford District would not designate the Green Springs Mountain Scenic potential ACEC under any 

of the action alternatives or the Proposed RMP because management for Visual Resource Management 
142 | P a g e

Class II and the Late-Successional Reserve would provide for the relevant and important values. In 

addition, management direction for the Late-Successional Reserve would also provide for the relevant and 

important values for the Hoxie Creek potential ACEC under Alternatives A and D, and the Proposed 

RMP, making designation unnecessary. The Medford District would not designate the Iron Creek and Tin

Cup potential ACECs under any of the action alternatives or the Proposed RMP because the management 

direction for the Late-Successional Reserve would achieve the desired protection for their relevant and 

important values. The Moon Prairie potential ACEC would not be designated under Alternatives A, C, 

and D because Late-Successional Reserve management direction would provide the management needed 

to provide for the relevant and important values.

The Salem District would not designate the Beaver Creek potential ACEC under the action alternatives 

and the Proposed RMP because the management direction for the Riparian Reserve would provide for the 

relevant and important values. The Molalla River Segment B corridor is recommended for inclusion into 

the national Wild and Scenic River system, which would provide for the relevant and important values of 

the Molalla Meadows potential ACEC under the action alternatives or the Proposed RMP.

The Yaquina Head potential ACEC lies entirely within the congressionally designated boundary for the 

Yaquina Head Outstanding Natural Area and would be allocated to the Congressionally Reserved Lands 

and the National Landscape Conservation System land use allocation under all action alternatives and the 

Proposed RMP. The Outstanding Natural Area designation was established by Congress to protect unique 

scenic, scientific, educational, and recreational values. Under all action alternatives and the Proposed 

RMP, the BLM would manage the Yaquina Head Outstanding Natural Area under management direction 

to conserve and develop the scenic, natural, and historic values and allow continued use for which the 

area was designated. The Salem District determined between the Draft RMP/EIS and this Proposed 

RMP/Final EIS that the Yaquina Head Outstanding Natural Area’s congressional designation and the 

management direction for the Congressionally Reserved Lands and the National Landscape Conservation 

System land use allocation provides all of the special management attention needed for the relevant and 

important values. For this reason, the BLM considered, but would not designate the Yaquina Head 

potential ACEC under any of the action alternatives or the Proposed RMP. Its relevant and important 

values are not included in Table 3-8.

Areas Not Designated Due to Conflicts with O&C Harvest Land Base

The BLM would not designate between 1 (Alternative A) and 10 (Alternative C) potential ACECs under 

the action alternatives or the Proposed RMP because the special management required for the protection 

or maintenance of the relevant and important values would preclude O&C sustained-yield timber harvest 

in the Harvest Land Base as shown in Appendix F, Table F-1 (as annotated by No_a in this table).

The BLM would not designate the Williams Lake potential ACEC in the Salem District under the 

Proposed RMP for this reason. The Williams Lake potential ACEC contains relevant and important 

values of ‘natural processes’ due to the presence of fragile lakeside native plant communities. Under the 

Proposed RMP, lands within this potential ACEC are allocated to the Harvest Land Base. Because these 

lands are also O&C lands, any designation of an ACEC must not preclude sustained-yield timber 

management (see Chapter 1, ‘Major Authorizing Laws – The O&C Act and the FLPMA’). The Salem 

District BLM staff reviewed management needs to protect the relevant and important values and 

determined that those management needs would preclude sustained-yield timber management, largely due 

to the fragile nature of the plant communities and the potential for disturbance from timber management. 

The relevant and important values for the potential ACECs not designated due to conflicts with 

management direction for the O&C Harvest Land Base would be lost or degraded over time (Table 3-8).
143 | P a g e

Areas Not Designated Due to Conflicts with Other Management Priorities

The Hult Marsh potential ACEC in the Eugene District would not be designated under Alternatives A and 

D, and the Proposed RMP because the special management needed to maintain current hydrologic 

conditions may conflict with public health and safety. The Eugene District identified Hult Dam as a high 

hazard dam. Alteration to the dam and the recommended water levels to maintain public safety may not 

maintain current hydrologic conditions needed to maintain the relevant and important values in the 

potential ACEC. The Riparian Reserve inner widths under these alternatives and the Proposed RMP 

would also not provide for the relevant and important values. The BLM includes the loss or degradation 

of these values in Table 3-8.

References

USDI BLM. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, 

Oregon/Washington State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.
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Air Quality

Key Points

 All action alternatives and the Proposed RMP would produce more particulate emissions than the 

No Action alternative and current conditions. However, adherence to the requirements of the 

Oregon Smoke Management Plan would continue to limit impacts to human health and visibility 

from prescribed fires.

 Based on the amount of area where active management would occur, Alternative C has the most

potential to reduce adverse effects to human health and visibility from wildfires over the longterm, while the No Action alternative would present the highest risk.

Summary of Notable Changes from the Draft RMP/EIS

 Changed Figure 3-10 and Figure 3-11 to display the emissions from prescribed fire only; 

wildfire emissions discussed separately to provide context for prescribed fire emissions and 

generalized more to reflect uncertainty over when wildfires would actually occur.

 Added an uncertainty analysis to the discussion on hazardous fuels prescribed fire emissions.

 Added a cumulative effects discussion.

 Removed the discussion concerning the potential of each alternative and the Proposed RMP to 

reduce wildfire emissions through active management, as it is not supported adequately by 

science.

Issue 1

How would the proposed management actions affect PM2.5, PM10, and expected visibility?

Summary of Analytical Methods

The effects analysis includes emissions from both the hazardous fuels and activity fuels prescribed fire

programs. The expected emissions from prescribed fire to reduce hazardous fuels do not vary, because 

there is no reasonable basis for the BLM to forecast a difference in the acreage of treatments among the 

alternatives and the Proposed RMP. Therefore, the main variable in estimated particulate emissions from 

prescribed fire is the amount of activity fuels prescribed burning. 

The Woodstock model produced estimates of the acres of activity fuels treatments by treatment type (e.g., 

hand pile burning, machine pile burning, and broadcast burning) for each alternative and the Proposed 

RMP. Based on input from district fuels specialists using professional expertise and experience, the RMP 

interdisciplinary team fuels specialist provided pile dimensions, estimates of the number of piles per acre,

and the amount of fuel typically consumed in broadcast burns. The fuels specialist provided similar 

details for the hazardous, or natural, fuels program along with the expected acres of each treatment type 

for each district. The BLM input these details into Consume 3.0 to estimate particulate emissions. The 

Planning Criteria provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales, which is incorporated here by reference (USDI BLM 2014, pp. 33–35).

Data sources include annual smoke reports from the Oregon Department of Forestry and visibility 

information from the Interagency Monitoring of Protected Visual Environments (IMPROVE) program for 

the existing condition. Appendix E contains a more detailed description of the analytical methods used to 

estimate particulate emissions from prescribed burning and wildfires.
146 | P a g e

This analysis does not quantify emissions from treating sudden oak death. At present, the number of acres 

treated through prescribed burning to control sudden oak death remains small, averaging 55 acres per 

year, but with considerable interannual variability (see Invasive Species, Issue 3 in this chapter for more 

detail). This small acreage of burning contributes a negligible amount to emissions, compared to other 

prescribed fire activities. Although it is reasonably foreseeable that the acreage treated for sudden oak 

death will increase over time, it is not possible to forecast that increase quantitatively, and emissions from 

sudden oak death treatments are likely to remain a negligible contribution to emissions compared to other 

prescribed fire activities. 

The BLM analyzed the expected emissions from wildfires to provide additional context. Estimated 

wildfire emissions vary over time, but not among alternatives or the Proposed RMP. The BLM altered the 

analysis process used to estimate particulate matter emissions from wildfires to reflect uncertainties over 

when those emissions might occur. Instead of estimating the emissions per decade, the BLM totaled the 

number of acres burned in wildfires over the 50-year analysis period and estimated the average emissions 

per year. The BLM estimated emissions from wildfires to provide context for the emissions from 

prescribed fire.

Background

Western Oregon has a history of air quality problems due to the combination of weather patterns and 

topography. Poor air quality develops when a major polluting activity or event combines with temperature 

inversions and strong high-pressure systems that create stagnant air. The topography of the planning area 

contains several bowls that trap and concentrate pollutants in valley bottoms, exacerbating the effects of 

stagnant air. The worst air quality in winter typically occurs due to the combination of a strong and 

persistent inversion, high vehicle use, and biomass consumption associated with heat or power generation 

(particulates) (ODEQ 2012). The worst air quality in summer typically occurs due to the combination of 

strong persistent high pressure and high vehicle use (ozone) or widespread and large wildfires 

(particulates, ozone). Sources of pollutants may be chronic, such as from a factory or homes heating with 

wood during the winter, or transient, such as from prescribed burning or wildfires. Pollutants from BLM 

land management activities or wildfires can exacerbate existing air quality problems.

Smoke from prescribed fire and wildfire produces carbon monoxide, nitrogen oxide compounds, and 

particulates, along with certain air toxics such as acrolein, benzene, and formaldehyde. The main criteria 

pollutant of concern for BLM management activities is particulate matter (PM10 and PM2.5) (ODEQ 2003, 

2009, 2012, 2013a); in addition to posing a human health risk (see Table 3-11) due to their small size, 

particulate matter from wildland fuels are excellent at scattering light, thereby reducing visibility. Carbon 

monoxide, on the other hand, while a substantial human health risk, dilutes rapidly, making it a hazard to 

firefighters only. The concentration of air toxics found in smoke are typically very low, with regulations 

focused on industrial and commercial sources, vehicle emissions, and indoor air. Prescribed fire and 

wildfire do not produce ozone directly, but do produce two additional pollutants, nitrogen oxides (NOx) 

and volatile organic compounds, which are precursors for ground-level ozone under certain conditions.

The Oregon Department of Environmental Quality (ODEQ) Air Quality Division implements the U.S. 

Environmental Protection Agency’s (EPA’s) air quality regulations and this division has delegated smoke 

management responsibilities to the Oregon Department of Forestry (ODF). All forest managers including 

the BLM conduct prescribed burning in western Oregon under requirements in the Oregon Smoke 

Management Plan (OAR 629-048-0001–0500). This plan requires dispersion, dilution, and avoidance 

techniques to minimize smoke impacts on mandatory Class 1 areas, designated air quality non-attainment 

and maintenance areas, and smoke sensitive receptor areas. Mandatory Class 1 areas are areas, such as 

designated Wilderness Areas, identified under the Clean Air Act as requiring the highest level of 
147 | P a g e

protection.36 Non-attainment and maintenance areas are areas that are either not attaining, or have a 

history of not attaining, the National Ambient Air Quality Standards (NAAQS). 37 A Smoke Sensitive

Receptor Area is an area that has the highest level of protection under the Oregon Smoke Management 

Plan due to a history of smoke incidents, its’ population density, or from a legal protection related to 

visibility.

Visibility is protected in mandatory Class I areas as required by the Clean Air Act. The goal of the 

Regional Haze Rule (a part of the Clean Air Act) is to reduce haze in mandatory Class I areas to naturally 

occurring levels by 2064. Because visibility varies day by day, the rule requires that visibility on the 20 

percent worst-case days be reduced to natural background conditions, while ensuring no degradation of 

the 20 percent best-case days. States are to take reasonable measures to make progress towards this goal.

Crater Lake National Park and the Kalmiopsis, Mt. Hood, Three Sisters, Mt. Jefferson, Mt. Washington, 

Diamond Peak, Gearhart Mountain, and Mountain Lakes Wilderness Areas are mandatory Class 1 areas 

within the air quality analysis area. Of these areas, visibility monitoring occurs at Crater Lake National 

Park and the Kalmiopsis, Three Sisters, and Mount Hood Wilderness Areas. Visibility is measured in 

deciviews with the lower the number, the better the visibility. The Interagency Monitoring of Protected 

Visual Environments (IMPROVE) program monitors air quality and visibility at selected mandatory 

Class 1 areas and has established natural condition deciviews at each monitored site for the clearest and 

haziest days. The program has estimated annual values and trends for the clearest days and haziest days 

since 2003 (data summaries available at 

http://views.cira.colostate.edu/fed/AqSummary/VisSummary.aspx?siidse=1).

The EPA regulates air quality under the Clean Air Act to protect human health and welfare, with visibility 

in mandatory Class 1 areas serving as the indicator for human welfare with respect to smoke. The EPA 

has established NAAQS for seven criteria pollutants (Table 3-10). The primary standard addresses human 

health and the secondary standard human welfare. On October 1, 2015, the EPA formally lowered the 8-

hour ozone standard to 0.070 ppm.

 

36 Mandatory Class 1 areas include 156 national parks, Wilderness Areas, international parks, and other areas 

identified by Congress in the 1977 amendment to the Clean Air Act. The areas designated include all national parks 

greater than 6000 acres in size and all designated Wilderness Areas and national memorial parks greater than 5,000 

acres in size in existence as of August 1977. The amendment also set a visibility goal for these areas to protect them 

from future human-caused haze, to eliminate existing human-caused haze, and require reasonable progress toward 

that goal.

37 National Ambient Air Quality Standards are specific target threshold concentrations and exposure durations of six 

pollutants based on criteria gauged to protect human health and the welfare of the environment.
148 | P a g e

Table 3-10. Criteria pollutants regulated under the Clean Air Act and the current NAAQS for each 

Pollutant Primary/

Secondary

Averaging 

Time Level Form

Carbon 

Monoxide 

(CO)

Primary

8-hour 9 ppm

Not to be exceeded more than once per year 1-hour 35 ppm

Lead Primary and 

Secondary

Rolling 3 

month average 0.15 μg/m3 Not to be exceeded

Nitrogen 

Dioxide

(NO2)

Primary 1-hour 100 ppb 98th percentile, averaged over 3 years

Primary and 

Secondary Annual 53 ppb Annual mean

Ozone

(O3)

Primary and 

Secondary 8-hour 0.075 ppm Annual fourth-highest daily maximum 8-hr concentration, averaged over 3 years

PM2.5

Primary Annual 12 μg/m3 Annual mean, averaged over 3 years

Secondary Annual 15 μg/m3 Annual mean, averaged over 3 years

Primary and 

Secondary 24-hour 35 μg/m3

98th percentile, averaged over 3 years

PM10

Primary and 

Secondary 24-hour 150 μg/m3 Not to be exceeded more than once per year on average over 3 years

Sulfur

Dioxide

(SO2)

Primary 1-hour 75 ppb 99th percentile of 1-hour daily maximum 

concentrations, averaged over 3 years

Secondary 3-hour 0.5 ppm Not to be exceeded more than once per year

ppm = parts per million, ppb = parts per billion, μg = micron 

Air quality non-attainment areas within the planning area include Eugene-Springfield and Oakridge for 

PM10, and Oakridge and Klamath Falls for PM2.5. Portland-Vancouver and Salem are air quality 

maintenance areas for ozone. However, the BLM does not know whether Portland-Vancouver and Salem 

would fall back into non-attainment under the new standard. The Oregon Smoke Management Plan 

identifies the following Smoke Sensitive Receptor Areas (SSRAs) within the planning area (Map 3-1):

 The cities of Carlton, Corvallis, Cottage Grove, Eugene, McMinnville, Portland, Sheridan, 

Silverton, Springfield, St. Helens, Stayton, Sublimity, Veneta, Willamina, and Yamhill; 

 The acknowledged urban growth boundaries of the following cities: Astoria, Coos Bay, Grants 

Pass, Klamath Falls, Lakeview, Lincoln City, Newport, North Bend, Oakridge, Roseburg, and 

Tillamook; 

 The area within the Bear Creek and Rogue River Valleys described in OAR 629-048-0160, 

including the cities of Ashland, Central Point, Eagle Point, Jacksonville, Medford, Phoenix, and 

Talent; and 

 The area within the Columbia River Gorge Scenic Area, as described in 16 U.S.C. Section 554b 

(2003). 
149 | Page

Map 3-1. Smoke Sensitive Receptor Areas as described in the Oregon Smoke Management Plan 
150 | P a g e

The BLM must register all prescribed burns on BLM-administered forestlands within the planning area 

with ODF in compliance with Oregon’s administration of the Clean Air Act. The registration includes the 

location, the planned date and time of ignition, and the estimated fuel load and consumption. The day 

before each planned burn, ODF meteorologists evaluate this information along with the forecasted 

weather for the next day to determine whether smoke from a given burn is likely to enter a SSRA. 

Meteorologists must not knowingly allow a burn to occur which will cause an intrusion of smoke into an 

SSRA. Thus, each day these meteorologists create burn instructions for different parts of the forest region 

to prevent smoke from entering SSRAs. The BLM must follow these instructions in compliance with 

Oregon’s administration of the Clean Air Act.

The Air Quality Index is widely used to report relative daily air quality in a common framework related to 

potential impacts to human health (Table 3-11). Index values range from zero to 300 and are typically 

displayed in a color-coded table or graph. The higher the value, the greater the level of air pollution and 

the greater the human health concerns. The Air Quality Index is based on the combined 24-hour 

concentrations of PM2.5 and O3. As pollution standards are changed, the formula used to calculate the air 

quality index is also adjusted in order to maintain the relationship to human health concerns.

Table 3-11. Air Quality Index with health advisories

Air Quality Air Quality 

Index Health Advisory

Good 0–50 No health impacts expected.

Moderate 51–100 Unusually sensitive people should consider reducing prolonged or 

heavy outdoor exertion.

Unhealthy for 

Sensitive Groups 101–150

People with heart disease, respiratory disease (such as asthma), older 

adults, and children should reduce prolonged or heavy exertion. Active 

healthy adults should also limit prolonged outdoor exertion.

Unhealthy 151–200

People with heart disease, respiratory disease (such as asthma), older 

adults, and children should avoid prolonged or heavy exertion. 

Everyone else should reduce prolonged or heavy outdoor exertion.

Very Unhealthy 

(Alert) 201–300

People with heart disease, respiratory disease (such as asthma), older 

adults, and children should avoid all physical activity outdoors. 

Everyone else should avoid prolonged or heavy exertion.

Ozone Maintenance Areas

Prescribed burning produces precursor emissions (e.g., NOx and volatile organic compounds) that under 

higher temperatures and sunny days produce ground-level ozone. However, BLM prescribed burning 

activities are projected to be a long distance from the two ozone maintenance areas within the planning 

area. As a result, effects would be very low for the precursors of ozone. Local vehicular traffic in 

Portland, Vancouver, and Salem represents a primary source of air emissions that may lead to the 

development of ozone. Furthermore, the highest levels of ozone in the maintenance areas occur during 

summer, while most prescribed burning activity is during spring and fall. Therefore, it is very unlikely 

that any of the alternatives or the Proposed RMP would have a notable effect on ozone levels in ozone 

maintenance areas in the planning area; therefore, the BLM did not analyze for this pollutant.

Conformity

The General Conformity Rule (a part of the Clean Air Act) applies to Federal actions occurring in nonattainment or maintenance areas when the net change in total direct and indirect emissions of non-
151 | P a g e

attainment pollutants (or their precursors) exceeds specific thresholds (known as di minimis levels). The 

intent of the General Conformity Rule is to prevent the air quality impacts of Federal actions from 

causing or contributing to a violation of the NAAQS (EPA 2013) or interfering with the purpose of the 

State Implementation Plan. This means that under the Clean Air Act, Section 176 and 40 CFR, Part 93, 

Subpart W, Conformity Rules, Federal agencies must make a determination that proposed actions in 

Federal non-attainment areas conform to the applicable EPA-approved State Implementation Plan before 

taking an action. 

All prescribed burns within western Oregon must comply with the Oregon Smoke Management Plan, 

which prohibits smoke intrusions into SSRAs. As a result, the Conformity Rule is not applicable for BLM 

prescribed burning actions within non-attainment areas, since the burning would not—

 Be likely to cause or contribute to new violations of Federal air quality standards; 

 Increase the severity of existing violations for Federal and State air quality standards; or 

 Delay the timely attainment of Federal air quality standards. 

Affected Environment 

Particulate Matter Emissions 

Most broadcast-type prescribed burning (broadcast burning, under-burning, jackpot burning) occurs in 

spring and early fall, when frequent cold fronts and short-wave troughs create atmospheric instability 

during the day. This instability promotes air mixing and transport of pollutants away from SSRAs and air 

quality non-attainment and maintenance areas. Most pile burning (hand piles, machine piles, landing 

piles) occurs in late fall and winter, when the atmosphere is typically more stable, with a higher potential 

to affect air quality adversely for relatively short periods. 

Large wildfires contribute to air quality issues over large areas and for prolonged periods. During 2002, 

wildfires resulted in 14 daily PM2.5 exceedences in Klamath Falls and one in Medford (ODEQ 2003); at 

that time, the daily PM2.5 standard was 65 μg/m3 (the standard has since been lowered). Elevated 

particulate levels were reported between late July and the end of August at Bend, Brookings, Cave 

Junction, Grants Pass, Klamath Falls, and Medford (ODEQ 2003). Similar issues developed in 2008 from 

extensive wildfires burning in northern California; smoke from those fires reached as far north as Portland 

(ODEQ 2009). 

ODF began estimating PM2.5 emissions from wildfires as part of their annual smoke management reports 

beginning in 2002, although only a statewide accounting is available. Estimated wildfire PM2.5 emissions 

commonly exceed 1,000 tons per year and exceeded 6,000 tons per year in 2006, 2007, 2012, and 2014. 

The 2012 fire season resulted in the highest estimated PM2.5 emissions from wildfire at nearly 12,000 

tons. The 2014 fire season the second highest, at about 9,000 tons. Most of the 2012 emissions were from 

the large rangeland wildfires in southeastern Oregon. Several large wildfires in southwestern Oregon in 

2013 contributed a significant amount of particulate pollution, and potentially created problematic surface 

ozone concentrations as well. 

Large wildfires that started on BLM-administered lands within the planning area produced an estimated 

1,217 tons per year of PM10 emissions and 731 tons per year of PM2.5 emissions on average, based on 

acres burned from 1981 through 2013. However, there is considerable interannual variability in 

emissions. Notable years where wildfire emissions were particularly high include 1987, 2002, and 2014, 

principally from wildfires originating on the Medford and Roseburg Districts. 
152 | Page

Based on ODF annual reports of tons consumed by prescribed burning in the Other Federal category from 

1995 through 2012, actual emissions have averaged 840 tons (range 376 – 1,538 tons) of PM10 and 753 

tons (range 337 – 1,378 tons) of PM2.5 per year, primarily from hazardous fuels reduction treatments in 

southwest Oregon and slash disposal following forest management operations (Figure 3-3). These 

estimated emissions account for approximately 7.5 percent of total PM10 and PM2.5 emissions from 

prescribed burning in western Oregon. The Other Federal category consists mostly of burning by the 

BLM, with only minor contributions from the National Park Service and U.S. Fish and Wildlife Service. 

Figure 3-3. Estimated emissions from prescribed burning in western Oregon for (a) particulate matter 10 

microns in size and smaller, and (b) particulate matter 2.5 microns in size and smaller 

The Oregon Department of Environmental Quality (ODEQ) (2013a) reports that trends have been 

downward for most pollutants in most areas, except for daily PM2.5 in Klamath Falls and Oakridge. Both 

Klamath Falls and Oakridge have exceeded the daily PM2.5 standard of 35 μg/m3

 nearly every year since 

2006, when the standard was lowered to that level. Residential home heating in winter is associated with 

most exceedences of the PM2.5 standard, with summer wildfires a secondary factor. The EPA (2013) 

lowered the primary annual PM 3

2.5 standard to 12 μg/m , effective March 18, 2013. Whether this change 

will result in any areas designated as non-attainment for the annual PM2.5 standard will not be known until 

late 2015 at the earliest. The daily PM2.5 standard remains unchanged. 

Despite the best efforts of both ODF smoke forecasters and BLM personnel, intrusions into SSRAs can 

and do occur. The occurrence of intrusions is not related to the number of acres burned in any given year 

(Figure 3-4) but, according to an evaluation of six smoke intrusion reports for 2008 and 2012, is most 

commonly a result of an unexpected shift in wind direction from the forecasted direction. Many of these 

shifts likely resulted from localized meteorological patterns, which could not be resolved with coarsescale weather forecast models. Nearly all intrusions shown in were in southwest Oregon. 

7,430 

294 

753 

1,550 

Average PM2.5 Emissions 

1995–2012 (Tons per Year)

Private

State

Other Federal

Forest Service

B.

Based on ODF annual reports of tons consumed by prescribed burning in the Other Federal category from 

1995 through 2012, actual emissions have averaged 840 tons (range 376 – 1,538 tons) of PM10 and 753 

tons (range 337 – 1,378 tons) of PM2.5 per year, primarily from hazardous fuels reduction treatments in 

southwest Oregon and slash disposal following forest management operations (Figure 3-1). These 

estimated emissions account for approximately 7.5 percent of total PM10 and PM2.5 emissions from 

prescribed burning in western Oregon. The Other Federal category consists mostly of burning by the 

BLM, with only minor contributions from the National Park Service and U.S. Fish and Wildlife Service. 

Figure 3-1. Estimated emissions from prescribed burning in western Oregon for (a) particulate matter 10 

microns in size and smaller, and (b) particulate matter 2.5 microns in size and smaller 

The Oregon Department of Environmental Quality (ODEQ) (2013a) reports that trends have been 

downward for most pollutants in most areas, except for daily PM2.5 in Klamath Falls and Oakridge. Both 

Klamath Falls and Oakridge have exceeded the daily PM2.5 standard of 35 μg/m3

 nearly every year since 

2006, when the standard was lowered to that level. Residential home heating in winter is associated with 

most exceedences of the PM2.5 standard, with summer wildfires a secondary factor. The EPA (2013) 

lowered the primary annual PM2.5 standard to 12 μg/m3

, effective March 18, 2013. Whether this change 

will result in any areas designated as non-attainment for the annual PM2.5 standard will not be known until 

late 2015 at the earliest. The daily PM2.5 standard remains unchanged. 

Despite the best efforts of both ODF smoke forecasters and BLM personnel, intrusions into SSRAs can 

and do occur. The occurrence of intrusions is not related to the number of acres burned in any given year 

(Error! Reference source not found.) but, according to an evaluation of six smoke intrusion reports for 

2008 and 2012, is most commonly a result of an unexpected shift in wind direction from the forecasted 

direction. Many of these shifts likely resulted from localized meteorological patterns, which could not be 

resolved with coarse-scale weather forecast models. Nearly all intrusions shown in were in southwest 

Oregon. 

8,293 

328 

840 

1,730 

Average PM10 Emissions 

1995–2012 (Tons per Year)

Private

State

Other Federal

Forest Service

A.

7,430 

294 

753 

1,550 

Average PM2.5 Emissions 

1995–2012 (Tons per Year)

Private

State

Other Federal

Forest Service

B.
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Figure 3-4. Number of smoke intrusions attributed to BLM prescribed fires into SSRAs compared to 

annual acres burned from 2002 through 2014 in western Oregon

Source: ODF annual smoke reports 2002–2014

Visibility and Air Quality

Of the four monitored mandatory Class 1 areas within or adjacent to the planning area, none meet the 

natural background conditions for haze for either the clearest or the haziest days, although Crater Lake 

National Park and Mount Hood Wilderness come the closest for the clearest days (Table 3-12). Visibility 

is generally improving at Crater Lake National Park and the Mount Hood and Kalmiopsis Wildernesses, 

although not all trends are statistically significant. Visibility at Three Sisters Wilderness is slowly 

degrading, although the trend is not statistically significant yet. The main contributors to the haziest days 

are organic carbon and ammonium sulfate.

0

1

2

3

4

5

6

7

8

9

10

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

BLM-attributable Smoke Intrusions

Acres Burned by Federal Agencies

(except USFS, mostly BLM)

Comparison of Acres Burned and Smoke Intrusions

Acres Burned by Federal Agencies (except USFS)

BLM-attributable Smoke Intrusions
154 | P a g e

Table 3-12. Visibility conditions and trends at four mandatory Class 1 areas within or adjacent to the 

planning area from 2003 through 2012 and the statistical trend

Parameter Crater Lake 

National Park

Kalmiopsis 

Wilderness

Mount Hood 

Wilderness

Three Sisters 

Wilderness

Natural condition: 

clearest days

246 miles

(0 deciviews)

~ 161 miles

(~ 4 deciviews)

229 miles

(1 deciview)

211 miles

(2 deciviews)

Current condition: 

clearest days

> 211 miles

(< 2 deciviews)

~ 143 miles

(~ 6 deciviews)

211–229 miles

(1–2 deciviews)

174–198 miles

(2.5–3.5 deciviews)

Statistical trend in 

clearest days

Significant 

downward

Non-significant 

downward

Significant 

downward

Non-significant 

upward

Natural condition: 

haziest days

~ 112 miles

(~ 8 deciviews)

~ 90 miles

(~ 9.5 deciviews)

~ 112 miles

(~ 8 deciviews)

92 miles

(9 deciviews)

Current condition: 

haziest days

40–87 miles

(10–18 deciviews)

37–68 miles

(13–19 deciviews)

47–81 miles

(11–17 deciviews)

37–62 miles

(13–18 deciviews)

Statistical trend in 

haziest days

Non-significant 

downward

Significant 

downward

Non-significant 

downward

Non-significant 

upward

Source: IMPROVE website: http://vista.cira.colostate.edu/improve/. Accessed November 18, 2014

In 2013, ODEQ evaluated the contribution of prescribed fire to the 20 percent worst-case visibility days 

in Oregon’s Class I areas, concluding that prescribed burning in close proximity to mandatory Class I 

areas was a statistically significant contributor to the 20 percent worse days (ODEQ 2013b). The 

Kalmiopsis Wilderness and Crater Lake National Park were particularly affected, especially in October 

and November (Figure 3-5). As a result, ODF revised the Oregon Smoke Management Plan to require 

that any personnel conducting a prescribed fire within 31 miles (50 km) upwind of these two mandatory 

Class I areas follow a checklist of procedures designed to keep the main plume out of Crater Lake 

National Park and the Kalmiopsis Wilderness.
155 | P a g e

Figure 3-5. Example of identification of the 20 percent worse days in a given year and the proportional 

contribution of various factors to reduced visibility

Note: Black and green indicate vegetation burning as the source of the pollutant. W identifies a worse day and a circled W 

indicates prescribed fire as the probable cause. 

Source: ODEQ 2013b

Adverse impacts to air quality that are caused by prescribed burning, including effects to visibility and 

human health, generally tend to be of short duration (hours) and limited to the local area (less than five 

miles from the burn). Conversely, wildfire adverse impacts tend to be of longer duration (days to weeks), 

occur over a much broader area, and produce much unhealthier conditions. Figure 3-6 displays the daily 

Air Quality Index for Medford in 2008. Large spikes in July and August are from wildfires, while 

moderate air quality in September through January is primarily from woodstoves with some smoke from 

pile burning possible. Three intrusions into mandatory Class 1 areas were attributed to BLM prescribed 

burning.
156 | P a g e

Figure 3-6. Daily air quality index for Medford in 2008 

Source: ODEQ 2009 

Air quality and visibility data from 2013 illustrate the impacts from wildfires. During that summer, 

wildfire impacts in southwest Oregon produced unhealthy or more severe levels for seven days in 

Medford (Figure 3-7) and for nine days in both Grants Pass and Cave Junction (Figure 3-8). The large 

spike in late July was due to a series of wildfires, of which the Douglas Complex was the largest. 

Additional air quality degradation occurred in Medford from November through February from sources 

other than prescribed fire. Wildfires also resulted in severe degradation of visibility in Crater Lake 

National Park (Figure 3-9) and the Kalmiopsis Wilderness (data not shown). Wildfires typically create 

five to ten times greater the impacts than other types of events and persist over several weeks. 
157 | P a g e

Figure 3-7. Air quality index for 2013 for Medford 

Note: ‘FF’ refers to the days where air quality degradation was attributed to forest fires. 

Source: ODEQ 2014 

Figure 3-8. Air quality index for 2013 for Grants Pass 

Note: ‘FF’ refers to the days where air quality degradation was attributed to forest fires. 

Source: ODEQ 2014 
158 | P a g e

Figure 3-9. Degradation of visibility from burning vegetation in 2013 as measured through light 

scattering (inverse megameters) at Crater Lake National Park 

Source: IMPROVE website, http://views.cira.colostate.edu/fed/DataWizard/Default.aspx, accessed November 25, 2014 

Environmental Consequences 

Particulate Matter Emissions 

Emissions of both PM10 and PM2.5 would increase relative to the 2013 baseline under all alternatives and 

the Proposed RMP because of the increase in activity fuels treatment levels (Figure 3-10 and Figure 3-

11). Although there are some decadal differences, prescribed burning emissions under the Proposed RMP 

would be very similar to those under Alternative B. 
159 | P a g e

Figure 3-10. Expected increases in PM10 emissions from prescribed fire over time and relative to the 

estimate for current prescribed fires

Figure 3-11. Expected increases in PM2.5 emissions from prescribed fire over time and relative to the 

estimate for current prescribed fires

0%

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160 | P a g e

Some of the difference between the estimated current and projected emissions is likely due to the 

differing estimation methods used for each. Fuel treatment method (e.g., hand or machine pile burning 

and broadcast burning) affects the amount of particulates emitted by affecting the amount of fuel 

consumed and the relative proportions of flaming and smoldering combustion (Hardy et al. 2001). 

Smoldering combustion emits more than twice the particulates as flaming combustion (Hardy et al. 

2001). The current condition is based on the tons of fuels consumed reported to ODF, with insufficient 

information to determine the proportions of actual treatment methods (Hardy et al. 2001, p. 100). Thus, 

the BLM assessed the current condition using a generic multiplier applied to the reported tons consumed. 

The BLM does not know whether this value represents an under-estimation or over-estimation of current 

conditions. The BLM estimated projected emissions on more detailed information using more 

sophisticated tools than a generic multiplier.

Although there is no reasonable basis for the BLM to forecast a difference in the acreage of hazardous 

fuels prescribed fire among the alternatives or the Proposed RMP, this program experiences considerable 

interannual variability in acres treated and treatment method (see the Fire and Fuels section of this 

chapter). As a result, the particulate matter emissions vary widely from year-to-year. Emissions for all 

prescribed burning can vary from the estimate due to actual verses assumed pile size, pile shape, and 

number of piles per acre and in fuel type, fuel loading, and fuel continuity in underburns and broadcast 

burns. Since fuels are more homogeneous in the activity fuels treatment program, the amount of variation 

is smaller than in the more heterogeneous fuelbeds of the hazardous fuels program. Accounting for these 

variations, the BLM estimated a potential range in average annual emissions of approximately 330 tons to 

1,300 tons of PM10 and 230 to 1,030 tons of PM2.5 with an expected annual average of 930 and 685 tons 

of PM10 and PM2.5, respectively.

Similar to the current condition, the BLM projected that the Medford District would have the largest 

number of acres burned by wildfire, followed by the Roseburg District and then the Eugene and Salem 

Districts, with much smaller acres projected to burn over time on the Coos Bay District and the Klamath 

Falls Field Office. Since the projected hazardous fuels program is the same as the current program, the 

Medford District would continue to have the largest hazardous fuels program, followed by the Klamath 

Falls Field Office and then the Roseburg District. The Coos Bay District would have a small hazardous 

fuels program while the Eugene and Salem Districts essentially would have no hazardous fuels program. 

In contrast, which district has the largest activity fuels program would vary by alternative and the 

Proposed RMP.

Emissions from the BLM’s prescribed fires under the alternatives and the Proposed RMP would typically 

exceed those projected from wildfires burning on BLM-administered lands for both PM10 and PM2.5. The 

amount of the difference would vary by decade and by alternative or the Proposed RMP, with Alternative 

D having the smallest differences and Alternative C the largest differences. In more active wildfire

periods, the particulate emissions from wildfire would nearly equal or exceed those from prescribed fire. 

If the predicted increases in wildfire activity arising from climate change occur, as discussed in the 

Climate Change section in this chapter, particulate emissions from wildfires burning on BLMadministered lands would exceed those from the BLM’s prescribed fires more frequently later in the 50-

year analysis period.

Under all alternatives, and the Proposed RMP, the Medford District would produce the most emissions 

from prescribed burning (Figure 3-12), with the highest emissions under Alternative B and the lowest 

under Alternative A. Emissions under the No Action alternative and Alternative D would be similar, with 

emissions under the Proposed RMP about midway in the range of estimated emissions. The Roseburg 

District would produce its highest emissions under Alternative C and lowest under Alternative A. 

Between these two districts, in combination with expected emissions from wildfire, the greatest potential 

impacts to air quality in the planning area would occur in the Rogue River and Umpqua River valleys and 
161 | P a g e

their associated SSRAs, along with the Kalmiopsis Wilderness and Crater Lake National Park. Much of 

the activity for hazardous fuels burning consists of pile burning, which typically occurs in late fall and 

winter. In late fall, limited atmospheric instability in the afternoon and relatively frequent storms provide 

enough ventilation to limit smoke impacts during the day, but areas down-drainage from burn locations 

could experience smoke impacts at night due to increased atmospheric stability after sunset. Inversions in 

winter could result in prescribed fire smoke mingling with woodstove smoke to affect air quality 

adversely at all hours, although compliance with the Oregon Smoke Management Plan usually would 

limit degradation of air quality.

Figure 3-12. Average annual PM2.5 emissions from prescribed burning over the 50-year analysis period

The Klamath Falls Field Office would produce its highest emissions under Alternative A with similar 

emissions among all other alternatives and the Proposed RMP (Figure 3-12). Due to compliance with the 

Oregon Smoke Management Plan, potential effects to the Klamath Falls non-attainment area likely would 

not differ from those currently experienced.

Expected emissions from the Coos Bay District vary little between the alternatives indicating little 

difference in the expected human health impacts given compliance with the Oregon Smoke Management 

Plan requirements. Alternative C would have the highest expected emissions and the Proposed RMP the 

lowest (Figure 3-12). Emissions would be similar for No Action and Alternatives A and B, while 

emissions from Alternative D would be slightly higher than under the Proposed RMP.

Due to expected increases in harvest levels and the associated prescribed burning, emissions from the 

Eugene and Salem Districts would increase under all alternatives and the Proposed RMP, except for 

Alternative D in the Eugene District, relative to the current condition, with the biggest increases under 

Alternative C (Figure 3-12). Emissions under the Proposed RMP would be slightly higher than under 

Alternative B for the Eugene District and slightly lower for the Salem District. As a result, the probability 

of adverse impacts to SSRAs in the Willamette Valley would increase, likely due to unexpected wind 

shifts, although the overall probability would remain low. Increased burning on the Eugene District may 

99 180 198

340

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200

120

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Coos Bay Eugene Klamath Falls Medford Roseburg Salem
162 | P a g e

result in additional adverse impacts to air quality in Oakridge, although the combined effects of the 

location of BLM-administered parcels relative to Oakridge (greater than 10 miles to the west), 

compliance with the Oregon Smoke Management Plan, terrain, and the timing of burns relative to the 

timing of the worst air quality in Oakridge would keep the probability of such effects very low.

Visibility and Air Quality

Continued adherence to the Oregon Smoke Management Plan would limit adverse effects to visibility and 

air quality across all alternatives and the Proposed RMP, although some issues would likely remain in 

southwest Oregon where the efficacy of the new requirements as of 2014 have not yet been established. 

The increased amount of prescribed burning, particularly under Alternative C, may increase the risk of 

additional smoke intrusions into mandatory Class I areas, although past intrusions have not been 

correlated with the number of acres burned. At present, there are no factors that provide a clear indication 

that the increased prescribed burning under the alternatives or the Proposed RMP would result in 

additional effects on visibility and air quality from smoke intrusions as compared to the observed past.

The relative proportion of the landscape under some degree of active management can influence 

subsequent wildfires and the potential to affect human health and visibility adversely in summer. Because 

the BLM has no way to know whether and where planned vegetation management would intersect with a 

future wildfire, the estimated wildfire emissions in this analysis do not include any impact from forest 

management on potential wildfire emissions under any of the alternatives or the Proposed RMP over the 

analysis period. Active management, particularly where a primary objective is to alter fire risks, can 

reduce the potential for adverse impacts to human health and visibility from wildfires by increasing 

landscape diversity in terms of the mix of stand sizes, age classes, structure, and species compositions. 

Landscape heterogeneity tends to create burn pattern heterogeneity and can reduce the potential for large, 

homogeneous stand-replacing patches and long-term smoldering within large wildfires, especially in 

landscapes with active fire regimes (e.g., Mitchell et al. 2009, Miller et al. 2012, Loudermilk et al. 2014, 

and Volkova et al. 2014). Less active management under the current conditions has tended to create 

landscapes that are more homogeneous, particularly with respect to stand structure, promoting larger 

patches of similar burn severity, longer-term smoldering, and resulting emissions.

Effect of Emissions from BLM Prescribed Burning in the Context of 

All Sources

Particulate emissions from prescribed burning by the BLM would increase relative to the current 

condition under all alternatives and the Proposed RMP, including the No Action alternative. This increase 

in emissions arises from the increase in harvest levels compared to the harvest levels currently being 

implemented, thereby increasing the amount of activity fuel to treat. Currently, BLM prescribed burns 

produce 7.5 percent of both PM10 and PM2.5 total average annual emissions from all sources in the 

planning area. Under the No Action alternative, Alternative A, and Alternative D, the BLM’s average 

annual prescribed fire emissions would increase to approximately 12 percent for PM10 and 11 percent for 

PM2.5 of the total estimated emissions. Alternative C would produce the largest increase to an estimated 

17 percent and 16 percent of PM10 and PM2.5, respectively. The BLM’s prescribed fire emissions would 

increase to 14 percent and 13 percent of total PM10 and PM2.5, respectively, under Alternative B and the 

PRMP. Generally, the largest increase in BLM’s portion of particulate emissions would occur in the first 

decade, with a reduction in expected emissions in subsequent decades. Adherence to the Oregon Smoke 

Management Plan requirements and daily instructions issued by the Oregon Department of Forestry are 

explicitly designed to limit potential impacts to smoke sensitive receptors by limiting the amount of fuel 

burned on any given burn day and by maintaining adequate separation between burn units. As such, the 

BLM expects that the potential increases in emissions would have no additional impacts on human health 

under any alternative or the Proposed RMP.
163 | P a g e

Climate Change

Over time, climate change may result in a reversal of the trend in visibility and a worsening of air quality

in summer and fall, despite any actions taken or not taken by the BLM and with full compliance with the 

Oregon Smoke Management Plan. Many climate projections foresee longer fire seasons and more severe 

burning conditions, which would lead to more acres burned, increased fire severity (e.g., Mote et al. 2014 

and references therein), and greater particulate production over the life of such wildfires. One result 

would be an increase in the number of unhealthy days and reduced visibility in mandatory Class 1 areas. 

In addition, as the atmosphere warms, it holds more moisture; an increasing trend in relative humidity has 

already been documented in the United States (Walsh et al. 2014 and references therein). Certain 

pollutants are very responsive to even small increases in relative humidity, potentially degrading visibility 

with no change in pollutant level (Hand et al. 2011).

References

Hand, J. L., S. A. Copeland, D. E. Day, A. M. Dillner, H. Indresand, W. C. Malm, C. E. McDade, C. T. Moore, M. L. Pitchford, 

B. A. Schichtel, and J. G. Watson. 2011. Spatial and seasonal patterns and temporal variability of haze and its constituents in 

the United States: report V. Colorado State University, Cooperative Institute for Research in the Atmosphere, Fort Collins, 

CO.

Hardy, C. C., R. D. Ottmar, J. L. Peterson, J. E. Core, and P. Seamon, editors. 2001. Smoke management guide for prescribed 

and wildland fire 2001 edition. National Wildfire Coordination Group, Boise, ID.

http://www.fs.fed.us/pnw/pubs/journals/pnw_2001_ottmar001.pdf.

Loudermilk, E. L., A. Stanton, R. M. Scheller, T. E. Dilts, P. J. Weisberg, C. Skinner, and J. Yang. 2014. Effectiveness of fuel 

treatments for mitigating wildfire risk and sequestering forest carbon: A case study in the Lake Tahoe Basin. Forest Ecology 

and Management 323: 114–125. http://www.srs.fs.usda.gov/pubs/ja/2014/ja_2014_loudermilk_001.pdf.

Miller, J. D., C. N. Skinner, H. D. Safford, E. E. Knapp, and C. M. Ramirez. 2012. Trends and causes of severity, size, and 

number of fires in northwestern California, USA. Ecological Applications 22(1): 184–203.

http://www.fs.fed.us/psw/publications/skinner/psw_2012_skinner001.pdf.

Mitchell, S. R., M. E. Harmon, and K. 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): 643–655.

http://andrewsforest.oregonstate.edu/pubs/pdf/pub4540.pdf.

Mote, P. W., A. K. Snover, S. Capalbo, S. D. Eigenbrode, P. Glick, J. S. Littell, R. Raymondi, and S. Reeder. 2014. Chapter 21: 

Northwest. Pages 487–513 in J. M. Melillo, T. T. C. Richmond, and G. W. Yohe, editors. Climate change impacts in the 

United States: the third national climate assessment. U.S. Global Change Research Program, Washington, D.C.

Oregon Department of Environmental Quality (ODEQ). 2003. 2002 Oregon air quality data summaries. ODEQ Air Quality 

Division, Portland, OR.

---. 2009. 2008 Oregon air quality data summaries. Portland, OR.

---. 2012. 2011 Oregon air quality data summaries. Portland, OR.

---. 2013a. 2012 Oregon air quality data summaries. Portland, OR.

---. 2013b. Evaluation of prescribed fire contribution to Oregon Class I area 20% WD impacts. Portland, OR.

---. 2014. 2013 Oregon air quality data summaries. Portland, OR.

Oregon – DOF. 2014. Department of Forestry, Division 48 – Smoke Management. OAR 629-048-0001 through 629-048-0500. 

http://arcweb.sos.state.or.us/pp./rules/oars_600/oar_629/629_048.html.

USDI BLM. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, 

Oregon/Washington State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.

U.S. Environmental Protection Agency (EPA). 2013. 40 CFR 50-53, 58: National ambient air quality standards for particulate 

matter, Final Rule. Federal Register 78: 3085–3287.

Volkova, L., C. P. Meyer, S. Murphy, T. Fairman, F. Reisen, and C. Weston. 2014. Fuel reduction burning mitigates wildfire

effects on forest carbon and greenhouse gas emission. International Journal of Wildland Fire 23: 771–780.

http://dx.doi.org/10.1071/WF14009.

Walsh, J., D. Wuebbles, K. Hayhoe, J. Kossin, K. Kunkel, G. Stephens, P. Thorne, R. Vose, M. Wehner, J. Willis, D. Anderson, 

S. C. Doney, R. A. Feely, P. Hennon, V. Kharin, T. Knutson, F. Landerer, T. Lenton, J. Kennedy, and R. Somerville. 2014. 

Chapter 2: Our changing climate. pp. 19–67 in J. M. Melillo, T. T. C. Richmond, and G. W. Yohe, editors. Climate change 

impacts in the United States: the third national climate assessment. U.S. Global Change Research Program, Washington, 

D.C.
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Climate Change 

Key Points 

 Net carbon storage would increase under all alternatives and the Proposed RMP, with the largest 

increase under Alternative D and the least increase under Alternative C. 

 Annual greenhouse gas emissions associated with BLM-administered lands would increase under 

all alternatives and the Proposed RMP, with the largest increase under Alternative C and the least 

increase under Alternative D. Annual greenhouse gas emissions associated with BLMadministered lands would remain less than 1 percent of the 2010 Statewide greenhouse gas 

emissions. 

 Climate change provides uncertainty that reserves will function as intended and that planned 

timber harvest levels can be attained, with the uncertainty increasing over time. 

 Active management would provide opportunities to implement climate change adaptive strategies 

and potentially reduce social and ecological disruptions arising from warming and drying 

conditions. 

Summary of Notable Changes from the Draft RMP/EIS 

The BLM has refined the calculations of carbon storage and greenhouse gas emissions, including the 

following: 

 Removing the acreage in roads and water from the estimated carbon stored in soils 

 Correcting the number of acres affected by wildfire 

 Correcting the number of acres of expected underburning/broadcast burning 

 Removing unmodeled forest as a category and replacing it with non-forest estimates 

 Correcting the animal unit month values for the No Action alternative in the estimated 

greenhouse gas emissions 

These refinements in the calculations alter the absolute values in these calculations, but do not alter the 

relative outcomes of the alternatives and the Proposed RMP or the overall analytical conclusions. 

The BLM has corrected the values in Table 3-13 for carbon density; the Draft RMP/EIS erroneously 

provided carbon density data in terms of Mg/ha instead of Mg/acre. 

The BLM has added discussion and estimation of the effects of hazardous fuels treatments on net carbon 

storage and has expanded the discussion under Issues 1 and 2 of the cumulative effect of carbon storage 

and greenhouse gas emissions in the context of other actions. 

Issue 1 

What would be the effects of BLM forest management on long-term net carbon storage? 

Summary of Analytical Methods 

The BLM estimated changes in the amount of carbon stored on the landscape in vegetation and soils, and 

in harvested wood products. This analysis accounts for the removal of carbon through wildfire, prescribed 

fire, and timber harvesting and the addition of carbon through vegetation growth. As such, this analysis 
166 | P a g e

estimates changes in the net amount of carbon stored under the different alternatives and the Proposed 

RMP. 

The BLM estimated net carbon storage on BLM-administered lands in the planning area by first 

estimating the amount of biomass on these lands and converting that to the carbon in live trees, standing 

and downed dead wood, understory vegetation, litter and duff, and in the upper 1 meter (3.3 ft.) of soil, 

except where noted. The Planning Criteria provides detailed information on analytical assumptions, 

methods and techniques, and geographic and temporal scales, which is incorporated here by reference 

(USDI BLM 214, pp. 36–38). The volume harvested, whether part of the Harvest Land Base or reserves, 

drives the variation in carbon storage under the different alternatives and the Proposed RMP. 

The BLM assumed the following categories to be constant across all alternatives and the Proposed RMP: 

 Carbon stored in soils 

 Carbon stored in non-forested lands 

 Carbon loss from wildland fire 

The BLM assumed no carbon is stored under roads or in water, and reduced the landbase used for net 

carbon storage estimation accordingly. Although there is some carbon storage under roads or in water, 

there is no data available to quantify this storage. Furthermore, the carbon storage would not measurably 

differ among the alternatives and the Proposed RMP over time, and thus would not alter the relative 

outcomes under the alternatives or the Proposed RMP. 

Although the BLM used much of the analytical approach described in the Planning Criteria, the BLM 

modified the data source for aboveground carbon based on the actual outputs from the Woodstock model. 

Instead of using stand structure as the basis for estimating the amount of above-ground carbon, as 

described in the Planning Criteria, the BLM used approximate stand age in combination with the 

information available through the Carbon OnLine Estimator version 3.0 (COLE 3.0 2015) to estimate the 

amount of carbon stored in standing and downed dead wood, understory vegetation, the forest floor (litter 

and duff) and soil. Instead of using only two regions, the BLM filtered the COLE outputs to report carbon 

storage for all Federal lands in the counties in which the majority of each BLM district occurs. For 

example, the BLM used all Federal lands in Coos and Curry Counties as the basis for estimates for Coos 

Bay District. This approach allowed for estimates that were more refined and better captured the 

variability in carbon stored than using the two regions. The BLM used all Federal lands instead of all 

lands, as the data for private lands tended to be skewed towards younger age classes than are typically 

present on the Federal lands. Furthermore, the data for only BLM-administered lands lacked a sufficient 

number of the Forest Inventory and Analysis plots used by COLE to provide robust estimates. The 

Woodstock outputs did not specifically identify which cells were woodlands, so the BLM did not carry 

out this portion of the analysis as described in the Planning Criteria. Because wildfire was not included in 

the volume estimates for year 100, the BLM dropped that year from the analysis and added year 40, 

resulting in estimates for years 10, 20, 30, 40, and 50. Appendix G describes the carbon estimation 

method in further detail along with sources of uncertainty in the results. 

The quantified analysis of changes in net carbon storage directly or indirectly incorporates the effects of 

land management actions, including timber harvest, prescribed burning, activity fuels treatments, and 

silvicultural treatments under the alternatives and the Proposed RMP through the vegetation modeling. 

Carbon affected by timber harvest has four potential fates: 

 Removal from the site and processed into a wood product 

 Removal from the site and burned as firewood or for energy production at a mill 

 Retain on the site and burned in a fuels treatment 

 Retain on the site and allowed to decay 
167 | P a g e

The vegetation model accounted for the changes in net carbon storage from harvesting by reducing 

volume and affecting average stand age in the decade when timber harvest would occur. 

The quantified analysis of changes in net carbon storage under the alternatives and the Proposed RMP 

does not incorporate the effects of hazardous fuels treatments38 on net carbon storage, because it is not 

possible to estimate such effects on net carbon storage accurately and because the BLM assumes that the 

amount of hazardous fuels treatments would not vary among the alternatives and the Proposed RMP. 

There is insufficient information on where and when the BLM would need to implement hazardous fuels 

treatments and how much biomass the treatments would remove. The BLM does not collect or store data 

on pre- and post-treatment biomass for the hazardous fuels treatments. Hazardous fuel treatments are 

highly variable in terms of acres treated and treatment methods. Hazardous fuel treatments are also highly 

variable in terms of treatment effects on carbon storage: not all fuels treatment methods remove the 

harvest residue and its carbon as a direct effect of the treatment. Material from treatments such as lopand-scatter or mastication remains on site and decays naturally. Biomass removal, primarily for personal 

use firewood, currently accounts for only 4 percent of the acres treated under the hazardous fuels 

treatments, with an unknown amount of biomass affected. While biomass removal for commercial energy 

production may occur or increase in the future, currently low product value and high transportation costs 

means very few facilities have been built or planned within or near the planning area that would use forest 

residues as a fuel source, and none have been built that use forest residues as a primary fuel source. Since 

BLM cannot parameterize the stand conditions where the hazardous fuels treatments would occur, the 

BLM could not include hazardous fuels treatments in the vegetation model. 

The primary effect of hazardous fuels treatments on net carbon storage comes from prescribed burning of 

piled vegetation, underburns, or broadcast burns. Factors influencing the amount of carbon removed by 

burning include pile size, pile shape, number of piles per acre, and amount of fuel both available and 

combusted through underburns or broadcast burns. With an estimated 173,300 acres of pile burning, 

underburns, and broadcast burning per decade, the additional reduction in net carbon storage from the 

hazardous fuels program would be less than 1teragram39 of carbon (Tg C), or less than 1 percent, per 

decade. Because of the insufficient information about future hazardous fuels treatments, the high 

variability in the implementation of hazardous fuels treatments, and the high variability in the effects of 

hazardous fuels treatments on carbon storage, this estimation of the effects of hazardous fuels treatments 

under the alternatives and the Proposed RMP at this scale of analysis is of very low accuracy. The BLM 

includes this estimation here to give context to the magnitude of the potential effect of hazardous fuels 

treatments on net carbon storage. 

It is possible that hazardous fuels treatments (and other land management actions) could indirectly reduce 

the loss of new carbon storage resulting from wildfire by reducing the severity and extent of future 

wildfires. However, it is not possible to quantify any change in future wildfire effects resulting from 

hazardous fuels treatments (see the Fire and Fuels section in this chapter).

 

38 Hazardous fuel treatments are non-commercial treatments that are designed to reduce existing, natural fuel 

accumulations. In contrast, activity fuel treatments are designed to reduce fuel accumulations created by 

management actions such as timber harvest (see the Fire and Fuels section in this chapter). The BLM assumed in 

this analysis that implementation of hazardous fuels treatments would not vary by alternative and the Proposed 

RMP. However, activity fuel treatments would vary by alternative and the Proposed RMP, because the BLM would 

implement activity fuel treatments in response to fuels created by differing management actions. 

39 Scientific literature on carbon storage at this scale of analysis reports carbon amounts in metric tons, which are 

equal to approximately 2,205 pounds. One million metric tons equals one teragram. 
168 | P a g e

In addition to comparing the alternatives and the Proposed RMP, the BLM also considered two reference 

analyses as a means of providing additional context for the alternatives and the Proposed RMP: the No 

Timber Harvest Reference Analysis without wildfire (providing an estimate of potential carbon storage 

resulting from the vegetation growth) and the No Timber Harvest reference analysis with wildfire. 

Comparing these two reference analyses allowed the BLM to estimate the effect of this natural 

disturbance alone and then in conjunction with harvesting in the alternatives and the Proposed RMP. 

The quantified analysis of changes in net carbon storage under the alternatives and the Proposed RMP 

does not incorporate the potential effects on carbon storage from changing climate conditions. The 

vegetation modeling did not incorporate projections of climate change into the simulation of the growth 

of stands through time (see the Vegetation Modeling section in this chapter). Climate change would alter 

the absolute estimates of net carbon storage over time, but would not alter the relative outcomes under the 

alternatives and the Proposed RMP. Based on recent research, climate change would likely result in 

smaller increases in future carbon storage in the decision area than estimated in this analysis, though 

differences may not be apparent within the time frame of this analysis. Using a different analysis method 

than the carbon analysis in this Proposed RMP/EIS that accounted for changing climate, Diaz et al.

(2015) also found that net carbon storage in trees would increase on BLM-administered lands within the 

planning area until mid-century and then level off under lower emissions scenarios and decline under 

other emissions scenario. Creutzburg et al. (2016) found that climate change would slow expected carbon 

accumulation rates in the northern Coast Range by about 8 percent relative to a static climate, largely 

between mid-century and the end of the century, but that total carbon would continue to increase. Rogers 

et al. (2015), using three different climate models, found that in western Oregon and Washington, carbon 

storage would increase slightly under two of the models by the end of the century but decline 

substantially under the third model. 

Future carbon storage on BLM-administered lands could differ from these estimates if the use of biomass 

for energy increases substantially. Using harvest-generated residues for bioenergy is a common 

proposition to reduce emissions from burning fossil fuels and both greenhouse gas and particulate 

emissions associated with prescribed burning to remove such residues. Although such changes in biomass 

utilization are possible, they are not reasonably foreseeable at this time (see the Sustainable Energy 

section in this chapter). A recent study in the Panther Creek watershed in northwestern Oregon indicates 

that if both private forests and BLM-administered lands were to ‘capture’ such residues for bioenergy 

production, net carbon storage would decline by only 2–3 percent relative to conventional harvest 

methods (Creutzburg et al. 2016). Rotation length and the age at which no harvesting would occur on 

BLM-administered lands had the main effect on carbon storage in the watershed, which includes a mix of 

BLM-administered and private lands. This same study also found that longer rotations and less intensive 

management on Federal and non-corporate private lands could counterbalance shorter rotations and more 

intensive management on private lands (Creutzburg et al. 2016).

There are multiple sources of uncertainty in estimating the amount of carbon stored on the BLMadministered lands within the planning area, which are discussed in more detail in Appendix G. Although 

it is not possible to quantify all of the sources of error, the potential error in the estimate for any one 

alternative and the Proposed RMP likely exceeds the amount of variance among the alternatives and the 

Proposed RMP. The U.S. Forest Service estimated standard errors ranging from 20 percent to slightly 

over 50 percent, averaging around 33 percent, for their lands in western Oregon (USDA FS 2015). The 

BLM standard errors are likely similar, albeit on the higher end of this range, given the estimation 

methods used. 

Affected Environment 

The BLM-administered lands within the planning area currently store an estimated 360 Tg C (Table 3-

13). In the 2008 FEIS, BLM estimated current carbon storage at 427 Tg, using a similar but more 
169 | P a g e

simplified approach that relied primarily on regional averages (USDI BLM 2008, pp. Appendices – 28-

29). The type of data available in 2008 for estimating carbon storage did not allow the more detailed 

approach used in this analysis. 

Table 3-13. Estimated current total carbon stored in vegetation and soil and carbon density 

District/

Field Office Acres Total Carbon(Tg C)

Carbon Density

(Mg C/Acre)

Coos Bay 313,945 59 190

Eugene 300,736 60 198

Klamath Falls 210,386 9 41

Medford 782,524 93 119

Roseburg 408,680 63 155

Salem 385,806 76 196

Totals 2,402,076 360 -

The Medford District currently stores the most carbon, with an estimated 93 Tg C, largely due to the size 

of the district. The Klamath Falls Field Office stores the least, approximately 9 Tg C, largely due to the 

high proportion of non-forest plant communities within the Field Office boundaries and the small size of 

the Field Office. Approximately 6 Tg C is currently stored in products made from wood harvested from 

BLM-administered lands that are either still in use or are located in sanitary landfills where decay rates 

are minimal (Earles et al. 2012). In the 2008 FEIS, the BLM estimated carbon storage in landfills and 

wood products was 11 Tg C using an approach based on the assumed proportion of pulpwood to saw logs 

and estimates of the cumulative emissions of carbon over time by each type of product (USDI BLM 2008, 

pp. Appendices – 30). In this analysis, the BLM estimated carbon storage in landfills and wood products 

using a decay function derived from Earles et al. (2012) that consolidated the same type of information 

used in 2008 with estimates from the Oregon Department of Forestry on the annual board foot volumes 

harvested from BLM-administered lands within the planning area from 1965 through 2012. The 

combination of carbon stored on the districts and in wood products brings the total estimated carbon 

storage currently associated with BLM–administered lands in the planning area to 366 Tg C. 

Carbon density, the amount of carbon per acre, provides a comparable measure between the districts that 

reflects carbon storage capability and general productivity. The Coos Bay, Eugene, and Salem Districts 

are moderate in size but have a high carbon density (Table 3-13). The Medford District has the largest 

acreage of BLM-administered lands of the administrative units in the decision area, and has the largest 

amount of total carbon storage, but has the second lowest estimated carbon density. The Klamath Falls 

Field Office has the smallest acreage of BLM-administered lands of the administrative units in the 

decision area and has the lowest carbon density. 

Environmental Consequences 

Timber harvest volume removed is the primary driver of differences across the alternatives and the 

Proposed RMP in net carbon storage on BLM-administered lands in the planning area, although a portion 

of the material harvested remains stored for up to 150 years in the form of wood products in use or in 

sanitary landfills (Earles et al. 2012). Comparing the No Timber Harvest reference analysis without fire to 

the No Timber Harvest Reference Analysis with fire indicates that wildfire reduces estimated net carbon 

storage by 0.4–0.7 percent across the planning area through 2063, varying by decade. For the Coos Bay, 

Eugene, and Salem Districts, and the Klamath Falls Field Office, the estimated reduction would be 

generally less than 0.3 percent of the net carbon stored on those Districts. On the Roseburg District, the 

reduction would be highly variable, ranging from as little as 0.12 percent to as high as nearly 3 percent. 
170 | P a g e

The expected reduction on the Medford District would be less variable, ranging from 1 to 2 percent, given 

that approximately 82.5 percent of the acres burned are predicted to occur on that district.

All alternatives and the Proposed RMP, including the No Action alternative, would increase net carbon 

storage over time relative to the current condition (Figure 3-13 and Figure 3-14). Differences among the 

alternatives and the Proposed RMP, and in comparison to the No Timber Harvest Reference Analysis 

with fire, would be minor until around 2033, and afterwards would become increasing apparent. Although 

Alternative D has the second largest Harvest Land Base of the alternatives and the Proposed RMP, the 

volume removed per acre would be low due to the overall approach to timber management (see the Forest 

Management section in this chapter). Alternative D would store the most net carbon, followed, in order, 

by Alternative A, the Proposed RMP, Alternative B, No Action, and Alternative C. The differences in net 

storage among the Proposed RMP, Alternative A, and Alternative B would be quite small. Carbon stored 

in wood products would range from an estimated 5 to 10 Tg, depending on alternative and the Proposed 

RMP and decade.

Figure 3-13. Estimated carbon storage over time by alternative and the Proposed RMP40

 

40 The 2013 value for the Proposed RMP is slightly less than the alternatives, because the BLM has updated current 

vegetation baseline information to incorporate the effects of the 2013 and 2014 fire seasons (see the Analytical 

Methodologies and Assumptions section of this chapter).

0

100

200

300

400

500

600

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Net Carbon Storage (Teragrams)

2013 2023 2033 2043 2053 2063
171 | P a g e

Figure 3-14. Change in carbon storage relative to the estimated total storage as of 2013

All alternatives and the Proposed RMP would increase net carbon storage, but not as much as under the 

No Timber Harvest reference analysis with wildfire (Figure 3-15). The difference in the increase in net 

carbon storage occurs as harvesting removes carbon and shifts stand characteristics, such as mean 

diameters and heights, in more of the landscape to smaller trees and younger age classes that store less 

carbon. Since Alternative C would harvest the most volume over time and would have the highest 

percentage of the landscape in younger age classes dominated by smaller trees, relative to the No Timber 

Harvest reference analysis, it would have the lowest increases in net carbon storage. After 2033, the 

Proposed RMP would store slightly less carbon than Alternative A, and slightly more carbon than 

Alternative B.

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

2023 2033 2043 2053 2063

Net Carbon Storage (% Change)

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest
172 | P a g e

Figure 3-15. Percent reduction in aboveground carbon storage from timber harvest relative to projected 

carbon storage in the No Timber Harvest reference analysis with wildfire

Effect of Net Carbon Storage on BLM-administered Lands in the 

Context of Other Lands

Placing carbon storage on BLM-administered lands in context of other lands in the planning area is 

difficult due to the nature of the data available, which is variable in extent of geographic coverage, in 

assessment dates, and in the carbon pools assessed. The most recent published statewide assessment 

covered live and dead trees and downed wood measured between 2001 and 2005, but does not include all 

carbon pools (Donnegan et al. 2008). In that assessment, all the forests in Oregon, including juniper 

woodlands, store an estimated 1,215 Tg C in live and dead trees and downed logs and large branches. 

That assessment concluded that U.S. Forest Service lands, privately owned lands, and the BLMadministered lands store 56.7, 23.3, and 11.8 percent of the statewide total, respectively. The estimated 

statewide total for all BLM-administered lands (which includes BLM-administered lands outside of the 

decision area) of 144 Tg C as of 2005 is considerably less than the BLM estimated in either the 2008 

FEIS analysis or in this analysis for western Oregon. Other Federal lands, State and local government 

lands, Tribal lands, and other private lands stored the remaining 8.4 percent, with slightly over half of that 

amount on State forests.

The U.S. Forest Service has also estimated the amount of carbon stored in all pools (live and dead trees, 

downed wood, litter and duff, and the top meter of soil) for all U.S. Forest Service lands in 2013, 

providing a basis of comparison with BLM-administered lands in the decision area. The BLM obtained 

the data for the Fremont, Mt. Hood, Rogue River-Siskiyou, Siuslaw, Umpqua, and Willamette National 

Forests to compare with the BLM estimates above. The BLM-administered lands (which constitute 34.8 

percent of the acreage of U.S. Forest Service lands) stored approximately 39.4 percent of the amount of 

carbon stored on U.S. Forest Service lands;41 that is, carbon is stored on BLM-administered lands at 113.3 

percent of the density as on U.S. Forest Service lands (Table 3-14).

 

41 This comparison does not account for the effects of wildland fires in 2013 and 2014, which affected both BLMadministered lands and U.S. Forest Service lands.

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

2023 2033 2043 2053 2063

Net Carbon Stored (% Reduction)

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP
173 | P a g e

Table 3-14. Estimated carbon storage and carbon density for the major land ownerships in western 

Oregon

Land Owner/

Manager

Assessment 

Period

Total Carbon*

(Tg C) Acres Carbon Density(Mg C/Acre)

BLM 2013 361 2,402,076 150.4

U.S. Forest Service 2013 916 6,900,020 132.8

State of Oregon 2001–2010 96 789,610 122.0

Private Landowners 2001–2010 559 6,614,392 34.2

* Does not include carbon stored in wood products still in use or in landfills

Based on data from 2001 through 2010, forests managed by the state of Oregon in western Oregon have a 

slightly lower carbon density than the U.S. Forest Service lands (Gray 2015, personal communication; 

Table 3-14). This lower carbon density may be due to the amount of area in younger forests, such as the 

Tillamook State Forest, even though most of the State forestlands are located in the highly productive 

Coast Range or at similar elevations as the BLM-administered lands in the Cascade Range. Although 

private forestlands in western Oregon store a large amount of carbon and encompass an area similar in 

size as U.S. Forest Service lands, they have the lowest carbon density (Gray 2015, personal 

communication, Table 3-14), likely due to the predominance of intensively managed forests, which the 

owners typically manage on a 40- to 60-year rotation.

Carbon storage increased on the western Oregon U.S. Forest Service lands by approximately 1.73 Tg/yr 

between 1990 and 2013, despite the decreases on the Siskiyou National Forest and the apparent 

stabilization on the Rogue River National Forest (USDA FS 2015). Gonzalez et al. (2015) reported that

forest ecosystems in California lost carbon between 2001 and 2010, which they attributed principally to 

recent large wildfires in northern California and the Sierra Nevada Mountains. Southwest Oregon may be 

experiencing a similar effect given the high similarity in forest types with northern California and recent 

increases in area burned. The BLM does not know whether the BLM-administered lands in southwest 

Oregon (primarily Medford and Roseburg Districts) are experiencing the same loss or stagnation in 

carbon storage given the lack of long-term annual carbon data.

Carbon storage on BLM-administered lands in the decision area likely increased by a similar amount 

given the similarity in management between the BLM and the U.S. Forest Service over that period. The 

BLM estimated net carbon storage would increase by a low of 1.5 Tg/yr under Alternative C to a high of 

2.7 Tg/yr under Alternative D. Under the Proposed RMP, carbon sequestration would average 2.3 Tg/yr 

over the next 50 years. However, these estimates do not account for potential sources of mortality other 

than fire and potential increases in wildfire occurrence, size, or severity that might reduce that 

sequestration rate. The expected increase in net carbon storage as well as other forest management actions 

(see the Forest Management section in this chapter) under all alternatives and the Proposed RMP supports 

the Oregon interim strategy for reducing greenhouse gas emissions, although to what degree is not known 

since the State has not established specific carbon storage goals (OGWC 2010, 2013).

Issue 2

What would be the BLM’s expected contribution to greenhouse gas emissions from vegetation 

management activities such as timber management and prescribed burning?
174 | P a g e

Summary of Analytical Methods 

In this issue, the BLM estimated the gross greenhouse gas emissions from timber harvest, prescribed 

burning, wildfires and livestock grazing. These estimates are the direct emissions for all greenhouse gases 

emitted through natural processes (carbon dioxide, methane, and nitrous oxide). The carbon analysis 

under Issue 1 accounts for the carbon losses from fire and timber harvest by evaluating changes in net 

carbon storage. This analysis includes all greenhouse gases, including those that lack carbon (nitrous 

oxide), and all relevant sources of emissions, including those that do not directly affect net carbon 

storage. Because methane and nitrous oxide have higher global warming potential than carbon dioxide, 

the BLM followed global and national standards by reporting greenhouse gas emissions as carbon dioxide 

equivalents (CO2e). One methane molecule effectively equals 25 carbon dioxide molecules and one 

nitrous oxide molecule effectively equals 298 carbon dioxide molecules. 

Greenhouse gas emissions from BLM management activities that are most likely to be substantial and to 

vary among alternatives and the Proposed RMP are timber harvesting, grazing, and prescribed burning. A 

wide variety of BLM activities produce greenhouse gases, but the absence of reliable data limits the 

BLM’s ability to estimate emissions. For example, BLM-authorized mining operations are a source of 

greenhouse gases, but there is no data on which to base estimates of emissions from this sector, 

particularly since mining operations within the decision area currently involve salable and locatable 

minerals only (USDI BLM 2013, pp. 57–58). The BLM has no information on the type of equipment used 

for mining or for how long (see also the Minerals section in this chapter). The BLM could not locate any 

general information on greenhouse emissions from mining other than for coal; coal mining does not occur 

within the planning area. 

The BLM estimated greenhouse gas emissions for each alternative and the Proposed RMP, expressed in 

the form of carbon dioxide equivalent (CO2e), using projected timber harvest, permitted levels of grazing, 

and prescribed burning. The Planning Criteria provides more detailed information on analytical 

assumptions, methods and techniques, and geographic and temporal scales, which is incorporated here by 

reference (USDI BLM 2014, p. 38). The BLM changed the method for this analysis from what was 

described in the Planning Criteria by providing a greenhouse gas emission for year 40 and by not 

estimating emissions past year 50, since that was the last year for which the BLM modeled wildfire. 

The BLM estimated emissions from timber harvest by converting the estimates of board feet harvested to 

cubic feet and applying the emissions factor listed in the Planning Criteria (USDI BLM 2014, p. 38). The 

BLM estimated methane emissions from public lands grazing using the emission factor described by the 

Intergovernmental Panel on Climate Change (Eggleston et al. 2006). Instead of the emission factor listed 

in the Planning Criteria for prescribed fires, the BLM used estimated emissions from Consume 4.2 for 

carbon dioxide and methane and the emission factor provided by the Environmental Protection Agency 

for burning wood and wood products as a stationary source for nitrous oxide (EPA 2014a, Table 1) as the 

BLM believes these emission estimation methods are more accurate than the single emission factor 

initially proposed in the Planning Criteria. To provide context for the emissions from harvesting and 

prescribed burning, the BLM also estimated greenhouse gas emissions from wildfires. The BLM used a 

combination of wildfire records, fuelbeds from the Fuels Characteristic Class System (FCCS) version 3.0, 

and emissions estimates from Consume 4.2 to estimate emissions from wildfires. Appendix G details the 

estimation methods and associated uncertainties. 

This analysis may overestimate greenhouse gas emissions from both prescribed fire and wildfire. At least 

some of the carbon produced by wildland fires is deposited as pyrogenic organic matter, also known as 

charcoal, biochar, and black carbon, instead of being emitted into the atmosphere (Lehmann et al. 2006, 

Sohi et al. 2010, Santín et al. 2015). The amount of biochar produced depends on fire intensity (Nocentini 

et al. 2010, Sohi et al. 2010, Santín et al. 2012) and lignin content (Lehmann et al. 2006, Makoto et al. 
175 | P a g e

2011). Biochar produced by wildland fire can persist in soils for several hundred to several thousand 

years (e.g., Spokas 2010, Sohi et al. 2010, Criscuoli et al. 2014, Santín et al. 2015, and Wang et al. in 

press), providing storage instead of emission. Factors governing the durability of biochar in the soil 

include soil texture (Pingree et al. 2012 and references therein), particle size (Nocentini et al. 2010), the 

oxygen to carbon ratio in the particles (Spokas 2010), and fire frequency (Nocentini et al. 2010, Pingree 

et al. 2012). Estimates of the amount of biochar produced vary widely, however, ranging from 1 to 28 

percent of the above ground biomass (Lehmann et al. 2006, Sohi et al. 2010, Pingree et al. 2012, Santín et 

al. 2015), making any attempt to estimate this potential reduction in greenhouse gas emissions highly 

uncertain. 

Background 

Globally, atmospheric carbon dioxide (CO2) concentrations have increased from an estimated 277 ppm 

(parts per million) before 1750 to 395.31 ± 0.1 ppm in 2013, the highest level in the last 800,000 years 

according to the Global Carbon Project (2015). Preliminary estimates indicate global atmospheric CO2

concentrations reached 397.15 ppm in 2014. According to CO2Earth.org (2015), monthly atmospheric 

CO2 concentrations surpassed the 400 ppm benchmark during April through June of 2014 and February 

through July of 2015 at the Mauna Loa Observatory. Carbon dioxide is the primary greenhouse gas, 

comprising over 80 percent of total emissions globally, as well as in both the U.S. and Oregon. Fossil fuel 

combustion is the primary source of CO2 (McConnaha et al. 2013, Le Quéré et al. 2014, 2015; EPA 

2014b, 2015). United States emissions of greenhouse gasses (6,673 Tg CO2e) were 14 percent of global 

emissions (~ 47,664 Tg CO2e) in 2013 (Le Quéré et al. 2015; EPA 2015). In 2010, the latest year in 

which data are available, Oregon’s emissions were about 1 percent of the U.S. emissions (McConnaha et 

al. 2013, EPA 2014b). Globally, ocean and land greenhouse gas sinks removed about 50 percent of that 

emitted in 2013 (Le Quéré et al. 2015). Land sinks in the U.S. effectively reduced total greenhouse gas 

emissions by 13.2 percent nationally in 2013, with forests and wood products accounting for about 11.5 

percent (EPA 2015). The forests of western Oregon sequester more carbon per acre than the national 

average (Joyce et al. 2014, Figure 7.5). 

Several scientific studies have concluded that greenhouse gas emissions from human activities are driving 

relatively rapid climate change (IPCC 2013 and references therein). Under the current state of the science, 

however, the BLM cannot identify the impacts of greenhouse gas emissions from any one project or 

program, or from its activities in western Oregon on global, national, or even local climate. In 2004, the 

state of Oregon released its statewide strategy for greenhouse gas reductions. Oregon’s goal is to reduce 

statewide greenhouse gas emissions to at least 75 percent below 1990 levels by 2050, or to approximately 

15 Tg CO2e (ODOE 2004). To achieve this goal the State strategy calls for increased energy conservation, 

increased energy efficiency among natural gas and oil users, increased efficiency in transit and 

alternatives to driving cars and trucks, primarily in urban areas along the I-5 corridor, increased use of 

products that use less energy to produce and are designed for reuse or easy recycling, replacing fossil 

fuels with alternative energy sources, and increasing carbon capture and storage in forests and farms 

(ODOE 2014). Of these elements, BLM-administered lands would support this strategy through increased 

carbon capture and storage in forests. 

Affected Environment 

Total estimated greenhouse gas emissions from timber harvest, grazing, and prescribed fire on BLMadministered lands within the planning area averaged 122,398 Mg CO2e/yr over the past 19 years (1995–

2013) (Figure 3-16), or about 0.2 percent of Oregon’s in-boundary42 2010 emissions (McConnaha et al.

2013). Prescribed fires emitted about 90 percent of the BLM management-related greenhouse gases. In 

contrast, average emissions from wildfires that originated on BLM-administered lands were 

 

42 In-boundary emissions are those that occur within Oregon’s borders and emissions associated with electricity use 

within Oregon. 
176 | P a g e

approximately 69,636 Mg CO2e/yr or about 36 percent of all greenhouse gas emissions originating on 

BLM-administered lands within the planning area over the past 19 years (Figure 3-16). Prescribed fires 

emitted more greenhouse gases, on average, than wildfires over this time period. Emissions for any one 

year varied widely, largely depending on the amount of prescribed fire and wildfire, although emissions 

from prescribed fires varied much less than those from wildfires. 

Figure 3-16. Proportion of estimated greenhouse gas emissions from livestock grazing (enteric 

fermentation), timber harvest operations, prescribed fires, and wildfires on BLM-administered lands 

within the planning area 

The estimate of current greenhouse gas emissions for BLM-administered lands within the planning area 

represents the actual level of activity. This is in contrast to the analysis of the No Action alternative in the 

following section, which projects future implementation of 1995 RMPs as written. Actual harvest levels 

and grazing have been below what the 1995 RMPs anticipated (USDI BLM 2013). Therefore, prescribed 

burning of activity fuels created by harvesting activities is generally less than what was anticipated in 

1995, but prescribed burning of so-called natural fuels, or hazardous fuels, under the National Fire Plan 

(USDA FS and USDI BLM 2000) has partially compensated for the reduction in activity fuels burning. 

The National Fire Plan increased funding for hazardous fuels reduction beginning in 2001. 

The available data do not indicate how much of the prescribed burning was activity fuel reduction and 

how much was hazardous fuels reduction. The BLM explicitly designs the hazardous fuels reduction 

program to reduce potential fire behavior and effects and, hence, greenhouse gas emissions from 

wildfires. While the BLM does not design silvicultural treatments to reduce hazardous fuels, many 

treatments serve to do that as a secondary benefit of enhancing tree growth on the remaining trees (see 

also the Fire and Fuels section for additional analysis and references). Many studies also demonstrate that 

Enteric 

Fermentation

1%

Harvest 

Operations

5%

Prescribed Fire

58%

Wildfire

36%

Greenhouse Gas Emissions

(Mg CO2e/year)
177 | P a g e

reducing the fuels created by any forest vegetation treatment, regardless of the primary purpose of the 

treatment, is essential to reducing potential wildfire behavior and effects and resulting greenhouse gas 

emissions (e.g., Pritchard et al. 2010, Lyons-Tinsley and Peterson 2012, Safford et al. 2012, and Shive et 

al. 2013). 

The BLM is a relatively small emitter of greenhouse gases from harvest operations and prescribed fire 

within the planning area (Figure 3-17, the Other Federal category is largely BLM). Management on 

private forests and on U.S. Forest Service lands each result in greater emissions. In large part, these 

differences reflect the differences in land base and, in the case of private forests, management intensity. 

Prescribed fire emissions in private forests are largely due to clean up of harvest-generated residue 

(activity fuels), whereas a portion of the prescribed fire emissions from U.S. Forest Service lands and 

BLM-administered lands arises from the hazardous fuels reduction program in both agencies under the 

National Fire Plan. 

Figure 3-17. Proportion of estimated greenhouse gas emissions from (a) timber harvest and (b) prescribed 

burning by different entities 

Trends in emissions are more difficult to ascertain. Emissions from grazing on BLM-administered lands 

within the planning area have very slightly declined since 1995, as more allotments became vacant and 

the amount of active use declined. No trend is evident in wildfire emissions due to very high interannual 

variability in the acres burned on BLM-administered lands over the period of record (1980–2013). 

Although interannual variability in emissions from harvest operations and prescribed burning is also high, 

some trends are apparent. Harvesting on private forests reflects current economic conditions, particularly 

in the housing market. During the recent housing boom, harvesting and the resulting greenhouse gas 

emissions from private land harvesting increased from the late 1990s until 2007. Between 2007 and 2009, 

emissions declined sharply, reflecting the economic downturn, which had a substantial impact on housing 

demand and lumber. This same effect on greenhouse gas emissions was also apparent nationally (EPA 

2014b). Since 2009, harvesting levels and associated emissions have recovered to pre-recession levels. In 

contrast, harvesting levels and resulting emissions have been slowly increasing on both BLMadministered and U.S. Forest Service lands since 2001, with a slightly higher trend on the U.S. Forest 

Service lands. 

84%

7%

4%

5%

Private

State

BLM

Forest Service

A.

74%

3%

8%

15%

Private

State

Other Federal

Forest Service

B. 
178 | P a g e

The trends in emissions from prescribed burning do not track the trends in emissions from harvesting 

operations. On private forests, emissions from prescribed burning have fallen since about 2006, even 

when harvest levels have risen. Whether the continued fall represents a lag between time of harvest and 

time of site preparation, a reduction in activity fuels due to higher utilization, or a shift in how the land 

managers handled activity fuels is unknown. Fluctuations in emissions from prescribed burning on BLMadministered lands and the U.S. Forest Service lands within the planning area may reflect a combination 

of higher utilization and fluctuations in the hazardous fuels program. Since 2009, prescribed fire 

emissions from U.S. Forest Service lands have risen slowly, while emissions have fallen slowly on BLMadministered lands. 

Environmental Consequences 

As with particulate emissions (see the Air Quality section of this chapter), the amount of activity fuels 

prescribed burning is the primary factor driving the differences between alternatives and the Proposed 

RMP and over time. Greenhouse gas emissions from BLM activities would increase substantially relative 

to the estimate of current actual emissions under all alternatives and the Proposed RMP, with the 

exception of Alternative D (Figure 3-18 and Figure 3-19). This increase would be largely due to the 

amount of prescribed burning that would occur in conjunction with harvesting. Alternative C would result 

in the largest increases. However, even the highest projected emissions under Alternative C would remain 

less than 1 percent of Oregon’s 2010 in-boundary greenhouse gas emissions and approximately 0.0008 

percent of total U.S. greenhouse gas emissions in 2012 (EPA 2014b, Figure ES-1). Greenhouse gas 

emissions under Alternative B would be the second highest of all alternatives and the Proposed RMP. The 

Proposed RMP and Alternative A would result in similar emissions, lower than Alternative B and the No 

Action alternative. Alternative D would result in the lowest emissions of all alternatives. 

The BLM has considered measures that would reduce or avoid increases in greenhouse gas emissions 

above current levels. The current implementation of the timber management program is not consistent 

with the 1995 RMPs as written (see the Purpose and Need for Action section in Chapter 1; current 

implementation has been predominately thinning, and the current practices are not sustainable at the 

declared timber harvest levels (see the Alternatives Considered but not Analyzed in Detail section of 

Chapter 2). The current level of greenhouse gas emissions is substantially lower than the emissions that 

this analysis shows would result from implementation of the No Action alternative. The level of 

sustained-yield timber production and associated prescribed burning generally would reflect the level of 

greenhouse gas emissions. Any alternative that would provide a sustained yield of timber and restore fireadapted ecosystems would necessarily result in increases in greenhouse gas emissions above current 

levels. The alternatives and the Proposed RMP would result in varying amounts of increase in greenhouse 

gas emissions above current levels. However, it would not be possible to avoid increases in greenhouse 

gas emissions above current levels and meet the purposes of the action. 
179 | P a g e

Figure 3-18. Estimated average annual greenhouse gas emissions from the combination of timber harvest, 

grazing, and prescribed fire 

Note: Variation in activity fuels prescribed fire levels causes most of the fluctuation in expected emissions between 

decades. 

Figure 3-19. Projected increases in average annual greenhouse gas emissions from timber harvest, 

grazing, and prescribed burning relative to average annual emissions as of 2013 

Effect of Greenhouse Gas Emissions from BLM-administered Lands 

in the Context of Other Sources 

Placing BLM’s greenhouse gas emissions in a statewide or national context is difficult for the same 

reasons as discussed above for carbon storage. In addition, greenhouse gas emissions are rarely estimated 

for the forestry subsector alone. The EPA groups emissions from forestry operations into the agricultural 

sector. In 2013, national emissions from the agricultural sector were 586.8 Tg CO2e, or 8.8 percent of 

total U.S. emissions. Land use and forestry emissions accounted for 1.9 percent of agricultural emissions, 

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

CO2e (Megagrams)

2013 2023 2033 2043 2053 2063

0%

50%

100%

150%

200%

250%

2023 2033 2043 2053 2063

Average Annual GHG 

Emissions (% Increase)

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP
180 | P a g e

or 10.9 Tg CO2e (EPA 2015). Data for the state of Oregon does not include an estimate of emissions from 

land use and forestry. 

The 2013 estimate for BLM’s greenhouse gas emissions are 0.2 percent of the U.S. 2013 estimate for the 

agriculture sector. The BLM greenhouse gas emissions through 2063 would range from 0.3 to 0.7 percent 

of the U.S. 2013 estimate for the agricultural sector. Greenhouse gas emissions for each alternative and 

the Proposed RMP would fluctuate over the assessment period, depending on the extent of timber harvest 

and subsequent prescribed burning. Greenhouse gas emissions from timber harvest operations would be a 

higher proportion of BLM total emissions than they are in the national emissions, ranging from as low as 

4.2–5.4 percent under Alternative D to as high as 8.6–9.4 percent under Alternative C. Under the 

Proposed RMP, harvest emissions would account for between 5.2–6.4 percent of BLM’s expected total 

greenhouse gas emissions. The BLM emissions differ from the national emissions for the agricultural 

sector in that livestock and crop cultivation produced 90 percent of the national emissions whereas 

prescribed burning is expected to produce 90–96 percent of the emissions from BLM, depending on the 

alternative and decade. 

The BLM also compared how the relative proportions of greenhouse gas emissions would change for 

harvesting and prescribed fire assuming no change in the emissions from private forest owners, the State 

of Oregon, and other Federal agencies, using average annual estimates over the entire analysis period (50 

years). The BLM’s proportion of annual harvesting-related greenhouse gas emissions would increase 

from about 4 percent of the western Oregon estimate to a low of 5 percent per year under Alternative D 

and a high of 14 percent per year under Alternative C. The Proposed RMP annual harvesting greenhouse 

gas emissions would approximately double to an estimated 8 percent of western Oregon harvesting 

emissions, or 0.02 Tg CO2e per year on average. The BLM’s proportion of greenhouse gas emissions 

from prescribed burning would increase from approximately 8 percent per year of the western Oregon 

total to a low of 15 percent per year under Alternative D and a high of 20 percent per year under 

Alternative C. The Proposed RMP prescribed fire greenhouse gas emissions would increase to 17 percent 

of the western Oregon prescribed fire emissions, or 0.28 Tg CO2e per year, on average. 

Issue 3 

How would climate change interact with BLM management actions to alter the potential outcomes for key 

natural resources? 

Summary of Analytical Methods 

In this analysis, the BLM considered both how climate change would introduce uncertainty into outcomes 

described in other sections of this chapter and how the alternatives and the Proposed RMP might allow 

the BLM to undertake actions to adapt to climate change during plan implementation. The BLM 

described current and projected climate trends and analyzed how these trends could affect the resources 

described in other sections. The BLM then considered the extent to which the alternatives and the 

Proposed RMP would allow BLM to consider actions that promote adaptation to climate change during 

the implementation of the RMP. 

The potential climate change impacts of most concern to the BLM are the indirect effects of changes in 

temperature, precipitation, and snow within the planning area, as these factors affect forest productivity 

and species composition, habitat for terrestrial and aquatic wildlife, and key disturbance regimes. This 

analysis focuses on the possible impacts to tree species composition and growth, fire regimes, insect 

outbreaks, certain diseases such as Sudden Oak Death and Swiss needle cast, stream flow and temperature 
181 | P a g e

in the context of fish habitat, and habitat for old growth-associated species such as northern spotted owl

and marbled murrelet.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 39–40). The existing analyses in the NatureServe Climate Change Vulnerability Index website 

(2014) did not include any species of birds, fish, or mammals relevant to BLM-administered lands in the 

planning area as of September 3, 2014. The bulk of this analysis consists of a review and synthesis of key 

literature.

To assess observed changes in climate, the BLM elected to use temperature and precipitation data 

available through WestMap (2014), a tool developed by the Desert Research Institute, extracting the data 

by three hydrologic units: the Willamette River basin, Oregon coastal basins, which include southwest 

Oregon, and the Klamath River Basin. Data for the Klamath River basin includes northern California. 

Data extracted included precipitation, average temperature, average maximum temperature, and average 

minimum temperature, both annually and seasonally. The BLM used the water year (October 1 to 

September 30) for the annual basis and meteorological/climatological seasons (winter = December to 

February, spring = March to May, summer = June to August, and fall = September to November). The 

BLM imported the data into Excel spreadsheets, summarized, and conducted linear trend analyses using 

Sigma Plot 12.3. The BLM considered the results statistically significant at P-values of 0.05 or less. The 

BLM also extracted snow course data from the Natural Resources Conservation Service website (NRCS

2014) and evaluated long-term trends in April 1 snow water equivalent using an Excel spreadsheet. The 

BLM did not analyze these data for statistical significance.

Background

Global assessments of climate over time have increased the certainty that climate is changing and that 

humans are a primary cause of that change through emissions of greenhouse gases, carbon dioxide in 

particular (IPCC 2013). According to the latest assessment from the Intergovernmental Panel on Climate 

Change (IPCC) global temperatures have increased by 1.53 oF since 1880; the number of cold days and 

nights have decreased while the number of warm days and nights have increased; the frequency and 

intensity of heavy precipitation events have increased in North America and Europe; glaciers, sea ice, 

major ice sheets, and spring snow cover continue to shrink; and atmospheric concentrations of carbon 

dioxide, methane, and nitrous oxide exceed those of the last 800,000 years (IPCC 2013).

The latest national assessment for the United States affirms these same general trends. Average 

temperature in the United States has increased 1.3 to 1.9 oF, with most of this increase since 1970. The 

year 2012 was the warmest year on record. The length of the frost-free season has decreased and the 

subsequent growing season increased; heavy downpours have increased in frequency over the last three to 

five decades; heat waves are more frequent and intense, while cold waves are less frequent and less 

intense; winter storms have increased in frequency and intensity since the 1950s, and the general track has 

shifted northward; glaciers and snow cover are shrinking (Walsh et al. 2014).

The Pacific Northwest (Oregon, Washington, Idaho, and western Montana) has experienced many of the 

changes noted globally and nationally. The Pacific Northwest has warmed by 1.3 oF since 1895, with 

statistically significant warming in all seasons except spring, lengthening the frost-free period by 35 days 

(Snover et al. 2013, Abatzoglou et al. 2014). Spring precipitation has increased while summer and fall 

precipitation have decreased; with increasing potential evapotranspiration, the climatic water deficit has 

also increased (Abatzoglou et al. 2014). The frequency of extreme high nighttime temperatures has 

increased, with a statistically significant increase west of the Cascade Mountains; however, no clear 

change in other temperature extremes has emerged (Dalton et al. 2013, Snover et al. 2013). Annual 

precipitation has no clear trend either upward or downward, with high interannual variability (Snover et 
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al. 2013). Although annual snowpack also fluctuates widely, snow accumulation is generally declining, 

and spring snowmelt is occurring earlier, leading to an earlier peak in streamflow in snowmelt-influenced 

streams (Snover et al. 2013). 

Affected Environment 

Three different climate types characterize the planning area: maritime, Mediterranean, and continental. 

The Coos Bay, Eugene, and Salem Districts have a maritime climate, typified by relatively cool, moist 

conditions year-round, although the Willamette Valley can be quite warm and dry in summer. The 

western portion of the Klamath Falls Field Office and the Medford District have a Mediterranean climate, 

characterized by cool to warm, moist conditions in winter and hot, dry conditions in summer. The eastern 

portion of the Klamath Falls Field Office has a continental climate, with cold, dry winters and hot, dry 

summers. The Roseburg District encompasses a transition zone between the Mediterranean and maritime 

climates, with no clear demarcation between the two climate types. 

Based on the WestMap data, annual precipitation increased slightly in the Willamette River, Oregon 

Coastal and Klamath River basins since 1896, and in some seasons, although the increases were not 

statistically significant (Figure 3-20). The one exception is a statistically significant increase in spring 

precipitation in the Willamette River and Klamath River basins. All basins show a statistically nonsignificant decline in fall precipitation, and the Oregon coastal basins have a statistically non-significant 

decrease in winter precipitation. 

-2

-1

0

1

2

3

4

5

Annual Winter Spring Summer Fall

Changes in Precipitation (Inches)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

Figure 3-20. Observed changes in annual and seasonal precipitation by basin 

Note: A star indicates change is statistically significant; Annual = October 1–September 30, Winter = December–February, 

Spring = March–May, Summer = June–August, Fall = September–November 

The WestMap data also indicate that average annual and seasonal temperatures have experienced 

statistically significant increases across the planning area (Figure 3-21). Since 1896, average annual 

temperature has increased by 1.4 oF in the Oregon coastal basins, by 1.6 oF in the Willamette River basin, 

and by 1.8 oF in the Klamath River basin. Increases in average spring temperature are not statistically 

significant in the Willamette River and Klamath River basins. Increases in minimum temperatures are 

statistically significant in all basins, both annually and seasonally, whereas increases in maximum 

temperatures are significant only annually and in winter in all basins. The increase in summer temperature 
183 | P a g e

is also statistically significant in the Klamath River Basin. Increases in minimum temperature are greater 

than the increases in maximum temperature. Given the small increases in precipitation and the more 

statistically significant increases in temperature, the entire planning area is becoming warmer and drier, 

particularly in winter and at night. The amount of effective change in the Willamette River basin is 

smaller than the change in the Oregon coastal basins and Klamath River basin. 
184 | P a g e

Figure 3-21. Observed changes in (a) annual, (b) maximum, and (c) minimum temperature in each basin 

Note: A star indicates the change is statistically significant; Annual = October 1–September 30, Winter = December–February, 

Spring = March–May, Summer = June–August, Fall = September–November 

0

0.5

1

1.5

2

2.5

3

Annual Winter Spring Summer Fall

Annual Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

A.

0

0.5

1

1.5

2

2.5

Annual Winter Spring Summer Fall

Maximum Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

B.

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

Annual Winter Spring Summer Fall

Minimum Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

C.
185 | P a g e

Winter precipitation, in particular the amount, type, and timing, is an important factor in the response of 

vegetation and streams to climate change (Dalton et al. 2013, Peterson et al. 2014). Winter precipitation 

typically falls as rain in the coastal mountains and western Oregon valleys and a mix of rain and snow in 

the Cascade foothills and mountains (Safeeq et al. 2013, Klos et al. 2014). In the Cascades, only small 

differences in temperature differentiate between a rain event and a snow event (Lute and Abatzoglou 

2014). Interactions between the phase of El Niño-Southern Oscillation (ENSO) and the Pacific Decadal 

Oscillation (PDO) influence winter temperatures and precipitation, resulting in high interannual 

variability in winter precipitation amount and timing (Dalton et al. 2013, Lute and Abatzoglou 2014). El 

Niño winters (ENSO warm phase) typically result in 20–60 percent less snow, while La Niña winters 

(ENSO cool phase) typically result in 30–70 percent more snow (Lute and Abatzoglou 2014). The larger 

differences tend to occur when the phases of ENSO and PDO align (Dalton et al. 2013). 

Reflecting the observed changes in temperature in particular, April 1 snow water equivalent (the time 

when snowpack historically has peaked) has been decreasing across much of the western United States, 

with some of the largest relative decreases in western Oregon (Mote et al. 2005, Peterson et al. 2014). 

Snow course data for western Oregon indicate that decreases are occurring at all elevations across the 

planning area, although there is high interannual variability in snow amounts. Both the Cascade and 

Klamath Mountains can have high accumulations of snow, but that accumulation period is typically short, 

and the snowmelt period begins early and occurs more rapidly that most of the western United States 

(Trujillo and Molotch 2014). In contrast, the Coast Range has only intermittent snow all winter. Winter 

atmospheric rivers, often associated with La Niña winters, typically deliver the most snow and over short 

periods (1–2 days), but can also result in rain-on-snow events that result in very rapid melting and 

flooding (Lute and Abatzoglou 2014, Trujillo and Molotch 2014). 

Thus far, the observed changes in climate have not yet lead to obvious changes in forests, most 

disturbance regimes, and terrestrial wildlife species ranges or habitat within the planning area, although 

subtle changes could well be happening. Assessments at larger spatial and temporal scales suggest some 

changes could be occurring already, but at levels indistinguishable from natural variability. In other 

words, within the planning area, climate-related changes in ecosystems cannot be detected over the 

“noise” of interannual and interdecadal variability at this geographic scale. Apparent temporal 

disconnects between changes in climate and changes in vegetation are common; older forests in particular 

experience such disconnections as established vegetation is able to tolerate larger changes in climate than 

seedlings. 

Tree Species 

In their evidence-based review of the science, Allen et al. (2010) found that tree mortality from climateinduced stress driven by drought and warmer temperatures appears to be increasing worldwide in all 

forest types. In North America, drought and warmer temperatures have been correlated to increases in the 

mortality of several pine species, several spruce species, white fir, incense cedar, two species of juniper, 

and Douglas-fir (Allen et al. 2010). In the western United States, background rates of mortality have 

increased in recent decades across elevation, tree size, dominant genera, and past fire histories with 

warming and increased water stress believed to be a major contributor to the increase (van Mantgem et al.

2009, Smith et al. 2015). The patterns of mortality are patchy with higher levels in drier forests, but 

increased mortality has been documented on productive sites where changes in moisture stress may well 

interact with density-dependent factors (Allen et al. 2010). In conifer forests and woodlands, climaterelated mortality is more common during multi-year droughts than during seasonal droughts, and warmer 

temperatures can increase moisture stress independent of precipitation amount (Allen et al. 2010). Given 

these findings, climate change may have increased background tree mortality in the Klamath Falls Field 

Office and the Medford and Roseburg Districts, but it is less clear if background mortality may have 

increased in the Coos Bay, Eugene, and Salem Districts. 
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Devine et al. (2012) developed climate vulnerability rankings for major tree species U.S. Forest Service 

lands in Oregon and Washington, breaking out the results by geographic area. The authors based the 

ratings on tree species distribution, reproductive capacity, habitat affinity, adaptive genetic variation, and 

risk of insects and disease. Species deemed more vulnerable were those that are rare, have low seed 

production and low seed viability with very short dispersal distances, are habitat specialists, are either 

disjunct or at the edge of the species’ range, and have insect pests or diseases that are increasing in 

distribution and impacts with typically high mortality of mature trees, among other characteristics. 

Species rated as less vulnerable are those with opposite characteristics (e.g., widespread, common, habitat 

generalists, and high seed production with high seed viability). The rankings used data on the distribution 

of species on U.S. Forest Service lands, although the rankings provide an indicator of potential 

vulnerability on BLM-administered lands within the planning area. The authors normalized rankings so 

they vary between 0 and 100, with the higher the ranking, the more vulnerable the species.

Rankings sometimes differ for species that occur in both northwest and southwest Oregon (Table 3-15). 

For example, the authors rated Engelmann spruce as less vulnerable in northwest Oregon than in 

southwest Oregon, whereas the opposite was true for sugar pine. The authors rated Douglas-fir as slightly 

more vulnerable in northwest Oregon than in southwest Oregon, largely due to differences in adaptive 

genetic variation and insects and disease risks. Generally, species found primarily at higher elevations 

tended to be ranked as more vulnerable than those found primarily at lower elevations. Some species may 

be more widespread on BLM-administered lands, which tend to be lower elevation, than on U.S. Forest 

Service lands, and therefore may actually have a somewhat lower vulnerability, whereas the opposite may 

also be true for other species. Examples of the former would be the various oak species, while the latter 

would be the higher elevation species.
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Table 3-15. Climate change vulnerability scores for different tree species in western Oregon

Species Northwest Oregon Southwest Oregon

Subalpine fir 77 69

Pacific silver fir 66 56

Noble fir 60 -

Noble fir-Shasta red fir complex - 48

Grand fir 59 -

Grand fir-white fir complex - 55

Douglas-fir 41 36

Western hemlock 52 42

Western larch 52 -

Engelmann spruce 55 71

Sitka spruce 39 -

Whitebark pine 67 67

Lodgepole pine 56 42

Shore pine 17 -

Sugar pine 59 39

Ponderosa pine 46 46

Western white pine 39 36

Jeffrey pine - 39

Knobcone pine - 30

Western redcedar 36 35

Alaska yellow-cedar 59 -

Port-Orford-cedar 36 35

Incense-cedar - 33

Western juniper - 27

Bigleaf maple 50 39

Red alder 38 33

Tanoak - 46

Oregon white oak 54 48

California black oak - 45

Canyon live oak - 40

Black cottonwood 27 -

Pacific madrone - 46

Note: A higher score indicates greater vulnerability. In Devine et al. 2012, Northwest Oregon roughly corresponds to the Eugene, 

Roseburg, and Salem Districts, Southwest Oregon to the Coos Bay and Medford Districts and the Klamath Falls Field Office.

Source: Devine et al. 2012

One factor in the ratings is whether the species is at or near the limits of its range, although it is not clear 

if the authors rated species at the southern end of their range differently than species at the northern limit. 

A common climate change effect prediction is that species ranges would tend to shift poleward and 

upward in elevation; numerous studies of taxa other than trees have documented shifts consistent with this 

prediction (e.g., Parmesan and Yohe 2003, Root et al. 2003, Tingley et al. 2012, Comte and Grenouillet 

2013, and Cahill et al. 2014). Pacific silver fir, subalpine fir, Alaska yellow-cedar, and Engelmann spruce 
188 | P a g e

are at or near the southern limits of their range in western Oregon, so may well be more vulnerable in 

southwestern Oregon. Conversely, incense-cedar, sugar pine, Jeffrey pine, canyon live oak, California 

black oak, and tanoak are at the northern limits of their range in western Oregon and could be expected to 

expand northward, making them less vulnerable.

Insects and Pathogens

Many insects and pathogens are influenced by temperature and precipitation amount and timing (Sturrock 

et al. 2011, Vose et al. 2012, Peterson et al. 2014). Sturrock et al. (2011) reviewed much of the literature 

concerning the potential impact of climate change on a variety of important forest diseases. Generally, 

warming winters and minimum temperatures and increasing moisture during the growing season will 

favor pathogens that require leaf or needle wetness to spread, while drying conditions disfavor such 

pathogens. Examples include Sudden Oak Death (Venette and Cohen 2006), Dothistroma needle blight 

(Woods et al. 2005), Swiss needle cast (Manter et al. 2005, Lee et al. 2013, Tillmann and Glick 2013), 

and white pine blister rust (Sturrock et al. 2011). Although not specifically discussed, Port-Orford-cedar 

root disease, another Phytophthora species, likely responds similarly to Sudden Oak Death. In contrast, 

warming and drying conditions will favor pathogens that increase when host species are water-stressed, 

such as Armillaria root disease and various canker species (Sturrock et al. 2011, Vose et al. 2012). The 

response of pathogens that depend on insects for spread will likely be complex, depending on how the 

particular insect vector responds to changing climate (Sturrock et al. 2011).

Since temperature is a primary control on insect development and survival (Peterson et al. 2014), 

warming temperatures will and are altering insect pest dynamics (Chmura et al. 2011). The best-known 

and documented example is mountain pine beetle with the recent outbreak across western North America 

the subject of many studies. Warming temperatures and increased drought stress are commonly cited 

factors in the scale of the current mountain pine beetle outbreak (Vose et al. 2012). Conditions that create 

water stress in trees limit the effectiveness of tree defenses and favors bark beetles (Evangelista et al.

2011, Vose et al. 2012, Tillmann and Glick 2013, Creeden et al. 2014). How changing climate is now 

affecting and will potentially affect defoliating insects is less clear. Outbreaks of this class of insects tend 

to be cyclical and involve predators, parasitoids, and pathogens of the individual insect species, and the 

role of climate in such cycles is not clear (Vose et al. 2012, Tillmann and Glick 2013). For example, 

outbreaks of western spruce budworm in the interior west tend to occur near the end of droughts (Flower 

et al. 2014), but in British Columbia tend to be associated with dry winters followed by average spring 

temperatures (Campbell et al. 2006). Chen et al. (2003) noted that the degree of damage in Douglas-fir 

was also correlated with close matches between the phenology of budburst and larval emergence. 

Changing atmospheric CO2 concentrations will also influence insect dynamics by increasing carbon 

availability for tree defenses and altering the carbon:nitrogen ratios in leaves and needles, thereby 

reducing food quality (Peterson et al. 2014). Reduced food quality can lead to increased herbivory in 

order to obtain the amount of nutrients needed to complete insect life cycles.

Other than a documented increase in the incidence, damage, and inland spread of Swiss needle cast in 

northwest Oregon (Manter et al. 2005), no obvious climate change-related changes in the incidence of 

insects and diseases have been clearly noted within the planning area. Determining both whether 

increasing atmospheric CO2 has a bigger impact than increasing temperature and whether the effects of 

increasing atmospheric CO2 concentrations on insect dynamics has occurred within the planning area 

remains elusive.

Wildfire

Many studies have examined changes in area burned, individual fire severity, and fire season severity, 

concluding that changes in climate are a major factor driving these observed changes. Westerling et al.

(2006) documented an increase in the length of fire season in the western U.S. by at least one month, 

based on start dates of fires at least 1,000 acres in size, attributing this change to earlier snowmelt and 
189 | P a g e

longer, drier summers. Van Mantgem et al. (2013) reported an increase in the probability of tree mortality 

due to the combination of drought and warming temperatures. Dry, warm conditions, particularly in the 

years of fire, are also strongly associated with greater annual area burned in the northwestern United 

States (Littell et al. 2009). Larger wildfires in recent decades also tend to have a higher proportion of high 

severity burn area in terms of tree mortality, and larger high severity patch sizes when conditions are 

warm and dry (Abatzoglou and Kolden 2013, Cansler and McKenzie 2013).

Within the planning area, fire season length and potential severity, as measured by energy release 

component, a measure of seasonal dryness used in fire danger rating, has increased (Dalton 2014; 

unpublished data). The changes in fire season severity and the severity of individual wildfires have 

occurred in the Northwest consistent with the results above for the western U.S.; however, there are 

simply too few wildfires that have originated on BLM-administered lands (or in western Oregon), to 

provide a clear signal of such changes. An analysis of large fires across the entire state of Oregon using 

data from the Monitoring Trends in Burn Severity site (MTBS 2013) indicates that the proportion of highseverity fire in forests generally has increased by 11 percent since 1984, with much of the increase since 

2000.

Streamflow and Temperature

Several studies have concluded that observed changes in stream flow regimes and temperature in the 

western U.S. are a result of climate change, but that these changes depend on more than just changes in 

air temperature, precipitation amount, and timing. Geology, topography, vegetation, and other factors also 

play a role (Dalton et al. 2013, Safeeq et al. 2013). Safeeq et al. (2013) report that streams that are 

primarily groundwater-sourced respond differently to changing climate from those that are surface watersourced. In western Oregon, streams arising in the Coast Range are surface water-sourced from rain, 

whereas streams arising in the Cascades are groundwater-sourced from a mix of rain and snow, with 

predominately rain below 1,300 feet elevation, predominately snow above 4,900 feet, and a mix of rain 

and snow between 1,300 and 4,900 feet (Tague and Grant 2004, Safeeq et al. 2013, Klos et al. 2014). 

Total annual streamflow has been declining in the Pacific Northwest and current flows are similar to those 

in the 1930s, one of the driest periods on record (Luce et al. 2013). While scientists do not understand the 

exact causes, some combination of warming temperatures, decreasing snow, and decreasing mountain 

precipitation due to weakening of the westerly winds in winter appear to play a role (Dalton et al. 2013, 

Luce et al. 2013, Berghuijs et al. 2014).

The timing of peak flows is also shifting across the western U.S. with an increased proportion of the 

annual flow occurring in winter and a decreasing proportion in summer (Safeeq et al. 2013). Raindominated streams have earlier peak spring flows and declining late fall and winter flows, whereas snowdominated streams have greater reductions in summer flows (Safeeq et al. 2013). However, the response 

of individual streams varies, depending on underlying geology. For example, streams originating in 

geology that supports slow-draining, deep groundwater exhibit less variability in flow regimes than 

streams originating in geology that supports shallow, rapid subsurface flow (Tague and Grant 2004 and 

2009). However, as snowpack declines, the absolute change in summer base flows is greater in the deep 

groundwater systems than in the shallow, rapid subsurface systems (Tague et al. 2008, Tague and Grant 

2009, Safeeq et al. 2013).

Stream temperatures in the United States as a whole and in the Northwest have been increasing 

(Bartholow 2005, Kaushal et al. 2010, Dalton et al. 2013). However, there is local and regional variation. 

Kaushal et al. (2010) reported statistically significant upward trends for Fir Creek, the North Santiam 

River and Rogue River, statistically non-significant trends for the Bull Run, South Fork Bull Run, and 

North Fork Bull Run rivers, and no trend for the South Santiam River. Blue River had a statistically 

significant cooling trend, although all records for Oregon were relatively short. The direction and 
190 | P a g e

significance of stream temperature trends depend on the period of record, sample size, and spatial extent 

of the samples (Arismendi et al. 2012).

Northwest streams typically have cooling trends in spring, consistent with increasing precipitation, but 

warming temperatures in summer, fall, and winter. The cooling in spring is not enough to fully offset 

warming in the other seasons, leading to an overall warming trend in stream temperatures (Isaak et al.

2012). The rates of warming are highest in summer, with greater summer warming occurring in streams 

with the largest decrease in discharge instead of the streams with the lowest discharge (Isaak et al. 2012). 

Overall, stream temperatures track with air temperatures, although there is often a slight lag (Isaak et al.

2012, Arismendi et al. 2013). Diabat et al. (2013) found that increasing nighttime temperatures appears to 

be a bigger driver of stream temperature changes than increasing daytime temperatures, indicating that the 

observed increasing minimum temperatures in all seasons may be important factors. In the John Day 

River in eastern Oregon, the time lag between stream temperature maxima and stream flow minima has 

decreased by approximately 24 days since 1950, potentially due to earlier timing of stream flow minima, 

especially given no observed change in the timing of stream temperature maxima (Arismendi et al. 2013). 

Similar changes are likely within the planning area, given that the same air temperature and stream flow 

changes are occurring across Oregon.

Wildlife and Wildlife Habitat

Several different studies have documented changes in fish and wildlife species consistent with those 

expected with increasing temperatures worldwide, nationally, and statewide. These observed effects 

include changes in migration timing, species ranges, species abundance, and similar impacts (Parmesan 

and Yohe 2003, Hixon et al. 2010, Tillmann and Glick 2013, Groffman et al. 2014). Detailed discussion 

of any observed climate change effects on all fish and wildlife species found within the planning area is 

not possible. However, a brief discussion of climate influences on northern spotted owl and marbled 

murrelet illustrates how climate change may be influencing two important species.

Climate can affect species persistence directly by affecting survival of the young and indirectly by 

altering habitat, such as nesting sites or prey abundance. With northern spotted owls, climate conditions 

that affect prey abundance affect owl survival, with populations decreasing when winters and early spring 

were cold, wet and stormy or summers are droughty, and populations increasing when late spring through 

early fall are moist (Franklin et al. 2000, Glenn et al. 2010, Glenn et al. 2011). In Cascade populations, 

owl survival also decreases as the number of summer days with temperatures at or above 90 oF increases 

(Glenn et al. 2010, Glenn et al. 2011). Under stable habitat conditions, climate is apparently the dominant 

influence on owl populations, but as habitat quality declines, the effects of climate variation on survival 

increases (Franklin et al. 2000). Climate effects appear to be local, rather than regional, with some 

locations experiencing lags in effect with respect to sub-adult survival (Glenn et al. 2010, Glenn et al.

2011).

Marbled murrelets are affected by both land and ocean conditions. Various studies have attributed 

population declines in the 1990s and 2000s to loss of nesting habitat and low food availability at sea 

(Strong 2003, Peery et al. 2004, Becker et al. 2007, Norris et al. 2007, Miller et al. 2012b, Raphael et al.

in press), but disagree on which is more important. Poor ocean conditions arising from climate may have 

contributed to murrelet population declines in the 1990s by affecting food availability at sea, but given 

improved ocean conditions since the mid-2000s, climate may not have been a substantial factor in 

continued declines. Raphael et al. (2015) found that at the current low murrelet population levels, much 

of the ocean habitat with apparently suitable forage conditions is presently unused, but also that access to 

finer-scaled spatial and temporal conditions may have increased their ability to detect marine influences 

on murrelet at-sea distributions. Norris et al. (2007) found that since the 1950s, murrelet populations in 

southern British Columbia were adversely affected by low food quality, specifically by less abundance of 

small fish in the bird’s diet. Off the central California coast, Becker et al. (2007) found that murrelet 
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productivity was correlated with rockfish and krill productivity, which were higher when ocean 

temperatures were cooler. When food resources are low, murrelet adults must fly further and dive more 

often, using more energy (Peery et al. 2004). As with northern spotted owls, these findings indicate that 

even when sufficient high-quality nesting habitat is available, climate events and climate change can 

influence murrelet populations by affecting the conditions important for prey species.

Climate Change Projections and Potential Effects on Resources

Dalton et al. (2013) summarized the most recent climate change projections for the Pacific Northwest 

(Oregon, Washington, Idaho, and western Montana) under representative concentration pathways (RCP) 

4.5 and 8.5. These pathways represent a substantial reduction in greenhouse gas emissions in the near 

future and “business as usual,” respectively. Current greenhouse gas concentrations and atmospheric CO2

concentrations are tracking with the RCP 8.5 pathway (Peters et al. 2013, Le Quéré et al. 2014). By 

2041–2070, temperatures are projected to increase in all seasons, with the largest increase in summer 

(Table 3-16). Precipitation is projected to increase modestly in winter, spring and fall and decrease in 

summer throughout the Pacific Northwest. The area west of the Cascades where the maritime influence is 

strong would not warm as much as elsewhere in the Pacific Northwest, particularly in spring. Dalton et al.

(2013) did not identify any sub-regional differences in precipitation.

Table 3-16. Expected changes in mean annual and seasonal temperature and precipitation by 2041–2070 

as compared to means in the 1950–1999 for RCP 4.5 and RCP 8.5

Season

Temperature Precipitation

RCP 4.5 RCP 8.5 RCP 4.5 RCP 8.5

Annual 4.3 oF (2.0–6.7 oF) 5.8 oF (3.1–11.5 oF) +2.8% (-4.3–10.1%) +3.2% (-4.7–19.8%)

Winter (Dec.–Feb.) 4.5 oF (1.0–7.2 oF) 5.8 oF (2.3–9.2 oF) +5.4% (-5.6–16.3%) +7.2% (-10.6–19.8%)

Spring (Mar.–May) 4.3 oF (0.9–7.4 oF) 5.4 oF (1.8–8.3 oF) +4.3% (-6.8–18.8%) +6.5% (-10.6–26.6%)

Summer (Jun.–Aug.) 4.7 oF (2.3–7.4 oF) 6.5 oF (3.4–9.4 oF) -5.6% (-33.6–18%) -7.5% (-27.8–12.4%)

Fall (Sep.–Nov.) 4.0 oF (1.4–5.8 oF) 5.6 oF (2.9–8.3 oF) +3.2% (-8.5–13.1%) +1.5% (-11.0–12.3%)

Note: Ranges are in parentheses

Some of the projected changes displayed in Table 3-16 are not consistent with observed trends displayed 

in Figure 3-20 and Figure 3-21, with differences in precipitation especially notable. Climate models 

project an increase in fall precipitation, yet the observed trend is a decrease. Similarly, the observed trend 

in summer precipitation is a slight, statistically insignificant increase, whereas the projection is for a 

decrease. Observed and projected temperature changes are more consistent, but the magnitude of change 

shows some differences. For example, the observed increase in maximum summer temperatures in the 

Willamette basin is small; suggesting that the mid-century increase may not be as large as projected.

The differences between the projections and observed trends likely arise due to differences in the size of 

area assessed and resolution of the data used. Trends in a smaller part of the Pacific Northwest can differ 

from those for the area as a whole. The WestMap data are at a finer resolution than the climate projection 

data, so likely better reflects the effects of topography on both temperature and precipitation. The 

projected changes in precipitation in particular encompass large ranges, including both increases and 

decreases in all seasons in both climate change scenarios, even though the ensemble mean indicates 

increases in winter, spring, and fall and decreases in summer. Lastly, observed trends in precipitation may 

not continue in the future if increasing temperatures result in fundamental changes in the atmospheric 

circulation patterns that bring moist air into Oregon.

By 2041–2070, the number of frost-free days is projected to increase by 35 days (± 6 days) relative to 

1971–2000. Climate modeling indicated the number of growing degree-days using a base of 50 oF would 
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increase by 51 percent (± 14 percent). The number of hot days (i.e., days with maximum temperatures 

greater than 90 oF, 95 oF and 100 oF, as well as the number of consecutive days above 95 oF and 100 oF) 

would increase, while the cold days (with minimum temperatures of less than 32 oF, 10 oF, and 0 oF) 

would decline. The number of very wet days (with precipitation above 1 inch, 2 inches, 3 inches, and 4 

inches) would increase, as would the dry spells (maximum run of days with less than 0.1 inch).

As temperatures continue to warm, the extent of snow-dominated winter precipitation would continue to 

decline (Mote et al. 2005). By mid-century, none of the Cascades ecoregion (EPA Level-III ecoregion 4) 

would remain strongly snow-dominated, and the extent of strongly rain-dominated area would increase by 

42 percent to an estimated 59 percent of the ecoregion. Although none of the Coast Range (EPA Level-III 

ecoregion 1) and the Klamath Mountains (EPA Level-III ecoregion 78) are strongly snow-dominated, all 

of the Coast Range and 95 percent of the Klamath Mountains are projected to become strongly raindominated by mid-century (Klos et al. 2014).

Several different climate change assessments project that the frequency, duration, and severity of drought 

will increase globally, nationally, and regionally (Dai 2011, Gutzler and Robbins 2011, Jung and Chang 

2012, Vose et al. 2012, Dalton et al. 2013, Walsh et al. 2014). However, the term ‘drought’ remains illdefined, making projections of changing drought risks difficult to evaluate. Drought is not just a deficit in 

precipitation, but insufficient water to meet needs. Temperature plays a very important role that many 

drought assessment tools either do not incorporate or incorporate inadequately (Bumbaco and Mote 

2010). Three different types of drought occur in the Pacific Northwest (Bumbaco and Mote 2010) and 

more than one kind of drought can occur in a given year. The first type is very low winter precipitation 

with seasonally typical temperatures (dry drought), as represented by conditions in 2001. The second type 

of drought consists of warm winter temperatures with normal precipitation, resulting in more rain and low 

snow packs, followed by a very warm, dry summer (hot-dry drought), as represented by conditions in 

2003. This type of drought can develop suddenly with little or no warning and is associated with low 

summer streamflow in western Oregon. The third type of drought consists of a warm, dry winter followed 

by a near normal summer (warm-dry drought), as represented by conditions in 2005. A characteristic of 

all these drought types is a low winter snowpack combined with high evapotranspiration demand during 

the growing season. The warm-dry drought and hot-dry drought are also associated with more severe fire 

seasons in western Oregon. Based on the temperature and precipitation projections, Northwest climate 

scientists expect the warm-dry and hot-dry drought types will increase in frequency while the dry drought 

type will likely decrease in frequency (Bumbaco and Mote 2010).

A particular emerging concern among forest scientists who study climate change is the increasing role of 

drought in tree and forest mortality (e.g., Allen et al. 2015 and references therein, McDowell and Allen 

2015, and Millar and Stephenson 2015 and references therein). Variously called ‘global-change-type 

drought’, ‘hot drought’, and ‘hotter drought’, the focus is the role higher temperatures play in increasing 

drought intensity and severity, tree and forest water stress, and subsequent tree vulnerability to insects, 

pathogens, and fire (Allen et al. 2015, Millar and Stephenson 2015). While the most severe effects have 

occurred in semi-arid forests, scientists are increasingly concerned about the vulnerability of temperate 

forests (Millar and Stephenson 2015). There is scientific disagreement on just how vulnerable these 

forests are (Allen et al. 2015). In a review paper, Allen et al. (2015) identified six global vulnerability 

drivers:

 Droughts eventually occur everywhere

 Warming produces hotter droughts

 Atmospheric moisture demand increases nonlinearly with temperature during drought

 Mortality can occur faster in hotter drought

 Shorter droughts occur more frequently than longer droughts and can become lethal under 

warming, increasing the frequency of lethal drought nonlinearly
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 Mortality happens rapidly relative to growth intervals needed for forest recovery

These so-called hotter droughts could increase tree mortality in western Oregon in the future. These hotter 

droughts could also affect cold-water fish and aquatic organisms, species that depend on cooler 

temperatures, and species that depend on relatively frequent rain in summer.

There are substantial uncertainties associated with the various predictions discussed below. The choice of 

global climate model used is typically the largest source of variability in simulation study results (Hurteau 

et al. 2014). There is also a fundamental scale mismatch between the spatial resolution of climate 

predictions, even those that have been downscaled, and the size of the typical management unit simulated 

in many studies (Hurteau et al. 2014).

Tree Species

Understanding how climate change may affect species composition and forest productivity has been the 

topic of numerous studies. Results vary depending on the spatial and temporal scale of the studies and 

assumptions about climate drivers and the interaction between climate and non-climate drivers that 

underpin such studies. Therefore, interpreting what these results might mean for land management 

remains challenging. Generally, trees can respond to changing climate through phenotypic plasticity 

(altering physiology), morphology, and reproduction within their existing genetic capability, through 

natural selection, or through migration, as summarized by Peterson et al. (2014, Chapter 5).

There are several approaches to modeling potential vegetation change based on statistics, ecological 

processes, or a mix of the two, all with their strengths and weaknesses (Peterson et al. 2014, Chapter 6). 

Most studies of how tree species compositions may shift use bioclimatic envelope models, a statistical 

method that bases predictions on the climate where species are present and absent. Despite their 

limitations, bioclimatic envelope models are the most widely used, due to ease of use and applicability at 

a number of scales (Araújo and Peterson 2012, Peterson et al. 2014). Other factors, such as competition, 

land uses, soils, topography, and disturbance regimes, can prevent a species from occupying an area that 

is otherwise suitable climatically, or allow it to remain in a location that broader-scale climate predictions 

indicate would not remain suitable (Peterson et al. 2014). Process-based models and hybrid models can 

incorporate many non-climate drivers. However, these models remain rarely used to date, due to the lack 

of information needed to parameterize such models for most species, high computational demand, and 

lack of information on how climate affects many forest tree processes, particularly regeneration, growth, 

and mortality (Peterson et al. 2014).

Using the climate module of the Forest Vegetation Simulator (Climate-FVS), the climatically suitable 

area for many important timber species in the planning area would contract by mid-century, primarily 

from the lower elevations, with generally much greater contraction under RCP 8.5 than under RCP 4.5 

(Diaz et al. 2014). The suitable climate for western hemlock, western redcedar, Pacific yew, incense 

cedar, Port-Orford-cedar, grand fir, white fir, noble fir, and sugar pine are projected to contract 

substantially in western Oregon under both pathways. Several modeling approaches indicate probable loss 

of climatically suitable areas for western hemlock and western redcedar, primarily in southwest Oregon, 

but the projected losses from Climate-FVS are likely too high (Diaz et al. 2014). The area climatically 

suitable for Douglas-fir may increase in the Klamath Falls Field Office. The Climate-FVS analysis 

projected that the climatically suitable area for several species more typically found in California, such as 

several species of oak, white alder, California laurel, and knobcone pine would expand into Oregon and 

up the eastern side of the Coast Range and foothills of the Cascades.

The fate of Douglas-fir is of particular interest due to its current dominance throughout western Oregon 

and importance for both timber and wildlife habitat. Many studies predict some degree of decline in the 

extent of Douglas-fir, particularly at lower elevations. The degree of decline varies widely between 
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studies, ranging from major contractions, especially from the Coast Range, to little change (Bachelet et al.

2011 and references therein, Coops and Waring 2011, Peterson et al. 2014, Rehfeldt et al. 2014a).

Using the dynamic global vegetation model MC2, Bachelet (2014 in Diaz et al. 2014) projected 

substantial contraction of the maritime conifer forest and expansion of both the temperate conifer forest 

more typical of eastern Oregon and temperate cool mixed forest more typical of the central and southern 

Coast Range (data available at DataBasin 2014). Using MC1, Rogers et al. (2015 and references therein) 

also projected a contraction of the highly productive maritime conifer forests and expansion of the lower 

productivity warm temperate and subtropical mixed forests in western Oregon by the end of the century, 

although the degree of change varied by climate model. Douglas-fir is a substantial component of all three 

forest types, but consists of different ecotypes, or climatypes,43 of the species (Rehfeldt et al. 2014c). In 

addition, the temperate cool mixed-conifer forest type includes a number of so-called hardwoods, such as 

tanoak, madrone, and several species of oaks, suggesting broad consistency between the statistical 

approach used by Climate-FVS and the process-based approach used in MC1 and MC2.

With shifting bioclimate suitability, a primary concern is the rate at which climate is changing (climate 

velocity), relative to the rate at which a given species can migrate. For plants, migration rates depend on 

seed production rates, seed dispersal distances, average seed viability, presence or absence of barriers, 

biotic interactions between migrating species and current species, and the presence of suitable habitat 

between the current location of a given climatype and the likely future location of suitable climate 

(Peterson et al. 2014). Climate velocity is generally slower in complex terrain, and complex terrain is 

more likely to provide climate refugia (Peterson et al. 2014), such as is present in western Oregon. The 

reserve land use allocations in the different alternatives and the Proposed RMP may provide some climate 

refugia, depending on location, size, orientation, and conditions on adjoining lands. Further, species 

migration rates typically lag behind climate velocity rates with considerable regional variation in both 

rates and direction (Dobrowski et al. 2013). Thus, while several studies indicate that climate velocity 

exceeds the migration rate of many plant species, including many tree species, determining the 

vulnerability of individual species to climate change based on climate velocity is difficult with large 

uncertainties.

As climate shifts, forest scientists expect background tree mortality will increase, but do not expect major 

die-offs of mature trees because of changing climate alone. Instead, die-offs are expected from the 

interaction between changing climate and disturbance events, such as drought and fire (Allen et al. 2010, 

Peterson et al. 2014) or the interaction between changing climate and increased competition for water and 

carbon (Clark et al. 2014). Changes in vegetation are likely to be abrupt following an event such as 

prolonged drought, insect outbreak, or wildfire, when mature trees are killed and regeneration fails. The 

bioclimatic envelope for seedlings of montane species, such as Douglas-fir and ponderosa pine, typically 

differs from and is narrower than the bioclimatic envelope in which established trees can persist (Bell et 

al. 2014). Species with broad distributions typically have ecotypes/climatypes adapted to local conditions; 

as local conditions change, a given climatype may not be able to reestablish following a disturbance. 

Using climate variables, Rehfeldt et al. (2014b, 2014c) predicted that the varieties of Douglas-fir and 

ponderosa pine found in western Oregon are likely to persist, although probably would not persist in an 

area that includes the Klamath Falls Field Office. In contrast, St Clair and Howe (2007), using 

characteristics such timing of bud set and bud break and root:shoot ratios, predicted that most coastal 

Douglas-fir ecotypes in western Oregon and Washington would be maladapted to the expected climate at 

the end of the 21st century. The authors posited that much of the risk arises from differences in drought 

hardiness in the different ecotypes relative to expected changes in seasonal and prolonged drought, and 

lengthening of the growing season (St Clair and Howe 2007). A more recent study found that Douglas-fir 

 

43 A climatype is a population defined primarily by the temperature and precipitation ranges to which it is 

presumably adapted genetically.
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populations from areas with relatively cool winters and warm, dry summers, similar to that found in the 

Willamette Valley basin, might be better adapted to cope with future expected drought conditions than 

Douglas-fir from other areas (Bansal et al. 2015).

Available soil water during the growing season and soil water storage capacity are important drivers of 

which tree species can grow where and how well, particularly at lower and middle elevations (Chen et al. 

2010, Weiskittel et al. 2011, Clark et al. 2014, Mathys et al. 2014, Peterson et al. 2014). Year-round soil 

water availability and evapotranspiration demand are primary factors in the distribution of western 

hemlock (Gavin and Hu 2006, Mathys et al. 2014). Western redcedar distribution is controlled in part by 

the availability of soil water in summer and winter (Mathys et al. 2014). Climate change is projected to 

extend growing seasons and increase evapotranspiration demand in summer, increasing the amount of 

drought stress forests in western Oregon will experience (Peterson et al. 2014). Site index for many 

species in western Oregon could decrease by 10–30 percent by 2060, largely due to increased dryness in 

the growing season (Weiskittel et al. 2011).

Potentially mediating the expected increased drought stress is the increasing atmospheric CO2

concentrations. As atmospheric CO2 concentrations increase, trees do not have to open stomates as 

frequently or for as long to obtain the amount of CO2 necessary to drive photosynthesis, thereby reducing 

water loss that occurs at the same time (photorespiration) and increasing drought tolerance (Peterson et al.

2014). A recent study in the northern Rockies indicates that while both ponderosa pine and Douglas-fir 

have experienced increases in water use efficiency with increases in basal area increment in the latter half 

of the 20th century, ponderosa pine had greater increases, suggesting a possible shift in competitive 

advantage (Soulé and Knapp 2014). However, few studies have examined how different tree species 

might respond to changing atmospheric CO2 concentrations, particularly in conjunction with changing 

temperatures.

Along with changing species composition is an expected decline in growth rates and overall site 

productivity, particularly under business as usual emissions scenarios (Shive et al. 2014, Diaz et al.

2015). Climate modeling indicates that such downward shifts would begin about mid-century with larger 

changes potentially occurring in the Coos Bay, Eugene, and Salem Districts, than in the Medford and 

Roseburg Districts and the Klamath Falls Field Office (Diaz et al. 2015). Using Climate-FVS Diaz et al.

(2015) found that overall productivity could decline by one site class by mid-century and by two to three 

site classes by the end of the century as compared to current conditions, with the exception of the 

Klamath Falls Field Office. In the Klamath Falls Field Office area, productivity increased slightly by midcentury and then leveled out through the end of the century. These differences are likely due to how the 

different species and genotypes, and forests of different ages respond to drought and changing 

atmospheric CO2 concentrations, particularly with respect to seedling establishment and survival 

(Anderson-Teixeira et al. 2013). The Coos Bay, Eugene, and Salem Districts have humid to subhumid 

climates whereas the Medford and Roseburg Districts and the Klamath Falls Field Office are semi-arid. 

Forests in humid climates respond primarily to short-term drought, in subhumid climates to both shortand long-term drought, and in semiarid climates to long-term drought (Vincente-Serrano et al. 2014). 

Thus, forests in the warmer, drier part of the planning area are less vulnerable to drought.

The changes in growth rates and site productivity have implications for timber production beyond midcentury. Under lower emissions scenarios that hold the rise in the average global temperature to less than 

3.6 oF, harvest volume can remain relatively unchanged, although total volume on the landscape declines 

and then levels out and management intensity may need to increase (Diaz et al. 2015). However, under 

business as usual emissions scenarios, maintaining a set harvest value is likely to result in the 

combination of harvest and tree mortality exceeding growth by the end of the century (Diaz et al. 2015). 

After mid-century, sustaining a particular yield of timber would likely require shorter rotations and more 

clearcutting with less thinning and uneven-aged management and would become increasing difficult as 
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the variability in the harvestable volume available increases (Diaz et al. 2015). As the desired volume of 

stable harvest increases so does the difficulty in sustaining that volume become after mid-century under 

business as usual emissions scenarios, especially for the Coos Bay, Medford, and Roseburg Districts.

Insect Outbreaks and Pathogen Spread

Warming temperatures, wetter springs, and increased drought stress may increase the extent and impact 

from Swiss needle cast, sudden oak death, Port-Orford-cedar root disease, other root diseases such as 

Armillaria and Heterobasidion, bark beetles, and western spruce budworm in western Oregon (Chen et al.

2003, Manter et al. 2005, Campbell et al. 2006, Venette and Cohen 2006, Stone et al. 2008, Bentz et al.

2010, Chmura et al. 2011, Evangelista et al. 2011, Sturrock et al. 2011, Vose et al. 2012, Lee et al. 2013, 

Creeden et al. 2014, Flower et al. 2014, Peterson et al. 2014) (the discussion under Insects and Pathogens 

above has more detail). With their short generation times, both insects and pathogens can evolve more 

quickly than trees. Most insects and pathogens can migrate at faster rates than hosts, since wind and water 

disperse many of them farther than tree seeds (Sturrock et al. 2011, Peterson et al. 2014). 

An additional effect may be the appearance of new insects and pathogens currently not present in western 

Oregon or the emergence of a minor insect or pathogen into a major disturbance factor (Bentz et al. 2010, 

Vose et al. 2012, Tillmann and Glick 2013, Peterson et al. 2014). Climate change will also alter 

biological synchrony between hosts and pests, since most pests are host-specific, but such changes and 

the resulting impacts are difficult to predict (Chmura et al. 2011, Sturrock et al. 2011). For example, both 

Douglas-fir bark beetle and spruce bark beetle have obligate adult dormancy periods (diapause) triggered 

by low temperature that could be disrupted by increasing minimum temperatures (Bentz et al. 2010).

Wildfire

A number of recent studies have examined the potential effects of climate change on wildfire, as well as 

what the potential changes in wildfire could mean to greenhouse gas emissions and carbon storage. Most 

studies have examined how annual burned area may change, while an increasing number of studies have 

begun examining how the probability of wildfire and wildfire severity may change. Using Climate-FVS 

Diaz et al. (2015) found that the area of high fire hazard would change very little under lower emissions 

scenarios and increase somewhat after mid-century under the business as usual emission scenario in the 

moister districts (Coos Bay, Eugene and Salem). In the warmer-drier portion of the decision area, the area 

of high fire hazard would increase somewhat under lower emissions scenarios but increase substantially 

and rapidly after mid-century under the business as usual scenario, particularly for the Medford and 

Roseburg Districts.

All studies examined indicate that the annual area burned would increase, although they differ on how 

much of an increase will occur, when, or where. Differing scales of analysis and analysis methods make 

direct comparisons between studies difficult. The National Research Council (2011) reported that for a 1 

oC increase in global temperature, burned area in the Cascades and Coast Range could increase by 428 

percent and burned area in southwest Oregon could increase by 312 percent. Other estimates include a 78 

percent increase in burned area by mid-century in the Pacific Northwest as a whole (Spracklen et al.

2009) and at least a 60 percent increase in western Oregon and Washington by the end of the century 

(Rogers et al. 2011). Warmer and drier conditions are the primary drivers behind these projected 

increases in burned area, as well as predictions of increased fire severity (Littell et al. 2009, Abatzoglou 

and Kolden 2013, Cansler and McKenzie 2013, Peterson et al. 2014). The wetter forests of western 

Oregon, mixed severity fire regimes, and high severity fire regimes are projected to see greater changes as 

warmer and drier conditions in summer and increased frequency of drought lengthen the fire season, the 

probability of severe fire weather increases, and the combination of drought and heating from fire 

adversely affect tree xylem conductivity (Hessl 2011, Rogers et al. 2011, Abatzoglou and Kolden 2013, 

van Mantgem et al. 2013, Peterson et al. 2014, Rogers et al. 2015). Rogers et al. (2015) attributed the 
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increased vulnerability in the wetter forests to their inability to benefit from increased winter precipitation 

combined with the effects of increased summer drought. Under the Hadley climate model, increased fires 

in western Oregon would result in a predicted net loss of carbon by the end of the century (Rogers et al.

2015)

These same changes would also increase fire severity and the occurrence of very large fires (50,000 acres 

and larger) (Stavros et al. 2014b). Very large fires in the Pacific Northwest geographic area (Oregon and 

Washington) tend to occur under hotter, drier conditions, particularly in the first week following 

discovery of the fire, which historically occurred in three weeks (Stavros et al. 2014a, Stavros et al.

2014b). By mid-century, the number of weeks potentially supporting the occurrence of very large fires 

will increase to 6–8 weeks (Stavros et al. 2014b, supplementary table 1).

Other changes in wildfire include changes in fire probability and variability. Romps et al. (2014) 

projected a 50 percent increase in lightning occurrence across the continental U.S. by the end of the 

century. Guyette et al. (2014) predicted a 40–80 percent increase in fire frequency in western Oregon, 

with the largest changes predicted for colder and wetter ecosystems. Liu et al. (2013) also predicted 

increased inter-seasonal and inter-annual variability in fire potential along the Pacific coast. Using a 

process similar to one used in the Northwest Forest Plan 15-year monitoring report (Davis et al. 2011), 

Davis et al. (2014) projected that by 2060, the area where large wildfires are highly and very-highly 

probable would expand in the Klamath Falls Field Office, and the Medford and Roseburg Districts, and 

where large fires are at least moderately probable would expand into the Eugene, Salem, and Coos Bay 

Districts. However, the probability of large wildfires would remain low in most of the Coos Bay and 

Salem Districts.

Changes in annual area burned and fire severity would have clear implications for air quality, carbon 

storage potential, and greenhouse gas emissions as well. Greenhouse gas emissions would increase and 

carbon storage decrease as burned area and fire severity increase. Air quality typically degrades in years 

with higher acres burned and higher fire severity, due to longer duration burning on individual fires and 

greater degree of smoldering combustion that occurs during more severe fire seasons. This degradation 

typically results in more intrusions into mandatory Class I areas and greater effects to human health in 

Smoke Sensitive Receptor Areas (see Air Quality in this chapter). Earles et al. (2014) expect that as 

drought and fire frequency increase, carbon storage will destabilize where fire suppression has increased 

stand densities and ladder fuels and altered species compositions. The authors also assert that studies that 

compare the carbon effects of active management to no management in fire-suppressed forests are using 

the wrong baseline, based on a definition of carbon carrying capacity provided by Keith et al. (2009) 

(Earles et al. 2014). Keith et al. (2009) defined carbon carrying capacity in a manner that includes natural 

disturbance regimes, such as fire, but excludes anthropogenic disturbance, such as logging. Under this 

definition, as fire frequency and drought-induced mortality increases, carbon carrying capacity decreases 

with the implication that variability in carbon storage is much higher in fire-suppressed forests than in 

fire-included forests (Earles et al. 2014).

Scale mismatches means that important bottom-up controls on fire (e.g., topography, vegetation, and fuel 

availability) cannot be adequately incorporated into projections of how climate change may affect 

wildfires (Cansler and McKenzie 2013, Bowman et al. 2014). Other sources of uncertainty include 

whether drought-induced tree mortality will increase and tree responses to increased atmospheric CO2

concentrations (Hurteau et al. 2014). Predictions of changes in burned area, fire size, and fire severity 

assume that past relationships between climate and fire continue to hold (Littell et al. 2009, Cansler and 

McKenzie 2013, Bowman et al. 2014). If past relationships between climate and fire do not hold, it is not 

clear what would change, how, or when. If they do hold, then the landscapes of the future are likely to 

have a higher proportion in homogeneous, early seral patches, lower biodiversity, and lower resilience to 

other stressors, primarily in drier forests (Cansler and McKenzie 2013, Peterson et al. 2014). Climate and 
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weather are top-down controls on fire (e.g., Littell et al. 2009, Abatzoglou and Kolden 2013, and Higuera 

et al. 2015), but bottom-up controls are also important (e.g., Halofsky et al. 2011, Bowman et al. 2014, 

Peterson et al. 2014, and Higuera et al. 2015); the greater the spatial complexity of bottom-up controls, 

the less likely that top-down controls will override them (Cansler and McKenzie 2013).

Streamflow and Temperature

By mid-century, climate modeling indicates peak flows from snowmelt would occur 3–4 weeks earlier in 

the Pacific Northwest as compared to the current timing (Dalton et al. 2013 and references therein). All 

streams in western Oregon would be rain-dominant by the end of the century (Dalton et al. 2013 and 

references therein, Figure 3.2; Klos et al. 2014). Since rain-dominant streams tend to experience peak 

flows earlier than snow-dominant systems, some streams originating in the Cascades would experience 

earlier peak flows and reduced spring and summer flows (Dalton et al. 2013). If winter precipitation 

increases as projected, peak flows would increase in magnitude, but timing would otherwise not change in 

systems that are already rain-dominated (Dalton et al. 2013). Mean annual streamflow could initially 

decrease by the 2020s, possibly due to increased evapotranspirational demand, and then increase through 

the end of the century by 0.6 to 5.5 percent, apparently driven by projected increases in winter 

precipitation (Wu et al. 2012). Mean summer streamflow is expected to continually decrease, becoming 

approximately 30 percent less by the end of the century (Wu et al. 2012)

Non-climate factors, such as degree of stream shading, amount of groundwater input, and how streams 

and reservoirs are managed are also important drivers of stream temperatures, and can result in stream 

cooling at the same time that air temperatures are warming (Arismendi et al. 2012). Regardless, in the 

Northwest, warming air temperatures and declining summer base flows are strongly associated with 

warming stream temperatures (Kaushal et al. 2010, Isaak et al. 2012), with additional warming expected 

through the 21st century. If past trends continue, then some streams would be 1.6–2.0 oF warmer by midcentury than the 1980– 2009 baseline (Isaak et al. 2012, Wu et al. 2012).

Wildlife and Wildlife Habitat

Very few studies have examined the potential implications of climate change for northern spotted owls, 

and the BLM found no studies that directly addressed marbled murrelet. Rapid climate change could 

place additional stress on species already at risk of extinction from habitat loss, such as Fender’s blue 

butterfly (Hixon et al. 2010). Fish and wildlife species considered most vulnerable to climate change 

include—

 Several terrestrial and many aquatic invertebrates;

 Amphibians and cold-water fish, especially those with restricted ranges or narrow temperature 

requirements;

 Long-distance migratory shorebirds that winter or stop over in western Oregon; and

 Forest birds, especially those associated with either early seral habitat or old-growth habitat 

(Hixon et al. 2010 and references therein, NABCI 2014).

Projecting climate change effects on most terrestrial species is limited by the current inability of 

vegetation models to project changes in stand structure in response to climate changes, and the lack of 

knowledge of how climate directly influences the presence, absence, and fecundity of a given species 

(Carroll 2010, Hixon et al. 2010). Carroll (2010) projected that the extent of suitable habitat for northern 

spotted owl could contract in the Coast Range and southwest Oregon and shift upward in elevation in the 

Cascades by the end of the century, primarily due to changes in precipitation regimes that affect survival 

(see also Franklin et al. 2000, Glenn et al. 2010, Glenn et al. 2011).

Changes in disturbance regimes could disfavor species associated with old-growth forests, by shifting 

more of the landscape into earlier seral stages, altering species compositions to ones less preferred, 
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reducing the extent of large trees and structurally-complex forest, and decreasing patch sizes preferred for 

different life stages, such as nesting (Vose et al. 2012, Dalton et al. 2013, section 5.4.2, Peterson et al.

2014). These same types of changes could also adversely affect preferred prey species for predators like 

the northern spotted owl, although the ability of the owl to shift prey preferences is not well documented. 

Ocean warming and changes in ocean chemistry along with increasing extent and duration of dead zones 

(Hixon et al. 2010, Section 7.4 and references therein, Dalton et al. 2013, Chapter 4) could adversely 

affect the prey base used by species such as marbled murrelet.

Potential Effects of Alternatives in Adapting to Climate Change

In general, BLM actions to respond to changes in climate (such as modifying seed stock for replanting 

after harvest) would be implementation-level decisions that would be made subsequent to the approval of 

the RMP. This discussion considers how the alternatives and the Proposed RMP would set the stage for 

the BLM to take such actions in the future.

The current Douglas-fir-western hemlock-western redcedar forests typical of western Oregon developed 

in the last 5,600 years, apparently in response to cooling climate (Shafer et al. 2010 and references 

therein, p. 178). Historical tree migration rates during the Holocene range from 6 to 93 miles per century, 

whereas the current climate velocity is estimated at 186–311 miles per century (Tillmann and Glick 2013 

and references therein, p. 200). Given the expected climate velocity and the potential changes discussed 

above, scientists who study climate change impacts on natural resources recommend varying levels of 

active management in order to preserve or protect social and ecosystem values (e.g., Joyce et al. 2009, 

Spies et al. 2010, Peterson et al. 2011, Stein et al. 2014, and Millar and Stephenson 2015). Stein et al.

(2014) classify potential management actions into three general categories:

1. Resistance actions – those intended to maintain the status quo of species and systems

2. Resilience actions – those intended to improve the capacity of the system to return to desired 

conditions or to maintain some level of desired functionality in an altered state

3. Realignment actions – those intended to enable or facilitate the transition to a new functional state

However, many of the recommended types of forest management actions tend to overlap at least two of 

the categories. Generally, recommended actions for responding to climate change consist of reducing 

existing stresses, increasing resistance and resilience to climate change and other stressors, and enabling 

change where it is inevitable (Joyce et al. 2009, Spies et al. 2010, Peterson et al. 2011, Vose et al. 2012, 

Peterson et al. 2014, Stein et al. 2014). As summarized by Joyce et al. (2009), Spies et al. (2010), and 

Peterson et al. (2011) specific types of recommended actions include—

 Thinning forest stands to reduce competition and drought stress, increase diversity (species, 

structure, age classes, sizes, patch sizes, spacing) at the stand and landscape scales, and increase 

resistance to fire, insects, and pathogens;

 Protecting large old trees, large snags, and large downed wood;

 Planting new genotypes/ecotypes/climatypes and species to aid development of communities 

that can persist under both the current and expected future climate; and

 Identifying potential climate change refugia at regional and local scales

These approaches are known as ‘no regrets’ decisions and bet-hedging, given the large uncertainties over 

the rate and magnitude of climate change in any one location (Vose et al. 2012).

Whether thinning would increase or reduce forest resiliency in the face of climate change is scientifically 

controversial. Studies have shown strong evidence that unmanaged forests have great capacity for socalled self-correction and self-organization following natural disturbances (e.g., Peterson 2002, Scholl 

and Taylor 2010, and Amoroso et al. 2013) and some types of harvest prescriptions (e.g., Drever et al. 
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2006 and Messier et al. 2015). Of particular concern is misapplying thinning prescriptions more suitable 

for low-severity fire regimes to mixed-severity fire regimes (e.g., Odion et al. 2014 and DellaSala et al.

2015). In part, the controversy is about the breakpoint between low and mixed severity. The severity of 

any particular disturbance occurs on a continuum which scientists and managers bin into categories 

usually labeled as low, mixed, and high severity. Since there is no scientific method for determining 

breakpoints along a continuum, the definition of severity categories is subjective. While the scientific 

community has long recognized that the low-severity bin includes some amount of high severity patches, 

scientists disagree on how much high severity can be present before the appropriate bin should be mixed 

severity. The BLM uses the fire severity classes developed under the LANDFIRE project; which defines 

low severity as 6–25 percent stand replacement (high severity patches) (NIFTT 2010, p. 99). Others 

believe that low severity regimes contain less than 25 percent stand replacement (e.g., Odion et al. 2014

and Hanson et al. 2015). This differing view creates disagreement on what parts of the landscape fall into 

the different fire regimes and, therefore, what thinning prescriptions are appropriate. In addition, climate 

change will result in shifting the locations of the different fire regimes, but no one can say with much 

accuracy or precision when, where, and how rapidly these shifts may occur. Shifts are more likely to 

manifest after a stand replacement disturbance occurs and the site is no longer capable of returning to a 

condition similar to the past. One concern is that more intense thinning might trigger a similar outcome 

through the combined effects of reducing stand density and shading, shifting species composition, and the 

associated impacts of logging operations.

Within the scientific community, the use of assisted, or facilitated, migration as a climate change

adaptation technique is controversial. Assisted migration consists of the deliberate movement of species 

or ecotypes into locations where they presently do not occur instead of waiting for natural migration into 

these locations. Hewitt et al. (2011) provides the most recent paper summarizing the nature of the 

scientific debate. Sixty percent of the papers the authors examined were supportive of assisted migration, 

20 percent opposed, and 20 percent did not have a clear position. Arguments in favor of assisted 

migration include climatically suitable ranges outpacing migration rates, the risks of adverse outcomes are 

manageable with decision tools, the need for proactive measures to prevent biodiversity losses and 

extinctions, and the lack of appropriate or sufficient migration corridors. Arguments against assisted 

migration include risks of a species becoming invasive, costs, uncertainties over outcomes, the risk of 

legitimizing unauthorized and unregulated introductions, diversion of resources from higher conservation 

priorities, and bias toward species humans or societies deem important. Invasion risks are a particularly 

common argument against assisted migration, but seem to have the most relevance with respect to 

introducing completely new species or transferring species between continents (Vitt et al. 2010, Hewitt et

al. 2011 and references therein, Winder et al. 2011). Moving different genotypes of species within its 

current range or assisting in relatively short-distance range expansions appears to be much less 

controversial, although these moves are not risk-free either (Aitken et al. 2008, Vitt et al. 2010, Hewitt et

al. 2011, Winder et al. 2011). Some studies identified assisted migration as a primary need in order to 

preserve the presence of a forest, although not necessarily the present type of forest, in the face of climate 

change and associated changes in disturbance risks (Woods et al. 2010, Buma and Wessman 2013).

Management to adapt to climate change may not necessarily be consistent with management to maximize 

carbon storage. D’Amato et al. (2011) caution that rigid adherence to a single objective, such as 

maximizing carbon storage, is likely to result in adverse effects to other ecosystem components critical to 

long-term functioning in the face of changing climate. Increased burned area from wildfires in the mesic 

maritime forests of the Pacific Northwest could result in loss of up 1,900 Tg of carbon by the end of the 

century, an amount equal to 23 times the current combined emissions from all sources in Oregon and 

Washington (Rogers et al. 2011). Many studies have found that active management, particularly in forests 

adversely affected by fire suppression, could reduce both carbon losses and increases in greenhouse gas 

emissions from wildfires. Results from various thinning and burning prescriptions indicate that the shortterm reductions in carbon result in long-term benefits to carbon storage and greenhouse gas emissions by 
201 | P a g e

reducing fire-induced mortality, maintaining a higher fraction of carbon in live trees, increasing drought 

resistance, and reducing competition for water, nutrients, and light (Stephens et al. 2009, Hurteau and 

North 2010, North and Hurteau 2011, Stephens et al. 2012, Bowman et al. 2013, Hurteau et al. 2014, 

Loudermilk et al. 2014, Volkova et al. 2014). Other studies indicate that such potential benefits are 

unlikely to occur in moister forests with longer fire return intervals (e.g., Mitchell et al. 2009, Campbell et 

al. 2011, McKinley et al. 2011, Bowman et al. 2013, and Keith et al. 2014).

The degree to which an alternative or the Proposed RMP promotes active management provides 

opportunities to adapt to changing climate. In dry forests under all action alternatives and the Proposed 

RMP, management would emphasize increasing fire resistance and resilience, which would often also 

increase resistance to drought, insects, and pathogens. The No Action alternative does not explicitly 

prohibit management to increase fire resistance and resilience, but does not have the same emphasis as in 

the action alternatives and the Proposed RMP, especially within the Late-Successional Reserve and the 

Riparian Reserve allocations. This uncertainty in the management direction of the No Action alternative 

adds uncertainty to the implementation of actions to increase fire resistance and resilience, especially 

within reserve land use allocations in the dry forest.

Retaining portions of stands through uneven-aged management would reduce risks associated with 

reforestation failure in dry forests. All action alternatives and the Proposed RMP would manage the 

Harvest Land Base in the driest forests with uneven-aged management. In contrast, the No Action 

alternative would include regeneration harvest throughout the Harvest Land Base in the driest forests, 

increasing the risk of reforestation failure.

Reforestation after timber harvest or disturbance would provide opportunities to shift tree species 

composition or genotypes/ecotypes/climatypes under all alternatives and the Proposed RMP, except 

Alternative B in the Light Intensity Timber Area, where the BLM would use only natural regeneration. In 

addition to the risk of reforestation failures, the inability to replant after timber harvest or disturbance in 

this portion of the Harvest Land Base under Alternative B would limit the ability to adapt to climate 

change through replanting (see the Forest Management section in this chapter).

Reserves with minimal or no active management may provide areas of greater ecological stability on the 

landscape and provide benchmarks for comparison with actively managed areas. However, it is unclear to 

what extent such minimally managed reserves would be more stable and more resistant to climate change

effects. As discussed under the previous subsection on tree species, major shifts in plant communities are 

expected to be abrupt arising from the interaction of climate change and another disturbance (Paine et al. 

1998, Allen et al. 2010, Lindenmayer et al. 2011, Peterson et al. 2014, Clark et al. 2014). These shifts can 

lead to new plant communities and ecosystems not previously seen within the planning area (Paine et al. 

1998, Lindenmayer et al. 2011, Peterson et al. 2014). This disturbance could be forest management, one 

or more natural events, such as wildfire or insect outbreak, or both in combination. The combination of 

forest management and natural events could trigger development of so-called novel plant communities in 

the actively managed areas, whereas in minimally managed areas, the trigger would more likely be one or 

more natural events. Comparing recent satellite imagery of western Oregon with that collected in the mid1990s, reserves with minimal or no active management tended to become homogeneous with respect to 

stand density, age, and condition. Such landscapes appear to be increasingly vulnerable to large, standreplacing fire and the development of large, stand-replacing patch sizes based on recent fires and maps of 

burn severity. Shive et al. (2014) found that treating stands before a wildfire could be critical to retaining 

desired tree species in the face of climate change and the presence of wildfire even if at lower stand 

densities or basal area than in the past. Fire, insects, and pathogens often interact such that the occurrence 

of one of these disturbance types facilitates the occurrence of another (Vose et al. 2012, Tillmann and 

Glick 2013, Peterson et al. 2014). The larger the area in Reserves with minimal management, the more 

limited BLM’s management options would be to adapt to climate change over time.
202 | P a g e

In contrast to the risks of minimal management, areas with minimal vegetation management may provide 

refugia against climate change. Within the decision area, minimal vegetation management would occur in 

Congressional Reserves such as designated Wilderness and some Wild and Scenic River corridors, certain 

other reserves, such as some ACECs and Wilderness Study Areas, District-Designated Reserve – Lands 

Managed for their Wilderness Characteristics, portions of the Late-Successional Reserve that are 

structurally-complex forest or occupied marbled murrelet sites, and the inner zone of the Riparian 

Reserve under the action alternatives and the Proposed RMP. Climate change refugia provide conditions 

where species either may retreat or persist during long-term climatic change (e.g., Keppel et al. 2015, 

Olson et al. 2012, Gillson et al. 2013, and Buttrick et al. 2015). Species with narrow distributions or 

specialized habitat requirements that greatly constrain the ability to migrate to new locations are most 

vulnerable to climate change (Damschen et al. 2010, and Keppel and Wardell-Johnson 2012). In the 

absence of refugia, such species are more likely to face local extirpation or general extinction (e.g., 

Damschen et al. 2010). Climate refugia are more likely to occur in complex terrain where landform, 

topographic shading, and cool air drainage can moderate expected increases in temperature, thus 

maintaining habitat stability and climatic stability or slowing the rate of change (Ashcroft 2010, Spies et 

al. 2010, Buttrick et al. 2015). Climate refugia can occur at more than one scale, usually referred to as 

macrorefugia and microrefugia, but need to be large enough to support a small population of the species 

of interest (Ashcroft 2010). The BLM’s predominately checkerboard land ownership pattern limits the 

opportunity to provide macrorefugia. The Late-Successional Reserve network may provide climate 

change macrorefugia for species that are also able to disperse around or through the intervening lands, 

most of which are managed for timber production. In contrast, designated Wilderness, Wilderness Study 

Areas, some ACECs, and District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics and the inner zone of the Riparian Reserve in the action alternatives and the Proposed 

RMP, are likely to provide climate change microrefugia in some locations. Buttrick et al. (2015) 

identified much of western Oregon as having moderate to high terrestrial resilience to climate change 

(defined as likely to retain and support higher biodiversity as climate changes), although much of the 

lower elevations, where most BLM-administered lands occur in the planning area, range from below 

average to above average resilience.

The size of the inner zone of the Riparian Reserve provides the main difference among the alternatives 

and the Proposed RMP for climate change microrefugia. Alternative D, with the widest inner zone on all 

stream types, would provide the largest amount of potential climate change microrefugia, followed by 

Alternative A. The Proposed RMP would the same size inner zone along fish-bearing and perennial 

streams as Alternatives A and D, and would provide wider inner zones along intermittent and non-fishbearing streams than Alternatives B and C in most watersheds. See also the discussion in the Hydrology 

section of this chapter under Issue 1 concerning effective stream shading as an indicator of potential 

climate microrefugia.

The ability of active management to mitigate projected changes in stream temperature appear to be 

limited since changing air temperatures account for much of the expected changes in stream temperature 

(Holsinger et al. 2014). Equally important, however, is that wildfires and fuels management appear to 

have limited ability to adversely affect stream temperatures much beyond the immediate affected area. 

The inner zone of the Riparian Reserve in the action alternatives and the Proposed RMP would provide 

some degree of mitigation for climate change, but the degree of that mitigation depends on landform, 

degree of topographic shading, degree of cool air drainage from higher elevations, and primary water 

source (e.g., surface water from rain versus ground water recharged from snowpacks). Checkerboard 

ownership patterns limit the ability of management direction on the BLM-administered lands to help 

reduce the magnitude or rate of stream temperature rise as streams cross through younger forests with 

shorter rotations.
203 | P a g e

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Cultural and Paleontological Resources

Key Points

 The BLM can reduce or eliminate effects to cultural and paleontological resources through 

systematic and thorough cultural and paleontological resource inventories.

 Implementation of Alternative A is the least likely to result in potential adverse effects to cultural 

and paleontological resources from timber harvest because it has the fewest acres of timber 

harvest in the first decade; and from public motorized travel use because it has the largest acreage 

designated as closed for public motorized access within the decision area. 

 Implementation of Alternative D is the least likely to result in potential adverse effects to cultural 

and paleontological resources from road construction and livestock grazing because it includes 

the least amount new road construction and eliminates all livestock grazing.

Summary of Notable Changes from the Draft RMP/EIS

The BLM has adjusted the model from Gnomon Inc. by using different parameters than were used in the 

Draft RMP/EIS to calculate more accurately the areas with a high probability for finding cultural 

resources in western Oregon. For this analysis, the BLM redistributed the values for slope and distance to 

water to reflect more accurately the archaeological landscape in western Oregon. The BLM also added a 

temporal aspect to the comparison of the alternatives and the Proposed RMP to depict more meaningfully 

the potential effects from timber harvest by modeling probability zones against the first decade of timber 

harvest. The BLM also added a discussion of the potential effects on cultural resouorces from livestock 

grazing.

The BLM has revised the analysis on paleontological resources and present it as an ‘issue considered but 

not analyzed in detail’ because the small quantity of localities within the planning area did not allow for a 

meaningful analysis of effects.

Issue 1

How would BLM land management actions affect cultural resources across the decision area under each 

alternative?

Summary of Analytical Methods

Each BLM district in the decision area provided Gnomon Inc. with cultural site and survey information, 

which Gnomon Inc. then digitized. The BLM synthesized this digitized information in the sections below. 

The BLM used a model created by Gnomon Inc. for the purposes of forecasting the likelihood for cultural 

resources to occur within the decision area. The model used two key factors to determine the relative 

probability that cultural properties would be present within any given acre in the decision area. The two 

factors used were slope and the distance to perennial water. Archaeological data in western Oregon shows 

that past human activity most often took place on level ground and near freshwater sources, as revealed 

by the location of archaeological sites across the landscape (USDI BLM 2014a). For the model, the BLM 

assigned values between 0 and 50 to different slope breakpoints as well as to the distance to water 

breakpoints (Table 3-17). The breakpoints for distance to water represent discrete sets of distance in 

meters along a range from 0 to > 500. Similarly, the breakpoints for degrees of slope represent discrete 

sets of slope degrees that range from 0 to > 20. The BLM assigned the breakpoints based on previously 
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recorded site data by looking at which value ranges in each dataset were most associated with site 

presence. The model then calculated total values between 0 and 100 for the entire decision area and 

subsequently assigned a probability based on that value (Table 3-18). More details of the modeling 

methodology are in Ingbar et al. (2014).

Table 3-17. Values for slope and distance to water break points

Slope (Degrees) Value Distance to Water

(Meters) Value

0–10 50 0–100 50

11–20 25 101–250 25

> 20 0 251–500 12

> 500 0

Table 3-18. Total value scores and corresponding probability

Total Value Score

(Sum of Slope Value and

Distance to Water Value)

Probability

Zone

51–100 High

26–50 Medium

0–25 Low

The model placed each of the 2.5 million acres of BLM-administered lands in the decision area into one 

of three categories: high, medium, or low probability for finding cultural resources (Table 3-19). Then, 

for each alternative and the Proposed RMP, the BLM overlaid these three categories with the acreage of 

timber harvest in the first decade. The BLM calculated acres of timber harvest in the first decade for each 

probability category to determine which alternatives or the Proposed RMP are most likely to create the 

potential for disturbance of cultural resources (Table 3-8). This portion of the analysis focused on 

potential effects from timber harvest because of the associated ground disturbance, and timber harvest 

levels vary substantially by alternative and the Proposed RMP. The acreage of timber harvest in first 

decade was used as a surrogate for the total acreage potentially affected.

Table 3-19. Distribution of all acres within the decision area by probability zone

Probability Zone Decision Area

(Acres)

High 491,971

Medium 900,781

Low 1,086,104

Additionally, the BLM considered the risk of disturbance to cultural resources from road construction by 

comparing the mileage of new road construction in the first decade by alternative and the Proposed RMP. 

The BLM used new road construction miles as a factor because of the associated ground-disturbance. The 

BLM also considered potential effects from public motorized access designations. In comparing the 

potential effects of the alternatives’ public motorized access designations on cultural resources, the BLM 

assumed that open areas are the most likely to cause unintended disturbance of cultural resources from 

public motorized travel activities, while such disturbance is much less likely in limited areas and very 
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unlikely in closed areas. Lastly, the BLM considered potential effects to cultural resources from acres 

available to livestock grazing by alternative and the Proposed RMP.

As described below, this analysis considered the potential for effects from timber harvest, new road 

construction, public motorized access designations, and livestock grazing, but also assumed that predisturbance surveys will prevent effects in most instances.

Certain cultural resource types do not adhere to the parameters of the model as described. Sites such as 

rock shelters, trails, mines, traditional cultural properties, and sacred sites may not fall within areas 

deemed High probability by the model. BLM archaeologists are keenly aware of the difficulty of 

predicting the location of such sites. BLM archaeologists use resources such as tribal consultation and 

background research (e.g., literature, maps, and photos) to aid in identifying the location of these types of 

sites.

It is important to note that events and actions by others that the BLM cannot specifically predict (e.g., 

wildfire and looting) may also negatively affect cultural resources.

Although the BLM has some site-specific and anecdotal information about illegal public motorized travel 

activities, the BLM does not have a basis for predicting the location or effects of any widespread or 

systematic illegal public motorized travel activities. In addition, much of the decision area has physical 

limitations to potential illegal public motorized travel activities, including dense vegetation, steep slopes, 

and locked gates. Terrain, vegetation, and a greater amount of open spaces in most of the interior/south 

can lead to degradation and erosion in a greater proportion than the coastal/north where vegetation is 

denser and terrain is steeper. However, the BLM lacks a basis for characterizing current illegal public 

motorized travel activities or forecasting potential illegal public motorized travel activities in the future 

under any of the alternatives and the Proposed RMP at this scale of analysis. In this analysis, the BLM 

assumed that members of the public participating in motorized travel recreation would operate vehicles 

consistent with BLM decisions about public motorized travel opportunities.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014b, pp. 41–43). The analytical methods described above differ from those set out in the Planning 

Criteria. BLM annual reporting over the last 7 years spurred this change in analysis. The annual reports 

state that the implementation of project activities inadvertently damaged very few sites (i.e., two).

Conversely, the BLM and project proponents discovered 641 sites prior to implementation of project 

activities, and the BLM applied mitigation measures to avoid adverse impacts to these sites. Predicting 

the numbers of sites within each physiographic province, as the BLM described in the Planning Criteria, 

does not show the effects to cultural resources. Without more accurate data that includes all effects to 

sites through inadvertent discovery, the BLM must assume that it will conduct adequate and thorough 

cultural resource inventories prior to ground-disturbing activities and that these inventories will result in 

the avoidance of damage to cultural resources in nearly all cases. Regardless, it is still useful to 

understand how the alternatives and the Proposed RMP vary among the activities most likely to affect 

cultural resources as well as the distribution of timber harvest across the three probability categories.

Background

While the public discover sites incidentally (e.g., while hiking on BLM-administered lands) and the BLM 

discovers sites occasionally through project implementation, the primary mechanism for identifying 

cultural resources is through inventories conducted by trained archaeologists. BLM archaeologists plan 

and implement cultural surveys in a strategic manner focusing on areas with a high probability to yield 
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cultural resources. The Analysis of the Management Situation (USDI BLM 2013) contains a synthesized 

explanation of cultural resources in Oregon.

Cultural resource inventories are primarily project driven and conducted in support of management 

activities such as timber harvest, recreation management, aquatic restoration, and road construction, in 

compliance with Section 106 of the National Historic Preservation Act. The BLM complies with the 

National Historic Preservation Act through the State Protocol with the Oregon State Historic Preservation 

Office (USDI BLM 2015) as directed by the National Programmatic Agreement (USDI BLM 2012). In 

addition, each district undertakes a strategic and proactive survey strategy in compliance with Section 110 

of the National Historic Preservation Act. Section 110 surveys focus on inventorying pieces of land 

deemed to have high probability for yielding cultural resources; Section 110 surveys are not projectrelated. These areas are determined using the cultural resource model described in the Analytical Methods 

section above.

Affected Environment

According to current district records, there are 2,468-recorded cultural sites on BLM-administered lands 

in the decision area. Since most of BLM-administered lands remain un-inventoried, it is very likely that 

there are far more undocumented cultural sites.

The following tables provide a snapshot of cultural resources and inventories on BLM-administered lands 

in the decision area. Table 3-20 illustrates that the BLM has inventoried 10.5 percent of the decision area 

for cultural resources. These acres only reflect class III-intensive field surveys, as conducted per BLM 

Manual 8110.21C (USDI 2004). With 89.5 percent of the decision area considered unsurveyed, the BLM 

anticipates that inventories would continue for the near future in compliance with Sections 106 and 110 of 

the National Historic Preservation Act.

Table 3-20. Summary of acres of cultural resource inventories on BLM-administered lands

Administrative Boundary Inventoried Lands

(Acres)

Total Lands

(Acres)

Inventoried Lands

(Percent)

Coos Bay District 3,430 324,236 1.0%

Eugene District 4,801 311,064 1.5%

Klamath Falls Field Office 155,258 214,084 72.5%

Medford District 78,782 806,675 9.8%

Roseburg District 14,977 423,640 3.5%

Salem District 2,441 399,157 0.6%

Decision Area 259,689 2,478,856 10.5%

It is notable that the Klamath Falls Field Office, which is within the Eastern Cascades Slopes and 

Foothills physiographic province, has completed inventory of over 72 percent of their land base due to 

multiple large-scale projects (e.g., vegetation management and fuels treatments) where contractors 

surveyed thousands of acres at a time. Therefore, surveys have covered more acres across all probability 

zones in this region. Additionally, the parameters modeled for analysis (slope and distance from perennial 

water) do not reflect the cultural landscape of this area as well as it does in the rest of the planning area. 

Perennial water is not as pervasive in this area as it is in the coastal/north portion of the planning area; 

therefore, the model categorizes most of the landscape as Medium. In general, this area is considerably 

flatter and less vegetated than the forested areas of the coastal/north portion of the planning area. Distance 
217 | P a g e

to water would be less a hindrance in flatter terrain with less vegetation, therefore one would expect there 

still to be a high number of sites in Medium probability as modeled.

Table 3-21 illustrates the relationship between the total acres of cultural resource inventories conducted 

and numbers of sites recorded within the three probability zones. Medium probability areas have by far 

the most acres of inventory and the most sites. This may be attributed to a slight discrepancy in how the 

model predicts probability such as is explained above regarding the Eastern Cascades Slopes and 

Foothills physiographic province. Within the Eastern Cascades Slopes and Foothills physiographic 

province, the BLM conducted two-thirds of the inventories on Medium probability ground leading to the 

recording of a greater number of sites in Medium probability than High probability. How archaeologists 

conduct cultural inventories on the ground could account for the high inventory counts in Medium 

probability zones. In the model, areas with less than 10 percent slope but greater than 500 meters distance

from water are categorized as Medium probability. In practice, archaeologists would inventory all acres 

with less than 10 percent slope unless the area was a small isolated parcel.

Table 3-21. Summary of acres of cultural resource inventories and recorded sites by probability zone

Probability Zone

Inventoried 

Lands

(Acres)

Recorded

Sites

(Number)

Total

Lands

(Acres)

Inventoried 

Lands

(Percent)

Ratio of Sites

Identified Per

Inventoried Acres

High 61,284 1,029 491,971 12.5% 60:1

Medium 139,975 1,167 900,781 15.5% 120:1

Low 58,430 272 1,086,104 5.4% 215:1

Decision Area Totals 259,689 2,468 2,478,856 10.5% 105:1

Table 3-21 shows that one site is identified for every 60 acres in High probability zones, 120 acres in 

Medium probability zones, and 215 acres of Low probability zones on average. Had the BLM applied 

different modeling parameters to the Eastern Cascades Slopes and Foothills physiographic province, there 

would likely be a stronger difference between probabilities of the number of sites identified per number of 

acres surveyed. However, the model has calculated the number of sites identified per acres of survey at 

levels that match documented observations within the planning area (See Table 3-17 and Table 3-18 for 

modeling values).

Table 3-22 shows the distribution of site types across the districts. Ground-disturbing activities may be 

more or less likely to damage sites depending on the site type and activity type. The term ‘prehistoric site’ 

generally refers to archaeological sites that Native Americans occupied prior to European contact 

(generally prior to 1770); in the decision area, most prehistoric sites are subsurface. Approximately 56 

percent of the recorded sites in the decision area are prehistoric. ‘Historic sites’ refer to both subsurface 

and above ground sites, including structures that date from the contact period up to the recent historic 

period (generally 1770 to 50 years ago). Multicomponent sites are sites that date to multiple occupation 

periods and include both prehistoric and historic components. Ground-disturbing activities are more likely 

to affect subsurface sites inadvertently due to the lack of visibility of artifacts on the surface, especially in 

the densely vegetated landscape that composes a large majority of the lands administered by the BLM in 

the decision area.
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Table 3-22. Distribution of site types

District/

Field Office

Prehistoric 

(Sites)

Historic 

(Sites)

Multicomponent 

(Sites)

Unknown 

(Sites)

Totals

(Sites)

Coos Bay 30 24 1 1 56

Eugene 132 15 - - 147

Klamath Falls 760 284 62 61 1,167

Medford 148 492 22 6 668

Roseburg 250 34 14 - 298

Salem 67 62 3 - 132

Totals 1,389 911 102 68 2,468

Table 3-23 shows the last known condition of all the recorded sites in the decision area. The BLM 

monitors recorded sites to assess their condition over time and note impacts that affect the integrity of the 

site such as erosion, looting, weathering or from the implementation of BLM actions. The BLM 

categorizes the largest percentage of sites as ‘unknown’ (39 percent); the lack of a known site condition is 

likely due to the large amount of subsurface prehistoric sites within the decision area. Without subsurface 

testing and evaluation of these sites, it is hard, if not impossible, to assess the level of intact deposits (soil 

and cultural materials) within the site. The BLM has determined that less than 1.5 percent of recorded 

sites have been destroyed. There are 37 percent of the sites in excellent or good condition and 22 percent 

in fair or poor condition.

Table 3-23. Conditions of recorded sites within the decision area

Site Condition Recorded Sites

(Count)

Recorded Sites

(Percent)

Excellent 232 9.4%

Good 693 28.1%

Fair 256 10.4%

Poor 282 11.4%

Destroyed 34 1.4%

Other 11 0.4%

Unknown 960 38.9%

Totals 2,468 100%

Environmental Consequences

Under all alternatives and the Proposed RMP, the BLM would conduct adequate and thorough cultural 

resource inventories in advance of ‘federal undertakings’ and in accordance with Oregon BLM and 

Oregon State Historic Preservation Office Protocol (2015). The BLM anticipates avoiding or mitigating 

impacts to the vast majority of cultural resources through: (1) identification of cultural resources and 

potential impacts through inventory; and (2) applying appropriate mitigation measures.

Table 3-24 shows the acreage of timber harvest activities by each alternative and the Proposed RMP as 

modeled for the first decade, along with timber harvest distribution across the probability zones. Overall, 

Alternative A, which has the smallest Harvest Land Base, would have the lowest potential for disturbance 

to cultural resources from timber harvest; it has the lowest total acreage of timber harvest and the lowest 

acreage of harvest in high probability zones. Alternative C would have the highest potential for 
219 | P a g e

disturbance from timber harvest, with both the highest total acreage of timber harvest and the highest 

acreage of timber harvest in High probability zones. The Proposed RMP would have the third lowest 

potential for disturbance from timber harvest for both the total acreage of timber harvest and the acreage 

of timber harvest in High probability areas.

Table 3-24. Acreage of timber harvest for the first decade in each probability zone

Alternative/

Proposed RMP

Low

(Acres)

Medium

(Acres)

High

(Acres)

Totals

(Acres)

No Action 60,733 56,891 37,770 155,395

Alt. A 36,532 33,825 21,425 91,782

Alt. B 70,945 58,297 33,523 162,765

Alt. C 72,724 65,403 38,570 176,696

Alt. D 61,442 49,519 28,190 139,151

PRMP 65,846 54,603 30,949 151,398

Table 3-25 shows that the total mileage of new road construction, which generally corresponds with the 

total acres of timber harvest (Table 3-24). The No Action alternative and Alternative C would have the 

greatest potential for the disturbance of cultural resources through new road construction, while 

Alternatives A and D have the lowest potential for this type of disturbance. The Proposed RMP has the 

third lowest potential for disturbance through new road construction compared to the alternatives.

Table 3-25. Total mileage of new road construction

Alternative/

Proposed RMP

New Road Construction

(Miles)

No Action 637

Alt. A 299

Alt. B 531

Alt. C 699

Alt. D 240

PRMP 437

For all action alternatives and the Proposed RMP, the BLM would apply interim management guidelines 

for public motorized travel activities until implementation-level travel management planning is completed 

(Appendix Q). On the majority of the BLM-administered lands, public motorized travel activities would 

be limited to existing roads and trails (see Trails and Travel Management Table 3-218). None of the 

action alternatives or the Proposed RMP has lands designated as open for public motorized access. This 

differs from current practices and the No Action alternative, in which there are 319,661 acres of land 

designated as open. Due to this change, the BLM would expect a reduction in inadvertent effects to 

cultural resources from public motorized travel activities under all action alternatives and the Proposed 

RMP. In accordance with current policy, the BLM is deferring implementation-level transportation 

management planning until after completion of these RMPs. All areas identified as limited for public 

motorized access would have completed Travel Management Plans within 5 years of completion of these 

RMPs. Route designation would occur as part of implementation-level travel management planning, and 

the BLM would consider affects to cultural resources in compliance of Section 106 of the National 

Historic Preservation Act. The Trails and Travel Management section of this chapter and Appendix Q

contain more information on transportation management planning.
220 | P a g e

There are multiple activities associated with livestock grazing that cause effects to cultural resources. 

Impacts can come from congregation of livestock around watering or salting locations, the creation of 

trails, livestock movements (e.g., rubbing, trampling, and crushing), and fence construction. Creating 

trails, post-holing from hooves, hoof shearing, and trampling also cause erosion of the soil which can 

indirectly effect cultural resources by exposing them, which leaves them more susceptible to weathering, 

looting, or further trampling by livestock. The No Action alternative would have the largest potential for 

the disturbance of cultural resources based on available livestock grazing allotments, while Alternative D 

has no potential for this type of disturbance. Alternatives A, B, and C, would all have equal potential for 

disturbance from livestock grazing, and the Proposed RMP would have a slightly less potential from 

livestock grazing by making an additional four allotments unavailable. Table 3-26 shows the number of 

available authorized livestock grazing allotments, associated acres, and animal unit months (AUMs, the 

number of cow/calf pair permitted per month based on available forage).

Table 3-26. Number of available authorized livestock grazing allotments, acres, and active use

District/

Field Office

Alternative/

Proposed RMP

Allotments

(Number)

Public Land

(Acres)

Active Use

(AUMs)

Coos Bay

No Action 4 544 120

Alt. A, B, C - - -

Alt. D - - -

PRMP - - -

Klamath Falls

No Action 94 203,582 13,219

Alt. A, B, C 92 203,377 13,199

Alt. D - - -

PRMP 92 203,377 13,199

Medford

No Action 91 285,920 12,000

Alt. A, B, C 50 156,926 9,372

Alt. D - - -

PRMP 46 156,926 9,372

Totals

No Action 189 490,046 25,339

Alt. A, B, C 142 366,231 22,787

Alt. D - - -

PRMP 138 360,303 22,571
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Issues Considered but not Analyzed in Detail

How would land management actions affect paleontological resources?

The BLM does not maintain a central or consolidated dataset of paleontological resources within the 

decision area. Individual districts are responsible for maintaining their paleontological records as well as 

considering them during project planning. The BLM must assume prior to ground disturbing activities it 

would conduct adequate paleontological resource inventories in areas of known paleontological localities 

as well as in areas where geologic formations lend themselves to contain paleontological resources. The 

BLM assumed that these inventories would result in the avoidance of damage to paleontological resources 

in nearly all cases.

Paleontological resources include the fossil remains of plants (leaves and wood), vertebrates, and 

invertebrates. They also include the traces of animals or plants, such as the tracks or claw marks and skin 

impressions. Geologic processes important in the formation of fossils can also be paleontological 

resources. The BLM refers to fossil locations on the ground as ‘localities.’ Fossils are fragile and nonrenewable resources, and are susceptible to damage from weathering and erosional processes as well as 

from the public and Federal land management activities.

The BLM is required to identify locations likely to contain vertebrate fossils or exceptional invertebrate 

or plant fossils on land it administers. A BLM permit system regulates the collection of vertebrate or other 

scientifically important fossil specimens, including trace fossils on BLM-administered lands. The primary 

indicator for the significance of a paleontological resource is the characteristics of the fossil locality or 

feature that gives it importance and value for scientific or educational use. Natural weathering, decay, 

erosion, and improper or unauthorized removal can damage those characteristics that make the 

paleontological resource scientifically important.

There are a number of geologic formations that occur across the decision area, all of which span the 

Mesozoic and Cenozoic Eras (approximately 213–2 million years ago). The majority of paleontological 

resources within these formations are invertebrates and plants. Although vertebrate fossils are relatively 

less common, there are isolated occurrences of vertebrate fossils that are located mostly in cave settings 

within the decision area. The most prominent time period represented by vertebrate fossil localities within 

the decision area date from the late Miocene to early Pliocene epochs (approximately 23–1.8 million 

years ago, while the time frames for plants and invertebrates covers the Jurassic and Tertiary periods 

(245–145 million years ago). Some marine mammal fossils dated from the Mesozoic epoch occur in the 

decision area’s coastal areas. In addition, there are small samples of terrestrial mammals from the late 

Cenozoic epoch.

Currently, the BLM does not maintain a comprehensive database with paleontological localities mapped 

in the decision area. Each district and the Klamath Falls Field Office have recorded localities to varying 

degrees (Table 3-27). The recorded localities may provide a sense of the distribution of paleontological 

resources throughout the decision area. Table 3-27 lists the number of paleontological localities reported 

by BLM in the decision area. The BLM compiled these numbers by using annual reports and querying 

each districts’ specialists for refinement of the number of recorded or known localities, which last 

occurred in 2008. No new paleontological sites have been reported since 2008; therefore, these counts are 

considered the most accurate information available. The condition of these localities is currently 

unknown.
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Table 3-27. Number of reported paleontological localities

District/

Field Office

Paleontological Localities

(Number)

Coos Bay 19

Eugene 1

Klamath Falls 1

Medford 2

Roseburg 18

Salem 6

Totals 47

As described above, the BLM would avoid the majority of damage to paleontological localities under the 

alternatives and the Proposed RMP by conducting adequate paleontological inventories in areas of known 

localities or in High probability landforms prior to implementation of projects that could damage 

paleontological resources. Each district would implement suitable protection measures for known 

paleontological localities.

References

Ingbar, E., J. Hall, M. Drews. 2014. A Western Oregon Cultural Resource Forecast Model for USDI Bureau of Land 

Management. Gnomon, Inc. Carson City, NV.

USDI BLM. 2004. Identifying and Evaluating Cultural Resources. MS-8110. Release 8-73, December 3, 2004. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.15876.File.dat/81

10.pdf.

---. 2008. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western Oregon 

Bureau of Land Management Districts. Oregon State Office. Portland, OR. Vol. I–IV. 

http://www.blm.gov/or/plans/wopr/final_eis/index.php.

---. 2012. Programmatic Agreement Among the Bureau of Land Management, the Advisory Council on Historic Preservation, 

and the National Conference of State Historic Preservation Officers Regarding the Manner in Which the BLM Will Meet Its 

Responsibilities Under the National Historic Preservation Act.

---. 2013. Resource Management Plans for Western Oregon Bureau of Land Management Analysis of the Management Situation. 

Oregon State Office. Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.

---. 2014a. Oregon Heritage Information Management System. Oregon State Office. Portland, OR.

---. 2014b. Resource management plans for western Oregon planning criteria. Bureau of Land Management, Oregon/Washington 

State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.

---. 2015. State Protocol Between the Oregon-Washington State Director of the Bureau of Land Management (BLM) and the 

Oregon State Historic Preservation Officer (SHPO) Regarding the Manner In Which The Bureau of Land Management Will 

Meet Its’ Responsibilities Under the National Historic Preservation Act and the National Programmatic Agreement Among 

the BLM, the Advisory Council on Historic Preservation, and The National Conference of State Historic Preservation 

Officers. Oregon BLM-Oregon SHPO. Portland, OR.
223 | P a g e

Fire and Fuels

Key Points

 In the absence of natural fire as a disturbance agent, management activities, including prescribed 

fire and mechanical management of vegetation, can serve as a partial surrogate for natural 

disturbance, and promote and maintain desired forest stand structure, composition, and resistance 

to fire. These conditions may also provide opportunities for effective fire management, including 

the ability to utilize wildfire to meet land use and resource objectives consistent with management 

direction (Appendix B). However, due to the configuration of BLM-administered lands within 

the larger landscape, particularly their proximity to where people live, the ability to use wildfire 

may have limited application, and prescribed fire would likely account for the majority of 

managed fire under any alternative and the Proposed RMP.

 The BLM-administered lands constitute only a small portion of the entire interior/south dry forest 

landscape. Consequently, the modest shifts in forest structure and composition under any 

alternative or the Proposed RMP would not result in any substantial change in the overall 

landscape fire resilience. The dry forest landscape would continue to have an overabundance of 

mid-seral closed forest and a deficit of late-seral open forest.

 All alternatives and the Proposed RMP would increase stand-level fire resistance within the dry 

forest and reduce fire hazard on BLM-administered lands within the Wildland Urban Interface 

compared to current conditions. Within the Harvest Land Base, there would be greater variation 

in these variables among the alternatives and the Proposed RMP over time.

 The treatment of activity fuels associated with forest management is necessary to reduce potential 

fire intensity, particularly in areas with higher fire risk. Alternative C for the entire decision area 

and Alternative B and the Proposed RMP in southern portion would result in the highest levels of 

potential activity fuel risk.

Summary of Notable Changes from the Draft RMP/EIS

The BLM corrected a coding error for the acreage of early seral departure from reference conditions in 

Issue 1 and modified the extent of the Wildland Development Area in Issue 3 to be consistent with the 

extent used in Issue 4.

Background

Fire History and Fire Regimes

Fire has played a major role as a natural disturbance agent shaping vegetation patterns and structures 

across western Oregon landscapes for millennia (Agee 1991a and b, and Hessburg and Agee 2003).

Fire regimes quantify the historic spatial and temporal interaction of fire disturbance. Most fire regime 

classifications describe the presumed conditions under which vegetation communities have evolved and 

been maintained for a given ecosystem or landscape (Sommers et al. 2011). Different fire regime 

classifications exist, some of which focus on specific and specialized plant communities (e.g., grasslands, 

chaparral, and peat systems), while others include seasonality of burn and other nuanced factors 

(Sommers et al. 2011). This discussion will focus on the five fire regime groups recognized by 

LANDFIRE (Barrett et al. 2010), based on fire frequency, and expected severity (Table 3-28).
224 | P a g e

Table 3-28. Fire regime groups and descriptions used in current LANDFIRE Fire Regime Condition 

Class Guidebook Version 3

Fire Regime 

Group Frequency Severity Severity Description

I 0–35 years Low/Mixed

Generally low-severity fires replacing less than 25% of 

the dominant overstory vegetation; can include mixedseverity fires that replace up to 75% of the overstory

II 0–35 years Replacement High-severity fires replacing greater than 75% of the 

dominant overstory vegetation

III 35–200 years Mixed/Low Generally mixed-severity; can also include low severity 

fires

IV 35–200 years Replacement High-severity fires

V 200+ years Replacement/

Any Severity

Generally replacement severity; can include any 

severity type in this frequency range

Source: Barrett et al. 2010

In mixed-severity fire regimes, the influence of fuels, topography, and weather play out across the 

landscape to affect fire behavior, resulting in highly variable forest structure, vegetation patterning, 

successional stages (Perry et al. 2011, Donato et al. 2012), and rich biodiversity (Stephens et al. 2015, 

DellaSala and Hanson 2015). In low-severity fire regimes, fuels tend to be the dominant factor 

influencing fire behavior, while in high-severity fire regimes weather is the primary driver of fire 

behavior (Halofsky et al. 2011, Hessburg et al. 2005, Jain et al. 2012, Sommers et al. 2011), both of 

which result in less edge and larger patch sizes than mixed-severity regimes. At both local and regional 

scales, the influence of terrain, slope position, aspect, management actions, and ignition loading can result 

in a fine-scale mosaic of fire regimes (Agee 1991b, 1998, and 2005, Odion et al. 2004, Taylor and 

Skinner 2003), particularly in mixed-severity fire regimes.

Within the administrative boundaries of the Coos Bay, Eugene, and Salem Districts (coastal/north portion 

of the planning area), high proportions of the landscape, ranging from 44 to 53 percent, fall into the 

infrequent (> 200 years) and commonly replacement-severity fire regime group, with fire return intervals 

measured in hundreds of years (Table 3-29). Historically, fire was not an important frequent change agent 

acting to influence stand structure distribution of these forested ecosystems. Natural ignitions, weather, 

and fuel conditions to support fires in these areas rarely aligned, and fires that burned were large and of 

high severity (Morrison and Swanson 1990).
225 | P a g e

Table 3-29. Fire return intervals (FRI) by Historic Fire Regime Groups across the planning area

District/

Field Office

Historic Fire Regime Group and Description

I II III IV V

0-35 Year 

FRI, Low and 

Mixed 

Severity

(Percent)

0-35 Year 

FRI, 

Replacement 

Severity

(Percent)

35-200 Year 

FRI, Low and 

Mixed 

Severity

(Percent)

35-200 Year 

FRI, 

Replacement 

Severity

(Percent)

> 200 Year 

FRI, Any 

Severity

(Percent)

Coos Bay 39% - 16% - 44%

Eugene 17% - 34% - 50%

Klamath Falls 42% 6% 25% 23% 4%

Medford 91% - 7% 1% 1%

Roseburg 40% - 48% 1% 12%

Salem 22% - 25% - 53%

Source: LANDFIRE 2010 (LF_1.2.0)

The Klamath Falls Field Office and the Medford and Roseburg Districts (interior/south portion of the 

planning area) have high proportions, 73–98 percent, of lands within their administrative boundaries 

classified into low- and mixed-severity fire regime groups (I and III) with frequent (0–35 years), to 

moderately frequent (35–200 years) fire return intervals (Table 3-29). Historically, frequent to 

moderately frequent fire acted as a relatively important change agent affecting the landscape within the 

interior/south portion of the planning area.

Much of the southern portion of the planning area is within the Klamath ecological province, recognized 

for floristic diversity, geographic complexity, highly varied climatic gradients, and the prominent historic 

role of fire (Whittaker 1960, Atzet and Wheeler 1982). Prior to the 20th century, low- to mixed-severity 

fires played a substantial role in most dry forest ecosystems (Agee 1991a, Leiberg 1900, Colombaroli and 

Gavin 2010). Regional studies have found historic pre-settlement median fire return intervals ranging 

from 8–20 years in the drier and southern portions of the planning area (Sensenig et al. 2013, Taylor and 

Skinner 1998 and 2003), and longer median fire return intervals (35–120 years) in more mesic locations 

of the dry forest (Agee 1991b, Olson and Agee 2005, Van Norman 1998). These pre-20th century fires 

resulted both from lighting and human-caused ignitions (Sensenig 2002, Atzet and Wheeler 1982, 

Lalande 1995). Native Americans influenced vegetation patterns for over a thousand years by igniting 

fires to enhance values that were important to their culture, sustainability, and for vegetation management 

(Lalande 1991). Early settlers used fire to improve livestock grazing and farming, and to expose rock and 

soil for mining, and they set frequent and extensive fires (Atzet and Wheeler 1982, Leiberg 1900), heavily 

altering natural fire regimes.

Fire Exclusion in the Dry Forest

Historically, frequent low- to mixed-severity fire interacted with the complex landscape, vegetation, and 

climate to create and maintain patchy, mixed seral stages of shrubland, woodland, and mixed 

conifer/hardwood forests, in both open and closed conditions (Taylor and Skinner 1998, Hickman and 

Christy 2011, Duren et al. 2012, Dipaolo and Hosten 2015, Baker 2011). Frequent fire also cultivated 

large open grown trees, hindered the regeneration of fire intolerant species, promoted fire tolerant species 

and understory diversity, reduced forest biomass, and decreased the compounding impacts of insects and 

diseases (Halofsky et al. 2011, Perry et al. 2011, Jain et al. 2012). Historically, these heterogeneous 
226 | P a g e

landscape patterns and uneven-aged, uneven-structured stands of fire-dependent species contributed 

towards the fire resilience and rich biologic diversity of the southern Oregon landscape.

In the early 1900s, suppression of all wildfires became a goal of land management agencies and policy 

(Graham et al. 2004). This effectively took hold in western Oregon in the 1940s with the advent of 

mechanized equipment and the establishment of the smoke jumper base in Cave Junction (Atzet and 

Wheeler 1982, Atzet 1996). Effective fire exclusion and other land management practices (e.g., extensive 

even-aged forest management, mining, and grazing) has altered natural fire return intervals (Hessburg et 

al. 2015), and many areas have missed two to five fire cycles in the interior south (Agee 1991b, Taylor 

and Skinner 1998 and 2003, Olson and Agee 2005).

The absence of frequent low- and mixed-severity fire along with other land management practices has 

altered landscape seral distribution (Haugo et al. 2015), successional pathways (Donato et al. 2012), 

forest structural development (Halofsky et al. 2011), tree establishment (Sensenig et al. 2013, Comfort et 

al. in press), forest opening size and frequency (Skinner 1995, Taylor and Skinner 1998, Larson and 

Churchill 2012), and the horizontal and vertical fuel profile and loading (Agee 1998, Graham et al. 2004, 

Hessburg et al. 2005).

Currently, many of the dry forest stands are overly dense, are missing large fire-resistant trees, or are at 

risk from encroachment or fire-induced mortality (North et al. 2009, Jain et al. 2012, Comfort et al. in 

press). Dry forest species composition has shifted, resulting in significant reductions in the proportion and 

diversity of fire-adapted conifers, hardwoods, shrubs, and herbaceous species (Taylor and Skinner 1998 

and 2003, Franklin and Johnson 2010, Duren et al. 2012). The proportion of shade-tolerant species to 

fire-tolerant species has increased along with the proportion of small trees to large trees (Comfort et al. in 

press). The abundance of densely forested conditions has compromised individual tree vigor, resulting in 

extremely slow growth, which can delay or hinder the development of structurally-complex forest 

(Sensenig 2002, Sensenig et al. 2013). Open areas, such as forest gaps, shrublands, savannahs, grasslands, 

and hardwood woodlands, have been converting to closed areas via the recruitment of conifers (Taylor 

and Skinner 1998, Hosten et al. 2007, Comfort et al. in press). Surface, ladder, and canopy fuels have 

increased in loading and continuity, increasing the potential for larger scale crown and stand-replacing 

fires (Agee 1998, Sensenig 2002, Graham et al. 2004, Hessburg et al. 2005).

In general, the result of previous land management practices has resulted in homogenized vegetation 

patterns and fuel conditions at multiple scales (Hessburg et al. 2015) threatening overall forest health, and 

resistance and resilience to disturbance from fire, insects, and disease (Franklin and Johnson 2012, 

Sensenig et al. 2013). A recent regional evaluation of forest structure and restoration needs suggests that, 

40 percent of Oregon and Washington’s conifer forests are in need of disturbance through thinning or 

wildland fire (Haugo et al. 2015).

Current Fire Climate Environment and Future Trends

The area south of the Rogue-Umpqua divide generally has more severe and frequent thunderstorms with 

little precipitation, relative to the northern and coastal portions of the planning area (Agee 1991a, Atzet 

and Wheeler 1982, Sensenig 2002). While dry lightning is still infrequent in the coastal/north districts 

(Coos Bay, Eugene, and Salem), human ignitions are prevalent and account for greater than 90 percent of 

all ignitions within these districts (Figure 3-22). Human caused ignitions typically occur in relatively 

accessible locations and are sparse compared to multiple strikes in lightning events; coupled with 

overarching climatic patterns, human ignitions are typically manageable for suppression resources. 

Relative to frequent fire ecosystems, fire exclusion is an inconsequential factor influencing current fire 

frequency and severity, and structural stage distribution (Brown et al. 2004).
227 | P a g e

Figure 3-22. Average annual number and cause of ignitions (1984–2013) within the planning area

Source: Oregon Department of Forestry ignition data44

While fire regime groups represent historic conditions, the prevailing climatic patterns (hot, dry summers) 

influencing fire frequency and fire potential still exist in southern portions of the planning area, along with 

sufficient sources of both naturally and human-caused ignitions (Figure 3-22). Depending on fuel 

conditions, lightning from storms can start numerous wildfires in dry receptive fuels.

In the recent past, these multiple ignition events have on occasion overwhelmed suppression resources 

and have been a significant factor in the development of large wildfires within the southern portion of the 

planning area (notable years include 1987, 2002, 2013, and 2014). Currently, the vast majority (93 

percent) of acres burned are within wildfire perimeters greater than 1,000 acres, even though these 

wildfires account for less than 1 percent of all ignitions (Table 3-30). These large fires tend to burn during 

more extreme fire weather conditions, when fire behavior and growth potential exceed or challenge 

suppression resource availability and capabilities (Planning Level 4 and 5; NIFC 2014). This pattern of 

fire on the landscape is contrary to historic patterns of frequent fires burning throughout the dry season 

under various weather conditions across the landscape.

Table 3-30. Wildfire ignitions within the planning area by acre size class categories, 1984–2013

Fire Size Class

(Acres)

All Ignitions

(Percent)

Total Acres Burned

(Percent)

< 10 96% 1%

10-99 3% 2%

100-999 1% 4%

1,000+ < 1% 93%

Source: Oregon Department of Forestry ignition data

 

44 ODF ignition data likely underrepresents wildfire occurrence on BLM-administered lands within the Klamath Falls 

Field Office, as the Gerber Block located in the southeast portion of the field office is not under ODF protection.

66 73

40

192

55

185 6

6

48

72

23

8

0

50

100

150

200

250

300

Coos Bay Eugene Klamath Falls Medford Roseburg Salem

Number of Ignitions

District/Field Office

Lightning Human
228 | P a g e

In recent decades, the frequency of large wildfires and the annual acres burned have increased across the 

western states (Westerling et al. 2006) and in Oregon (USDI BLM 2013). Modeled projections indicate 

this trend will continue (Mote et al. 2014). Based on an analysis of fire start dates for wildfires greater 

than 1,000 acres, Westerling and others (2006) found that the fire season is already longer than it was in 

the 1980s by at least a month. With observed increase in mean summer temperatures and earlier 

snowmelt, some climate changes have already begun to manifest. These changes in climate strongly 

correlate with increasing wildfire size, large wildfire frequency, and longer wildfire durations (Westerling 

et al. 2006, Littell et al. 2010, Miller et al. 2012, see the Climate Change section in this chapter). These 

observed trends and forecasts suggest that wildfire will continue to be a major change agent affecting 

ecosystem structure and spatial distribution, further exacerbating the problems of fire exclusion and 

previous land management activities. In recent decades, there has been growing concern over cost and 

lasting effects of large wildfires (Ingalsbee and Raja 2015). In part, this prompted Congress to pass the 

2009 FLAME Act (43 U.S.C. 1701). This Act directed the Secretary of Agriculture and the Secretary of 

the Interior to submit a joint strategy to address major wildland fire issues in the United States through the 

enhancement and development of fire-adapted communities, effective and efficient wildfire response, and 

resilient landscapes.

Recognition of both the spatial and temporal process and vegetative structure of fire regimes is necessary 

to promote resilience in frequent fire-adapted forests (Agee 2002, Jain et al. 2012). In fire-adapted 

ecosystems, fire on the landscape can clearly provide benefit to fire-dependent species and promote rich 

biologically diverse successional stages and vegetation patterning (Agee 1993, Agee 2005, Odion et al.

2010, Swanson et al. 2011, DellaSala and Hanson 2015). In the absence of utilizing natural fire as a 

disturbance agent, management activities can serve as a partial surrogate to promote and maintain desired 

spatial and temporal structural and composition. Despite a presumed low probability that wildfires will 

intersect treatments (Rhodes and Baker 2008), recently, there has been a growing body of evidence 

throughout the western states (Martinson and Omi 2013, Ewell et al. 2015), Pacific northwest (Prichard et 

al. 2010, Shive et al. 2013, and Prichard et al. 2014), and in southwest Oregon (local observations) that 

they do. This evidence demonstrates that vegetation management, incorporating mechanical and 

prescribed fire treatments, has successfully moderated fire behavior and fire effects, even under extreme 

weather events (Prichard and Kennedy 2014), and has contributed toward more resilient future forest 

structure (Stevens-Rumann et al. 2013). During extreme fire weather events and plume-dominated fire 

behavior, even fuel profiles and vegetation structure representative of historic fire regimes may have a 

reduced likelihood of altering fire behavior (Lydersen et al. 2014), and treated areas may become less 

effective at altering fire behavior (Ewell et al. 2015), resulting in large areas of high severity. However, 

Kennedy and Johnson (2014) and Ewell et al. (2015) found that these types of treatments also improved 

fire management opportunities. These moderated vegetation structures, and thus moderated fire behavior 

under less than extreme fire weather conditions, may provide opportunities to utilize wildfire (North et al.

2015) to meet land use and resource objectives.

Issue 1

How would the alternatives affect fire resiliency in the fire-adapted dry forests at the landscape scale?

Summary of Analytical Methods

To measure dry forest fire resilience at the landscape scale, the BLM45 quantified the departure of current 

vegetation structure and landscape composition patterns from a set of reference conditions that represent 

the historic range of variability (Barrett et al. 2010, Keane et al. 2009). In this approach, less departure 

 

45 Chris Zanger, Forest Analyst for The Nature Conservancy, conducted this analysis of landscape-scale fire 

resiliency under an agreement with the BLM.
229 | P a g e

from reference conditions represents greater fire resiliency. Historic conditions within the dry forests were 

more resilient to fire disturbance than current conditions, in large part, because frequent fire was present 

on the landscape (Hessburg and Agee 2003, Brown et al. 2004, North et al. 2009). 

In this analysis, the BLM quantified how the seral stage distribution would vary in 50 years for each 

alternative and the Proposed RMP, relative to the reference condition. This analytic process built upon the 

conceptual framework of the LANDFIRE Fire Regime Condition Class concept (Schmidt et al. 2002, 

Barrett et al. 2010). The LANDFIRE Fire Regime Condition Class conceptual framework assumes that, 

given natural disturbance processes (e.g., historic fire regime), a biophysical setting will have a 

sustainable range of variation in the proportion of each successional stage for a given landscape (Barrett 

et al. 2010). This reference condition—the percentage of a biophysical setting in each seral stage—does 

not represent a specific historical date, but instead approximates an equilibrium condition, or ecological 

reference condition, based upon the natural biological and physical processes. While a variety of 

perspectives exist regarding historic vegetation reference conditions and natural range of variability 

(Strittholt et al. 2006, Colombaroli and Gavin 2010, Baker 2011, and Dipaolo and Hosten 2015), this 

analysis utilizes LANDFIRE biophysical settings which provide comprehensive reference conditions for 

all seral-states and have been developed based on literature review, local data, and expert estimates. 

Four primary data inputs provided the foundation for this assessment of successional stage departure: 

1. A classification and map of forested biophysical settings to identify dry forest and moist forest 

(ILAP Potential Vegetation Types; Map 3-2) 

2. A reference condition for the natural range of variability for each biophysical setting 

(LANDFIRE BPS 2008, Rollins 2009, Ryan and Opperman 2013) 

3. A delineation of landscape units for each biophysical setting (i.e., the dry forest within the 

administrative boundaries of the Klamath Falls Field Office, and Medford and Roseburg 

Districts) (Appendix H) 

4. A spatial delineation of forest structure and composition for current and future conditions, 

under all alternatives and the Proposed RMP (Appendix H). These classifications are based on 

structure and do not infer an ecologically intact seral-state. 
230 | Page

INSERT MAP HERE 

Map 3-2. Moist and dry forest types 
231 | P a g e

The BLM used the Integrated Landscape Assessment Project (ILAP) Potential Vegetation Type spatial 

data, which approximate an aggregation of plant associations and Plant Association Groups, to classify 

forests within the planning area into moist and dry forest categories, based on Franklin and Johnson 

(2012). U.S. Forest Service Region 6 Ecologists reviewed the initial categorizations of moist and dry 

Plant Association Groups, and BLM district staff refined the data, based on local knowledge of the 

ground. Using the refined ILAP Potential Vegetation Type 30-meter spatial data, the BLM categorized as 

‘dry’ any Forest Operations Inventory polygons that had more that 50 percent of its area within a dry 

Potential Vegetation Type.

The BLM recognizes that vegetation types result from complicated relationships among, climate, 

topography, soils, and disturbance regimes. In addition, while vegetation types typically occur along 

moisture gradients, they do fall into broad relative moisture categories of moist and dry, particularly at the 

scale of the planning area. This discrete classification into moist or dry recognizes general differences in 

disturbance regimes, succession, and species composition, and as such, relevant management objectives 

and direction. The BLM acknowledges that several other vegetation classification schemes exist (e.g., 

LANDFIRE 2010, Ecological Systems Classification (Comer et al. 2003), National Gap Analysis 

Program (Jennings 2000), and The National Vegetation Classification System (Anderson et al. 1998, 

FGDC 2008), however, these classification schemes do not group forests into broad moisture categories 

(e.g., moist and dry) relevant to management decisions, objectives, and direction. For the purposes of this 

analysis, the BLM uses the classification scheme described above, which is further detailed in Appendix 

C.

This analysis presents effects on landscape-scale fire resiliency that includes land management on BLMadministered lands and non-BLM-administered lands. The analysis area is the dry forest area within the 

western portion of the Klamath Falls Field Office, and the Medford and Roseburg Districts. Each of these 

three administrative areas constituted a landscape for the purpose of this analysis. The BLM-administered 

lands comprise 28 percent of the analysis area. The BLM also refers to this area as the interior/south 

portion of the decision area. These three administrative units encompass the majority of the dry forest 

landscape within the planning area (Map 3-2). Although the Coos Bay District has a large portion (39 

percent) of lands classified as fire regime I within the district boundary (Table 3-29), the overwhelming 

majority of the BLM-administered lands in the Coos Bay District are classified as moist forest (Figure 3-

23). Therefore, lands within the Coos Bay District are not included in this analysis. The Coos Bay, 

Eugene, and Salem Districts comprise the moist or coastal/north portion of the decision area.
232 | P a g e

Figure 3-23. Forest type (moist and dry) distribution on BLM-administered lands

In this analysis, the BLM created a cross-walk between the structural stages used in the Woodstock model 

(Appendix C) and the five seral stages used in the LANDFIRE Fire Regime Condition Class conceptual 

framework: early seral, mid-seral closed, mid-seral open, late-seral closed, and late-seral open (Appendix 

H). Although necessary to produce data suitable for this analytical methodology, the crosswalk from 

structural stages to seral stages may have resulted in the misclassification of some stands.

The vegetation growth Woodstock model is not able to depict precisely or accurately the within-stand 

heterogeneity that would result from the management approach in the Uneven-aged Timber Area. Under 

the action alternatives, the Uneven Aged Timber Area makes up most or all of the Harvest Land Base 

within this analysis area. Implementation of the management direction in the Uneven-aged Timber Area 

would likely result in a mix of open and closed stand conditions. This analysis likely represents this finescale heterogeneity as closed stand conditions. Therefore, this analysis likely overestimated the extent of 

mid-seral closed (and, to a lesser extent, late-seral closed) stand conditions that would result from 

management in the Uneven-aged Timber Area, and potentially underestimated the extent of mid-seral 

open (and late-seral open stand conditions). However, given the small percentage of the overall dry forest 

landscape in Uneven-aged Timber Area in any of the alternatives or the Proposed RMP, these errors 

would not alter the overall trend and magnitude of changes over time at the scale of this analysis.

The BLM assumed that changes in seral stage distribution in the moist forest portions within the Klamath 

Falls Field Office, and the Medford and Roseburg Districts would not be as relevant to landscape-scale 

fire resilience, because of the difference in fire severity and frequency associated with fire regimes in 

those vegetation types.

For the purpose of this analysis, the BLM assumed that the future distribution of forest structure 

conditions on non-BLM-administered lands would continue to reflect the current distribution of forest 

structure conditions. The assumption that the future distribution of forest structure conditions on nonBLM-administered lands would continue to reflect the current distribution of forest structure conditions is 

323,548 301,637 

8,831 

45,611 

222,784 

395,523 

2,260 12,010 

206,151 

764,783 

203,116 

7,415 

0

150,000

300,000

450,000

600,000

750,000

900,000

Coos Bay Eugene Klamath Falls Medford Roseburg Salem

Forest Type Distribution (Acres)

District/FieldOffice

Moist Dry
233 | P a g e

consistent with the assumption used in the analysis of forest structure and spatial pattern in the 2008 

FEIS, which describes the limitations on analyzing future changes on non-BLM-administered lands and is 

incorporated here by reference (USDI BLM 2008, pp. 532–536).

The BLM acknowledges that the distribution and spatial arrangement of seral stages would change in the 

future, but lacks information to make specific projections of how successional stages relevant to this 

analysis of fire resiliency would change over time on non-BLM-administered lands. Seral stage is a key 

component of this this analysis, and the BLM lacks information on stand attributes on non-BLMadministered lands that are directly relevant to this analysis. Holding seral stages constant on non-BLMadministered lands provides a reasonable benchmark to determine relative differences in how the 

management of BLM-administered lands would contribute towards the larger landscape resilience within 

the analysis period.

This analysis evaluated the departure, relative to a reference condition, of each vegetation type, for each 

seral stage, in each of the three administrative units. Presenting all of these results together would produce 

an analysis of bewildering complexity. For example, summing all vegetation types within an 

administrative unit would show simultaneous overabundance and deficits in each seral stage, because 

some vegetation types would be overabundant in that seral stage, while other vegetation types would be 

deficit. Therefore, this analysis focused on the two most common vegetation types in the analysis area: 

the Douglas-fir/dry and Douglas-fir/moist vegetation types, which account for most (74 percent) of the 

analysis area (Table 3-31).

Table 3-31. Amount of dry forested vegetation types in the interior/south portion of the planning area 

included in departure analysis

Vegetation Types All Interior/South Dry Forest

(Percent) (Acres)

Douglas-fir - Dry 41% 1,336,438

Douglas-fir - Moist 33% 1,090,723

Tan oak - Douglas-fir - Ultramafic 8% 277,579

Douglas-fir - White oak 8% 250,616

Shasta red fir - Moist 5% 157,989

Ponderosa pine - Lodgepole pine 2% 66,714

Jeffery Pine 2% 59,152

Western hemlock - Moist 1% 20,192

Mixed Conifer - Warm/Dry < 1% 15,833

Ponderosa pine - Xeric < 1% 8,776

Lodgepole pine < 1% 443

Oregon white oak - Ponderosa pine < 1% 43

Total Dry Forest Acres in Analysis Area 100% 3,284,497

The results of this analysis do not include vegetation changes resulting from non-commercial hazardous 

fuels work, which would likely contribute toward decreasing acres in the mid-closed seral stage similarly 

among all alternatives and the Proposed RMP.

Appendix H provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales in this analysis.
234 | P a g e

Affected Environment and Environmental Consequences

The Douglas-fir/dry vegetation type shows similar general patterns both currently and in the future for all 

three administrative units. Therefore, this discussion sums the results for all three administrative units.

Currently, the Douglas-fir/dry vegetation type has a slight overabundance of early seral46 and a substantial 

overabundance of mid-seral closed forest (Figure 3-24). As stated in the methods, the BLM used forest 

structure to develop seral stage classifications, and these classifications may not represent an ecologically 

intact state. The Douglas-fir/dry vegetation type has a slight deficit of mid-seral open forest47 and lateseral closed forest, and a substantial deficit of late-seral open forest.

 

46 Incorporation of the 2013 and 2014 wildfires into the starting condition (see the Analytical Methodologies and 

Assumptions section of this chapter) increased the over-abundant early seral acreage by approximately 3,000 acres

for the current condition. Directly attributed to the wildfires, these acres are assumed to be ecologically functioning 

complex early seral habitat, which is markedly different from heavily managed early seral forest conditions 

(DellaSala and Hanson 2015). Figure 3-24 does not depict this slight overabundance.

47 In contrast to the Medford and Roseburg Districts, the Klamath Falls Field Office has a slight overabundance of 

mid-seral open forest (approximately 3,000 acres), both currently and in the future under each alternative and the 

Proposed RMP. Figure 3-24 does not depict this slight overabundance.
235 | P a g e

Figure 3-24. Departure from reference conditions in the Douglas-fir/dry vegetation type by seral stage 

Note: This includes the current conditions, the alternatives, the Proposed RMP, and the No Timber Harvest reference analysis in 2063.48

48 In contrast to the Klamath Falls Field Office and Roseburg District, Alternatives B, C, and D, the Proposed RMP, and the No Timber Harvest reference 

analysis would result in a deficit of early seral forest (3,100–6,400 acres) on the Medford District in 50 years. Figure 3-24 does not depict this deficit. 

-600,000

-400,000

-200,000

0

200,000

400,000

600,000

800,000

Departure from Reference Condition (Acres)

Seral Stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Ref. Cond.

Early Seral Mid-seral

Closed

Mid-seral

Open

Late-seral

Closed

Late-seral

Open

 
236 | P a g e

In 50 years, conditions in the Douglas-fir/dry vegetation type under the No Timber Harvest reference 

analysis and all alternatives and the Proposed RMP would generally result in continued departure from 

reference conditions (Figure 3-24). 

The alternatives and the Proposed RMP would result in only modest shifts in the seral stage distribution 

on the BLM-administered lands. There would be continued overabundance of mid-seral closed forest 

conditions. The action alternatives, the Proposed RMP, and the No Timber Harvest reference analysis 

would result in slight improvements in the early seral departure for the Klamath Falls Field Office and 

Roseburg District, and late-seral closed departure for the entire interior/south. Under any scenario, there 

would be no change to the late-seral open forest departure. Because the BLM-administered lands 

constitute only a small portion of the analysis area, these modest shifts would not result in any substantial 

change in the overall landscape condition in the Douglas-fir/dry vegetation type. Under all alternatives, 

the Proposed RMP, and the No Timber Harvest reference analysis, the landscape condition in the 

Douglas-fir/dry vegetation type would continue to be shaped by an substantial overabundance of midseral closed forest and a large deficit of late-seral open forest. 

The Douglas-fir/moist vegetation type has differing patterns both currently and in the future for the three 

administrative units. Therefore, this discussion presents the results for the three administrative units 

separately. 

Currently within the Klamath Falls Field Office, the amount of Douglas-fir/moist early seral vegetation is 

within the natural range of variability of the reference condition, hence, there are no bars associated with 

this seral-state (Figure 3-25). There is a substantial overabundance of mid-seral closed forest and slight 

overabundance of mid-seral open forest (Figure 3-25). The Douglas-fir/moist vegetation type is also 

slightly deficit of late-seral closed forest and substantially deficit of late-seral open forest. 
237 | P a g e

Figure 3-25. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage for the Klamath Falls Field Office 

Note: This includes the current conditions, the alternatives and the Proposed RMP, and the No Timber Harvest reference analysis in 2063. 

-40,000

-30,000

-20,000

-10,000

0

10,000

20,000

30,000

40,000

Departure from Reference Condition (Acres)

Seral Stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Ref. Cond.

Early Seral Mid-seral

Closed

Mid-seral

Open

Late-seral

Open

Late-seral

Closed
238 | P a g e

In 50 years, all alternatives, the Proposed RMP, and the No Timber Harvest reference analysis would 

result in only modest shifts of seral stage distribution on BLM-administered lands in the Klamath Falls 

Field Office. The No Action alternative and Alternatives C and D would slightly reduce the 

overabundance of mid-seral closed forest, from current conditions. The No Action alternative and 

Alternatives C and D would result in a sight overabundance of early seral acreage. For all other seral 

stages, conditions in the Douglas-fir/moist vegetation type under any alternative, the Proposed RMP, and 

the No Timber Harvest reference analysis would result in essentially no change to current departure from 

reference conditions. 

Currently within the Medford District, the Douglas-fir/moist vegetation type is slightly deficit in early 

seral and mid-seral open forest (Figure 3-26). There is a substantial overabundance of mid-seral closed 

forest and slight overabundance of late-seral closed forest. The Douglas-fir/moist vegetation type has a 

sizeable deficit of late-seral open forest. 
239 | P a g e

Figure 3-26. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage for the Medford District 

Note: This includes the current conditions, the alternatives and the Proposed RMP, and the No Timber Harvest reference analysis in 2063. 

-400,000

-300,000

-200,000

-100,000

0

100,000

200,000

300,000

400,000

Departure from Reference Condition (Acres)

Seral stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Ref. Cond.

Early Seral

Mid-seral

Closed

Mid-seral

Open

Late-seral

Open

Late-seral

Closed
240 | P a g e

In 50 years, conditions in the Douglas-fir/moist vegetation type in the Medford District under any 

alternative, and the Proposed RMP, and the No Timber Harvest reference analysis would generally result 

in continued departure from reference conditions (Figure 3-26) and result in only modest shifts, if any, in 

seral stage distribution. Again, the Douglas-fir/moist vegetation type would continue to be shaped by an 

overabundance of mid-seral closed forest and a deficit of late-seral open forest. 

Currently within the Roseburg District, the Douglas-fir/moist vegetation type has a slight overabundance 

of early seral and late-seral closed forest and slight deficit in mid-seral open forest (Figure 3-27). Again, 

there is a substantial overabundance of mid-seral closed forest and a sizeable deficit in late-seral open 

forest. 
241 | P a g e

Figure 3-27. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage for the Roseburg District 

Note: This includes the current conditions, the alternatives and the Proposed RMP, and the No Timber Harvest reference analysis in 2063. 

-200,000

-150,000

-100,000

-50,000

0

50,000

100,000

150,000

200,000

Departure from Reference Condition (Acres)

Seral stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Ref. Cond.

Early Seral

Mid-seral

Closed

Mid-seral

Open

Late-seral

Open

Late-seral

Closed
242 | P a g e

Again, in 50 years, conditions in the Douglas-fir/moist vegetation type in the Roseburg District under any 

alternative, the Proposed RMP, and the No Timber Harvest reference analysis would generally result in 

continued departure from reference conditions. There would be a shift in departure of early seral acres 

from a slight overabundance in the current condition to a slight deficit under all alternatives, the Proposed 

RMP, and the No Timber Harvest reference analysis. There would be little change from current departure 

in both the mid-seral closed and late-seral open forest under any alternative and the Proposed RMP. 

Similar to the Douglas-fir/dry vegetation type, in 50 years, conditions in the Douglas-fir/moist vegetation 

type under any alternative, the Proposed RMP, and the No Timber Harvest reference analysis would 

generally result in continued departure from reference conditions (Figure 3-25, Figure 3-26, and Figure 

3-27). The alternatives and the Proposed RMP would result in only modest shifts in the seral stage 

distribution on the BLM-administered lands, and thus the overall landscape condition in the Douglasfir/moist vegetation type. Under all alternatives, the Proposed RMP, and the No Timber Harvest reference 

analysis, the landscape condition in the Douglas-fir/moist vegetation type would continue to be shaped by 

an overabundance of mid-seral closed forest and a deficit of late-seral open forest. 

While objectives associated with the Harvest Land Base and Late Successional Reserve land use 

allocations in the interior/south coincide with the development of complex and heterogeneous seral stage 

landscape distribution, aligned with low- and mixed-severity ecosystems (Appendix B), in both the 

Douglas-fir/dry and Douglas-fir/moist vegetation types, the differing BLM management under the 

alternatives and the Proposed RMP would result in little change in the departure from reference 

conditions over time, for several reasons. First, the BLM-administered lands represent a small portion of 

the analysis area. Second, under all alternatives and the Proposed RMP, the BLM would allocate only a 

small portion of the BLM-administered lands to the Harvest Land Base, in which the BLM would 

implement the most active management capable of shifting seral stages. Management within reserve 

allocations would be unlikely to shift seral stages substantially, given the reserve land use allocation 

objectives. Finally, the 50-year analysis period may be too short in length to show substantial shifts in 

seral stages (e.g., for development of mid-seral closed forests into late-seral open forests). 

In summary, the landscape would remain departed from reference conditions similarly under any 

alternative or the Proposed RMP, with a continued overabundance of mid-seral closed forest and a deficit 

of late-seral open forest. Changes in seral stage distribution on BLM-administered lands would account 

for only small shifts in the landscape departure under any alternative or the Proposed RMP. 

Issue 2 

How would the alternatives affect fire resistance in the fire-adapted dry forests at the stand level? 

Summary of Analytical Methods 

Resistance refers to the capacity for an ecosystem to resist the impacts of disturbances without 

undergoing significant change. For example, wildfire can burn through a resistant forest without 

substantially altering its structure, composition, or function (Franklin et al. 2013). 

In this analysis, the BLM assigned forest structural stages (Appendix C) to a relative ranking of 

resistance to stand-replacement fire (Table 3-32). These categories range from Low/Moderate fire 

resistance (i.e., greater tendency of a stand-replacement fire) to High fire resistance (i.e., less probability 

of a stand-replacement fire). Mixed fire resistance indicates the potential to exhibit the full range 

of resistance categories (High to Low) (Appendix H). 
243 | P a g e

Table 3-32. Resistance to stand-replacement fire by structural stage

Structural Stages Subdivisions Resistance to Stand 

Replacement Fire

Early Successional with Structural Legacies Moderate

without Structural Legacies Moderate

Stand Establishment with Structural Legacies Moderate

without Structural Legacies Low

Young Stands – High Density with Structural Legacies Low

without Structural Legacies Low

Young Stands – Low Density with Structural Legacies Moderate

without Structural Legacies Moderate

Mature

Single-layered Canopy High

Multi-layered Canopy Mixed

Structurally-complex

Developed Structurally-complex Mixed

Existing Old Forest Mixed

Existing Very Old Forest Mixed

While the structural stage classification does not specifically account for surface fuel loading, the BLM 

assumed that vegetation community structure is an important factor affecting potential fire behavior, postfire effects, and fire resistance, particularly to crown fire (Jain and Graham 2007), which has the largest 

immediate and long-term ecological effects (Graham et al. 2004). In the frequent fire-adapted dry forest, 

fire resistant stand structure reduces the likelihood of atypical large-scale crown fires (Agee and Skinner 

2005, Jain et al. 2012, Franklin et al. 2013). In general, stands with higher fire resistance have reduced 

surface fuel loading, lower tree density, large diameter trees of fire-resistant species, increased height to 

live crown (Brown et al. 2004, Peterson et al. 2005, USDI BLM 2008), and discontinuous horizontal and 

vertical fuels.

This analysis does not account for the complex interaction among fuels (including vertical and horizontal 

composition and moisture), topography (e.g., slope, topographic position, elevation, and aspect), and 

weather (e.g., wind, temperature, relative humidity, fuel moisture, and drought) that influence fire 

behavior, resultant burn severity, and fire effects (Andrews and Rothermel 1982, Scott and Reindhardt 

2001) and the specific conditions related to crown fire initiation and spread (Van Wagner 1977). As fire 

weather indices increase throughout the summer, resistance to stand-replacement fire decreases. Weather 

events and climatic conditions, including drought, have the potential to result in unexpected and extreme 

fire behavior, and subject every structure class to high-severity fire. Nevertheless, at this scale of analysis 

with the data available, the assignment of structural stages to a relative ranking of stand-level resistance 

provides a robust and consistent basis for comparing the effects of the alternatives and the Proposed 

RMP.

The analysis area is the dry forest area within the interior/south: the Klamath Falls Field Office, and the 

Medford and Roseburg Districts, as described in Issue 1. The BLM quantified the acreage of BLMadministered lands in the dry forest in the Klamath Falls Field Office, and the Medford and Roseburg 

Districts in each fire resistance categories for each alternative and the Proposed RMP over 50 years.

The results of this analysis do not include effects from non-commercial hazardous fuels work, which 

would contribute toward improving fire resistance similarly among all alternatives and the Proposed 

RMP.
244 | P a g e

Appendix H provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales.

Affected Environment and Environmental Consequences

Currently, about half of the BLM-administered lands in dry forest have relatively Moderate or Low fire 

resistance (i.e., greater potential of a stand-replacement fire). Approximately 5 percent of the BLMadministered lands in dry forest currently have High fire resistance (i.e., less potential of a standreplacement fire) (Figure 3-28). The remaining acres are in a Mixed fire resistance.

Figure 3-28. Stand-level fire resistance categories in the dry forest in the interior/south for the current 

condition and in 50 years

In 50 years, all alternatives and the Proposed RMP would result in an increase in stand-level fire 

resistance across the dry forest and would reduce the acres of Moderate or Low fire resistance and 

increase the acres of High fire resistance, relative to current conditions across the dry forest. The No 

Action alternative would result in the least reduction in the acreage of Moderate or Low fire resistance. 

Although results among the action alternatives and the Proposed RMP are very similar, Alternatives B 

and D would result in the largest reduction in the acreage of Low or Moderate fire resistance, followed by 

the Proposed RMP and then Alternatives A and C.

The effects of the alternatives and the Proposed RMP on stand-level fire resistance in both the Medford 

and Roseburg Districts in 50 years would approximate the effects across the dry forest (Figure 3-29 and 

Figure 3-30). Differences would be more evident for the Klamath Falls Field Office (Figure 3-31), where 

Alternatives A and B, and the Proposed RMP would result in the most pronounced reduction of Low and 

Moderate fire resistance conditions and the largest increase in Mixed and High fire resistance acres. The 

No Action alternative would result in a slight increase in the acreage of both High and Moderate fire 

resistance from current conditions, and, consequently only a slight reduction in the acreage of Low fire 

319,156 

199,269 215,360 200,152 228,494 189,395 203,394 

134,202 

169,833 

57,872 47,151 

64,440 

63,338 65,858 

418,272 

390,476 

489,668 513,790 479,623 501,371 497,183 

56,607 

168,668 165,346 167,154 155,689 174,142 161,811 

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Resistance (Percent of Acres)

Low Moderate Mixed High
245 | P a g e

resistance. Alternative D would result in only a slight increase in High and Mixed fire resistance 

conditions, and little reduction in Low and Moderate fire resistance. Alternative C would result in no 

increase in the acreage of High fire resistance and less increase in the acreage of Mixed fire resistance 

than the other alternatives and the Proposed RMP.
246 | P a g e

Figure 3-29. Stand-level fire resistance categories in the dry forest in the Medford District for the current 

condition and in 50 years

Figure 3-30. Stand-level fire resistance categories in the dry forest in the Roseburg District for the current 

condition and in 50 years

Figure 3-31. Stand-level fire resistance categories in the dry forest in the Klamath Falls Field Office for 

the current condition and in 50 years

246,923

158,847 168,547 159,190 175,425 151,922 162,126

99,294

133,376 49,043 42,204 51,147 48,913 53,289

328,299

306,803 379,131 395,642 375,709 391,053 385,785

40,996 116,485 118,790 118,476 113,231 123,624 114,311

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Resistance

(Percent of Acres)

Low Moderate Mixed High

56,682

32,486 37,085 30,477 38,933 29,304 30,131

25,904

22,708 7,393

3,419

7,350

6,648 10,992

80,700

74,560 91,105 99,073 89,933 94,786 92,712

7,303 40,835 35,006 37,620 34,372 39,850 36,754

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Resistance

(Percent of Acres)

Low Moderate Mixed High

15,551

7,935 9,728 10,485 14,136

8,168 11,136

9,005

13,750 1,436 1,528

5,942

7,778

1,577

9,283

9,113

19,432 19,075

13,980

15,532 18,686

8,307 11,348 11,550 11,058 8,086 10,668 10,747

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Resistance

(Percent of Acres)

Low Moderate Mixed High
247 | P a g e

The alternatives and the Proposed RMP differ in the extent and location of both the Harvest Land Base 

and the Late-Successional Reserve (Figure 3-32). The associated changes in vegetation, due to different 

extents and management direction within the Harvest Land Base among the alternatives and the Proposed 

RMP, would influence the overall patterns of stand-level fire resistance, rather than changes occurring 

within the reserves.
248 | P a g e

Figure 3-32. Stand-level fire resistance categories in the Late-Successional Reserve in the dry forest in the interior/south for the current condition 

and in 50 years

38,232 

24,741 

151,759 

77,086 

92,464 

54,874 

101,014 

62,419 54,734 

28,015 

78,442 

47,861 

15,910 

5,933 

44,072 

20,985 

38,034 

11,399 

38,093 

14,168 

11,169 

8,543 

32,458 

10,880 

71,205 

75,653 

299,650 

341,843 

225,793 

250,165 

261,374 

284,199 

218,787 

232,455 

215,648 

238,898 

6,991 

26,010 

33,411 

88,987 

21,054 

60,907 

22,843 

62,548 

16,425 

32,112 

19,583 

48,493 

0%

20%

40%

60%

80%

100%

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

No Action (132,338) Alt. A (528,901) Alt. B (377,345) Alt. C (423,333) Alt. D (301,124) PRMP (346,131)

Late-Successional Reserve by Alternative (Acres)

Fire Resistance (Percent of Acres)

Low Moderate Mixed High
249 | P a g e

Even though the alternatives and the Proposed RMP differ substantially in the extent and location of the 

Late-Successional Reserve in the dry forest, current fire resistance within the Late-Successional Reserve 

is similar (Figure 3-32). Additionally, all alternatives and the Proposed RMP would similarly reduce the 

acreage in the low or moderate fire resistance categories within the Late-Successional Reserve after 50 

years, thus not influencing the overall patterns of change within the dry forest. However, within the 

Harvest Land Base, there would be greater variation in the patterns of change in stand-level fire resistance 

over time, and this would drive the differences among the alternatives and the Proposed RMP across the 

dry forest overall (Figure 3-33). In large part, the lack of difference among alternatives and the Proposed 

RMP for the dry forest in the interior/south is due to the abundance of acres in the Mixed fire resistance 

category (Figure 3-28), especially in the Late-Successional Reserve (Figure 3-32). The Mixed fire 

resistance category has the potential to exhibit the full range of resistance categories (High to Low), 

discussed in further detail in Appendix H.

The BLM assumed that the restoration approach taken in the Late-Successional Reserve in the dry forest 

would include stand density reductions, cultivation of large trees with old-growth characteristics, 

introductions of heterogeneity into increasingly uniform stands, and treatments to reduce fire risk adjacent 

to high-value habitat. However, treatments in the Late-Successional Reserve – Dry land use allocation 

may not be a priority; guarantee of treatment occurrence is tenuous. The Proposed RMP includes 

management direction that directs the application of selection harvest or commercial thinning treatments 

on 21,500 eligible acres within the Late-Successional Reserve – Dry land use allocation per decade 

(Appendix B), and would afford reasonable certainty of actions occurring on approximately 12 percent of 

this land use allocation each decade.

Within the Harvest Land Base, the current stand-level fire resistance conditions differ among the 

alternatives and the Proposed RMP due to the differing extents and locations of the Harvest Land Base 

(Figure 3-33). The No Action alternative has the largest Harvest Land Base (i.e., Matrix and Adaptive 

Management Areas) and the smallest proportion (52 percent) currently in Low or Moderate fire 

resistance. While the size of the Harvest Land Base is relatively similar among Alternatives B, C, and D, 

and the Proposed RMP, the Proposed RMP has the smallest Harvest Land Base with Alternative D having 

the largest Harvest Land Base within the dry forest. Among these alternatives and the Proposed RMP, 

approximately 60 percent of the Harvest Land Base acreage is currently in Low or Moderate fire 

resistance. Alternative A has the smallest Harvest Land Base and the largest proportion (75 percent) in 

Low or Moderate fire resistance.
250 | P a g e

Figure 3-33. Stand-level fire resistance categories in the Harvest Land Base in the dry forest in the interior/south for the current condition and in 

50 years

179,908 

109,136 

63,964 62,776 

110,068 

67,645 

120,455 

101,879 

127,584 

73,840 

97,178 

62,478 

70,841 

153,387 

29,899 

22,632 

42,276 

17,080 

48,686 

35,095 

57,295 

35,184 

42,666 

33,886 

200,390 

140,063 

20,983 

21,975 

94,507 

130,790 

84,386 

89,988 

81,120 

110,604 

80,164 

97,581 

33,414 

81,977 

10,968 

18,430 

22,469 

53,814 

23,660 

50,226 

23,363 

69,735 

20,450 

46,513 

0%

20%

40%

60%

80%

100%

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

No Action (484,563) Alt. A (125,814) Alt. B (269,329) Alt. C (277,188) Alt. D (289,363) PRMP (240,458)

Harvest Land Base by Alternative (Acres)

Fire Resistance (Percent of Acres)

Low Moderate Mixed High
251 | P a g e

In 50 years, all of the action alternatives and the Proposed RMP would reduce the proportion of the 

Harvest Land Base in Low or Moderate fire resistance (Figure 3-33). Alternative A would reduce this 

proportion by 7 percent, Alternative C would result in a decrease of 12 percent, and Alternatives B and D 

would result in the largest decrease (25 and 26 percent, respectively) in the proportion of the Harvest 

Land Base in Low or Moderate fire resistance. The Proposed RMP would decrease the acres of Low and 

Moderate fire resistance by 18 percent. In contrast, the No Action alternative would slightly increase the 

proportion of the Harvest Land Base in Moderate fire resistance, while decreasing the proportion of Low

fire resistance in 50 years. 

Alternative B, followed by Alternative D and the Proposed RMP, would result in the largest proportions 

of High and Mixed fire resistance within the dry forest Harvest Land Base in 50 years. The results for 

each district approximate the same trends as the entire dry forest Harvest Land Base (Appendix H).

The differences among alternatives and the Proposed RMP, in stand-level fire resistance within the 

Harvest Land Base, largely would result from the type of management and associated management 

direction. 

The Harvest Land Base within the dry forest for the interior/south in Alternatives A and C is comprised of 

both the High Intensity Timber Area and the Uneven-aged Timber Area (Table 3-33). A larger proportion 

of the Harvest Land Base in Alternative A is in the High Intensity Timber Area, which would result in 

only a slight improvement in stand-level fire resistance in the Harvest Land Base, relative to the current 

condition. Alternative C has a larger Harvest Land Base with more acres in both the High Intensity 

Timber Area and the Uneven-aged Timber Area than Alternative A. A larger proportion of the Harvest 

Land Base in Alternative C is in the Uneven-aged Timber Area which would improve overall stand-level 

fire resistance slightly more than Alternative A.

Table 3-33. Harvest Land Base allocations in the dry forest in the interior/south

Alternative/

Proposed RMP Harvest Land Base Allocations Area(Acres)

No Action Matrix/AMA 484,563

Alt. A

High Intensity Timber Area 71,474

Uneven-aged Timber Area 54,340

Total 125,814

Alt. B Uneven-aged Timber Area 269,329

Total 269,329

Alt. C

High Intensity Timber Area 92,588

Uneven-aged Timber Area 184,528

Total 277,188

Alt. D

Moderate Intensity Timber Area 31,258

Uneven-aged Timber Area 62,214

Owl Habitat Timber Area 195,891

Total 289,363

PRMP

Moderate Intensity Timber Area 8,575

Low Intensity Timber Area 32,513

Uneven-aged Timber Area 199,370

Total 240,458
252 | P a g e

The High Intensity Timber Area includes management such as thinning and regeneration harvest with no 

retention and rapid reforestation on a relatively short rotation. This management approach would result in 

continuous horizontal and vertical fuel profiles of reduced stand-level fire resistance, more prone to 

support high-severity fire (Odion 2004, Thompson et al. 2007). Although mixed-severity fire regimes 

would have historically included patches of high-severity fire, there currently exists an overabundance of 

young and closed conditions in need of mechanical treatment or wildland fire disturbance (Haugo et al.

2015). Large areas of no retention are not representative of the prevailing vegetative patterns and structure 

associated with frequent fire, low-severity or mixed-severity fire regimes (Taylor and Skinner 2003, 

Larson and Churchill 2012).

In Alternative B, all of the dry forest Harvest Land Base in the interior/south is Uneven-aged Timber 

Area. Alternative D has most of the Harvest Land Base in the Uneven-aged Timber area or Owl Habitat 

Timber Area. The Proposed RMP has most of the Harvest Land Base in the Uneven-aged Timber Area. 

Alternatives B and D would result in the largest decrease in Low and Moderate fire resistance, relative to 

current conditions, followed by the Proposed RMP.

The management approach in the Uneven-aged Timber Area includes reducing stand densities and 

promoting or enhancing heterogeneity and large tree growth, through a combination of silviculture 

treatments, harvest, and prescribed fire. Management in the Owl Habitat Timber Area includes both 

lighter thinning and uneven-aged management. Both of these management scenarios would result in the 

largest reduction of low and moderate stand-level fire resistance and the largest increase in the mixed- and 

high-fire resistance acres. These mixed- and higher-fire resistance stands would result in more 

discontinuous fuel profiles and a greater resistance to a stand-replacement fire. Additionally, 

discontinuous fuels tend to reduce the complexities associated with implementation of prescribed fire 

(Jain et al. 2012), presenting more opportunities to apply fire on the landscape and maintain fire-resistant 

stand conditions.

The Uneven-aged Timber Area management direction also provides the latitude to increase within and 

between-stand heterogeneity in response to topographic and vegetative complexity (Hessburg et al. 2015), 

as well as create strategic landscape conditions that provide fire management opportunities. (Appendix 

B). The increased spatial heterogeneity at multiple scales, and disruption of fuel continuity, can alter 

potential fire behavior (Finney 2001) and may create conditions in which wildfire can occur without 

detrimental consequences, reducing impacts to highly valued resources, including timber and wildlife 

habitat (Jain et al. 2012). Particularly in stands that are not currently structurally-complex, the creation of 

small openings and heterogeneous (patchy) stand composition will move vegetation patterns and fuel 

loadings and arrangements toward conditions comparable to low- and mixed-severity fire regimes (Agee 

2002). These conditions may also provide opportunities for effective fire management, including the 

ability to utilize wildfire to meet land use and resource objectives consistent with management direction 

(Appendix B). However, due to the configuration of BLM-administered lands within the larger 

landscape, particularly their proximity to residential areas, the ability to use wildfire may have limited 

application. Prescribed fire would likely account for the majority of managed fire under any alternative or 

the Proposed RMP.

Alternative D has a little more than 30,000 acres of the Harvest Land Base in the Moderate Intensity 

Timber Area, while the Proposed RMP has 8,575 acres in this sub-allocation. The Moderate Intensity 

Timber Area includes thinning and regeneration harvest with 5–15 percent basal area retention, longer 

rotations, and rapid natural or artificial reforestation of species appropriate to the site. This management 

approach would result in more continuous horizontal and vertical fuel profiles and reduced stand-level 

fire resistance. However, the Moderate Intensity Timber Area constitutes only about 11 percent of the dry 

forest Harvest Land Base under Alternative D and 4 percent in the Proposed RMP diminishing its 
253 | P a g e

influence on overall stand-level fire resistance in the interior/south. The Harvest Land Base suballocations in the Proposed RMP direct some level of retention of certain large trees (Appendix B), which 

are important fire-resistant structures.

In summary, all alternatives and the Proposed RMP would reduce the acres of moderate or low fire 

resistance and increase the acres of high fire resistance, relative to current conditions across the dry forest 

in the interior/south. Although the alternatives and the Proposed RMP would differ only slightly across 

the dry forest, those differences reflect the varied extent and patterns resulting from management within 

the Harvest Land Base. The effects of some alternatives and the Proposed RMP, evident within the 

Harvest Land Base, are less evident at the entire extent of the dry forest, due to the small Harvest Land 

Base relative to a larger Late-Successional Reserve system. 

Issue 3

How would the alternatives affect fire hazard within close proximity to developed areas?

Summary of Analytical Methods

In this analysis, the BLM evaluated stand-level fire hazard within close proximity to developed areas.

In this analysis, the BLM assumed that a one-mile buffer around the West Wide Wildfire Risk 

Assessment Wildland Development Areas data layer (WWRA 2013) represents the geographic scope of 

possible immediate risks to the public and firefighter safety within close proximity to communities 

located within the Wildland Urban Interface (WUI)49 across the planning area. The Oregon Department of 

Forestry, on behalf of the Council of Western State Foresters and the Western Forestry Leadership

Coalition, completed the West Wide Wildfire Risk Assessment in 2013. This assessment quantified the 

magnitude of the current wildland fire problem in the west and established a baseline for planning 

mitigation activities and monitoring change over time. The Wildland Development Areas data layer 

provides a delineation of where people live in the wildland, classifying a minimum of 1 structure per 40 

acres as a developed area. The magnitude of human-caused ignitions that occur there illustrates the 

substantial exposure and demand on fire suppression resources within close proximity to developed areas 

and risk to life and property (Figure 3-34).

 

49 The Healthy Forest Restoration Act (2003) identifies WUI as an area within or adjacent to structures and other 

human development that meet or intermingle with undeveloped wildland.
254 | P a g e

Figure 3-34. Average annual number of human-caused ignitions in proximity to Wildland Development 

Areas, 1984–2013

Source: Oregon Department of Forestry ignition data

The BLM assigned forest structural stages (Appendix C) to a relative ranking of stand-level fire hazard 

(Table 3-34). These categories range from high to moderate fire hazard (i.e., relatively difficult to 

control) to Low fire hazard (i.e., relatively easy to control). Mixed fire hazard indicates the potential to 

exhibit the full range of hazard categories (High to Low)). Fire hazard refers to the ease of ignition, 

potential fire behavior, and resistance to control of the fuel complex, defined by the volume and 

arrangement of several strata, including surface, ladder, and canopy fuels (Calkin et al. 2010). Fire 

behavior has a direct effect on fire severity, mortality, suppression tactics, and the initiation of crown fire, 

which presents the greatest resistance to control and the largest potential to threaten wildland urban 

interfaces (Graham et al. 2004).

Table 3-34. Stand-level fire hazard ratings by structural stage

Structural Stages Subdivisions Fire Hazard

Early Successional with Structural Legacies Moderate

without Structural Legacies Moderate

Stand Establishment with Structural Legacies High

without Structural Legacies High

Young Stands – High Density with Structural Legacies High

without Structural Legacies High

Young Stands – Low Density with Structural Legacies Moderate

without Structural Legacies Moderate

Mature

Single-Layered Canopy Low

Multi-Layered Canopy Mixed

Structurally-complex

Developed Structurally-complex Mixed

Existing Old Forest Mixed

Existing Very Old Forest Mixed

56 61

26

175

46

11 12 156

13

17

9

28

0

50

100

150

200

Coos Bay Eugene Klamath

Falls

Medford Roseburg Salem

Human Caused Ignitions

(Annual Average)

District/Field Office

Within WDA Outside WDA
255 | P a g e

The BLM assumed that broad descriptions of forest vegetation conditions reflect relative stand-level fire 

hazard, based on general assumptions regarding the fuel profile and the probable fire behavior within that 

structural stage classification. The BLM quantified the acreage of forested BLM-administered lands in 

each fire hazard category for each alternative and the Proposed RMP over the course of 50 years within a 

1-mile buffer of the Wide Wildfire Risk Assessment Wildland Development Areas data layer (WWRA 

2013).

Similar to the analytical methods for stand-level fire resistance, this analysis does not account for the

complex interaction among fuels (including vertical and horizontal composition and moisture), 

topography (e.g., slope, topographic position, elevation, and aspect), and weather (e.g., wind, temperature, 

relative humidity, fuel moisture, and drought) that influence fire behavior, resultant burn severity, and fire 

effects (Andrews and Rothermel 1982 and Scott and Reindhardt 2001).

The results of this analysis do not include effects from non-commercial hazardous fuels work, which 

would contribute toward reducing fire hazard similarly among all alternatives and the Proposed RMP, and 

be less likely to result in structural stage shifts.

Appendix H provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales.

Background

Managing fire hazard in the western United States is becoming an increasingly complex challenge. 

Wildland fuels continue to build, drought conditions persist, human development spreads, budgets 

fluctuate, and fire suppression costs increase. New home construction steadily increased within wildland 

areas in Oregon between 1990 and 2008 (Stein et al. 2013, Brown et al. 2014), and this trend is likely to 

continue in the future, given expected increases in Oregon’s population (OR OEA 2012).

Much of the planning area has a checkerboard pattern of ownership, with square mile sections alternating 

between private and BLM-administered lands. The BLM-administered lands in the planning area are 

typically located in the foothills and mountains surrounding inhabited valley bottomlands and are closely 

intermixed with small towns, rural residential areas, and private and industrial forests. This is an area 

commonly referred to as the Wildland Urban Interface (WUI). These lands all have different land use 

objectives and boundaries that wildfire does not recognize. Additionally, this complex multi-jurisdictional 

landscape increases the inherent complexities of fuel reduction efforts, particularly prescribed burning, 

and fire management operations, including managing wildfires to meet resource and land use objectives 

due to the risk of affecting adjacent lands.

The Healthy Forest Restoration Act (2003) provides the latitude to Community Wildfire Protection Plans 

(CWPP) to refine their WUI boundary, based on vegetation conditions, topography, and geographic 

features, including infrastructure, where strategic fuel reduction can reduce risks from large, severe 

wildfires and promote fire-adapted communities. Additionally, CWPPs may incorporate areas near 

communities that have important economic, social, cultural, visual, and ecological values in the 

delineation of their WUI boundary (CWPP Handbook 2004). Collaborating partners, including the BLM, 

use Community Wildfire Protection Plans and WUI boundaries for local coordination, prioritization, and 

implementation of landscape-level fuel treatments. These plans often contain fine-scale analysis that 

provide a robust investigation of ways to prioritize fire risk mitigation around locally identified and vetted 

highly valued resources and assets (e.g., Metlen et al. 2015), and aid in the identification of strategically 

defensible fuel breaks for wildland fire management.
256 | P a g e

Between 18 and 44 percent of BLM-administered lands are within 1 mile of Wildland Development 

Areas (Map 3-3). The Eugene and Medford Districts have the largest proportion, 41 and 44 percent, 

respectively. The Medford District has more than three times the acreage of any other district within close 

proximity to developed areas. A quarter of BLM-administered lands within Coos Bay (25 percent), 

slightly more than one third of Roseburg BLM-administered lands (31 percent), and nearly one third of 

Salem BLM-administered lands (28 percent) are within close proximity to wildland development areas. 

The Klamath Falls Field Office has the smallest proportion (18 percent) of BLM-administered lands 

within 1 mile of Wildland Development Areas. For many districts, the footprint of Wildland 

Development Areas buffered by 1 mile is a considerably smaller extent than the CWPP WUI boundaries. 
257 | Page

INSERT MAP HERE 

Map 3-3. Wildland Development Areas within the Planning Area 
258 | P a g e

The vast majority of BLM-administered lands burned by wildfire are in the interior/south (Table 3-35). In 

the past decade, less than 5 percent of the acres burned in the decision area were in the coastal/north.

Table 3-35. Total acres burned by wildfires within the planning area, 1984–2013

10-year Interval Coastal/North

(Acres)

Interior/South

(Acres)

1984–1993 23,476 138,612

1994–2003 12,938 583,724*

2004–2013 6,601 163,352

* Includes the 499,945-acre Biscuit wildfire

Source: Oregon Department of Forestry ignition data

Between 1984 and 2013, human-caused ignitions were the source of most wildfires for nearly all districts 

within the planning area (Figure 3-22). The vast majority of all human-caused ignitions occurred within 

close proximity to developed areas (Figure 3-34). Increased development of homes in the WUI, trail 

systems, dispersed campsites, recreation, and major travel corridors all serve to increase the risk of

human-caused fires.

During this period, the Oregon Department of Forestry has provided fire prevention and protection 

services on BLM-administered lands in the planning area under the Western Oregon Fire Protection 

Services contract. Firefighting resources across the planning area have been highly effective at 

minimizing acres burned for most wildfires, keeping 96 percent of all ignitions to less than 10 acres in 

size (Table 3-30). However, extreme fire weather conditions still present problems for control.

Affected Environment and Environmental Consequences

Currently, almost half of all forested, BLM-administered lands within close proximity to Wildland 

Development Areas have High to Moderate stand-level fire hazard (i.e., fires are relatively difficult to 

control). In the coastal/north, approximately 20 percent of forested, BLM-administered lands within close 

proximity to Wildland Development Areas have Low stand-level fire hazard (i.e., fires are relatively easy 

to control) (Figure 3-35). In the interior/south, only 5 percent of forested, BLM-administered lands 

within close proximity to Wildland Development Areas have Low stand-level fire hazard (Figure 3-36).
259 | P a g e

Figure 3-35. Stand-level fire hazard for all BLM-administered lands in the coastal/north within the WUI 

by current condition and in 2063

Figure 3-36. Stand-level fire hazard for all BLM-administered lands in the interior/south within the WUI, 

by current condition and in 2063

64,695 

94,131 91,143 91,115 80,235 91,434 93,226 

95,507 

146,716 132,166 141,066 

103,350 

159,898 139,977 

7,821 

22,615 

22,376 

37,714 

33,872 

14,659 

19,482 130,420 

34,980 52,757 

28,547 

80,985 

32,451 45,756 

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Hazard (Percent of Acres)

Low Mixed Moderate High

22,997 

76,173 74,087 70,748 63,640 81,468 71,578 

193,172 

178,543 

225,752 236,895 

221,893 

234,335 232,822 

35,878 

41,403 

29,028 30,395 

32,080 

23,217 26,164 

194,690 

150,618 

117,870 108,698 129,124 107,717 116,172 

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Fire Hazard (Percent of Acres)

Low Mixed Moderate High
260 | P a g e

In 50 years, all alternatives and the Proposed RMP would result in a decrease of stand-level fire hazard 

for the 298,441-forested acres within close proximity to Wildland Development Areas (WWRA 2013) in 

the coastal/north (Figure 3-35). All alternatives and the Proposed RMP would reduce the acres of 

Moderate or High fire hazard and increase the acres of Low hazard, relative to current conditions. 

Alternative C would result in the least reduction of High or Moderate hazard acreage. The No Action 

alternative and Alternative D would result in the largest reduction in the acreage of Moderate or High fire 

hazard, closely followed by Alternatives A and B, and the Proposed RMP. The effects of the alternatives 

and the Proposed RMP on stand-level fire hazard for individual districts in 50 years would approximate 

the effects across the entire coastal/north portion of the planning area (Appendix H).

In 50 years, all alternatives and the Proposed RMP would result in a decrease in stand-level fire hazard 

for the 446,737-forested acres within close proximity to developed areas in the interior/south (Figure 3-

36). All alternatives and the Proposed RMP would reduce the acres of Moderate or High fire hazard and 

increase the acres of Low hazard, relative to current conditions. The No Action alternative and 

Alternative C would result in the least reduction of High or Moderate hazard acreage. Alternatives A, B, 

and D, and the Proposed RMP would reduce Moderate or High fire hazard within close proximity to 

Wildland Development Areas (WWRA 2013) similarly and to a greater extent than Alternative C or the 

No Action alternative. The effects of the alternatives and the Proposed RMP on stand-level fire hazard for 

individual districts in 50 years would approximate the effects across the entire interior/south portion of 

the planning area (Appendix H).

As concluded in Issue 2, all alternatives and the Proposed RMP would have similar effects on fire hazard 

within the Late-Successional Reserve and the patterns of change would not differ (Appendix H). In 

addition, the extent of the Harvest Land Base under each alternative and the Proposed RMP and the 

associated changes in vegetation due to differing management direction would influence the overall 

patterns in stand-level fire hazard, rather than changes within the reserves. However, the relatively small 

extent of the Harvest Land Base minimizes changes in fire hazard patterns at the scale of all Wildland 

Development Areas.

In the coastal/north, the alternatives and the Proposed RMP differ in the extent and location of the Harvest 

Land Base. However, the current fire hazard conditions are relatively similar within close proximity to 

Wildland Development Areas among the alternatives and the Proposed RMP (Figure 3-37). All 

alternatives and the Proposed RMP have between 50 and 60 percent of the acreage in High or Moderate 

fire hazard. Alternative C has the largest acreage of Harvest Land Base within proximity to Wildland 

Development Areas. Alternative C has the largest amount of Harvest Land Base within close proximity to 

developed areas. The amount of Harvest Land Base within proximity to Wildland Development Areas is 

relatively similar among the No Action alternative and Alternatives B and D. Alternative A and the 

Proposed RMP have the smallest acreage of Harvest Land Base within proximity to Wildland Developed 

Areas.
261 | P a g e

Figure 3-37. Stand-level fire hazard for the Harvest Land Base in the coastal/north within the WUI by current condition and in 2063

25,612 

31,760 

18,749 16,527 20,376 

26,557 

32,929 35,514 23,486 26,702 

16,423 17,105 

24,550 

30,769 

13,032 

2,737 

15,623 

14,442 

34,642 

8,362 

15,878 

36,095 

12,658 

6,903 

3,473 

18,511 

2,645 

17,714 

2,914 

33,419 

4,410 

30,617 

3,136 

10,549 

2,513 15,067 

48,259 

20,853 

42,833 40,282 

51,251 

15,745 

74,234 71,722 

51,914 

21,067 

38,927 

31,447 

0%

20%

40%

60%

80%

100%

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

No Action (101,893) Alt. A (77,260) Alt. B (90,163) Alt. C (146,215) Alt. D (94,413) PRMP (70,521)

Harvest Land Base by Alternative (Acres)

Fire Hazard (Percent of Acres)

Low Mixed Moderate High
262 | P a g e

In 50 years, the No Action alternative and Alternatives B, C, and D, and the Proposed RMP would vary 

slightly increase the proportion of low hazard acres in the Harvest Land Base, relative to the current 

condition in the coastal/north (Figure 3-37). Within the Harvest Land Base, Alternative D would decrease 

the proportion of High and Moderate hazard by 25 percent, and the No Action alternative would result in 

a decrease of 12 percent. Alternative B would decrease the proportion of High hazard by 39 percent, and 

increase Moderate hazard by 34 percent, resulting in a slight (6 percent) net decrease of acreage in High

or Moderate hazard within the Harvest Land Base. Similarly, Alternative A and C would only slightly 

decrease the proportion of High hazard and increase moderate hazard, resulting in a net increase (16 

percent) of acreage in High or Moderate hazard within the Harvest Land Base. The Proposed RMP would 

slightly decrease the proportion of High hazard, and increase Moderate hazard, resulting in a slight (7 

percent) net increase of acreage in High or Moderate hazard within the Harvest Land Base.

For the interior/south, the alternatives and the Proposed RMP also differ in the extent and location of the 

Harvest Land Base, and the current conditions of fire hazard differ (Figure 3-38). The No Action 

alternative has the largest Harvest Land Base (i.e., Matrix and Adaptive Management Areas) and the 

smallest proportion (53 percent) currently in High or Moderate fire hazard. The size of the Harvest Land 

Base is relatively similar in Alternatives B, C, and D, and the Proposed RMP, and approximately 60 

percent of the acreage is in High or Moderate fire hazard. Alternative A has the smallest Harvest Land 

Base and the largest proportion (75 percent) in High or Moderate fire hazard.
263 | P a g e

Figure 3-38. Stand-level fire hazard for the Harvest Land Base in the interior/south within the WUI by current condition and in 2063

14,335 

39,180 

5,060 6,524 8,616 

22,514 

8,943 

21,416 

8,809 

30,753 

7,195 

18,381 

107,790 

78,314 

12,491 10,808 

50,553

63,772 

51,605 

52,207 

41,919 

53,300 

40,310 

47,421 

22,664 35,660 

7,831 

12,653 

9,644 

16,952 

10,645 

18,802 

10,576 

9,363 

9,644 

11,530 

116,322 107,958 

44,826 

40,221 

74,498 

40,073 

85,730 

64,498 

74,458 

42,347 

62,929 

42,746 

0%

20%

40%

60%

80%

100%

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

Current

Condition

Year

2063

No Action (261,111) Alt. A (70,207) Alt. B (143,311) Alt. C (156,923) Alt. D (135,763) PRMP (120,078)

Harvest Land Base by Alternative (Acres )

Fire Hazard (Percent of Acres)

Low Mixed Moderate High
264 | P a g e

In 50 years, all alternatives and the Proposed RMP would slightly increase the proportion of Low hazard 

acres, relative to the current condition in the Harvest Land Base in the interior/south (Figure 3-38). 

Alternative D would decrease the proportion of High and Moderate hazard by 25 percent, Alternative B 

would result in a decrease of 19 percent, and the Proposed RMP a decrease of 15 percent. Alternative C 

would only slightly decrease (8 percent) the proportion of High and Moderate hazard. The No Action 

alternative would result in slight increase in High and Moderate hazard acreage within close proximity to 

Wildland Development Areas, while there would be no change in Alternative A. 

In summary, all alternatives and the Proposed RMP would increase the acres of Low hazard, relative to 

current conditions, on all BLM-administered lands within close proximity to Wildland Development 

Areas. Alternatives A and C, and the Proposed RMP would increase the total combined acres in High or 

Moderate fire hazard, and the No Action alternative and Alternatives B and D would reduce the total 

combined acres in High or Moderate fire hazard relative to current conditions on all BLM-administered 

lands within close proximity to Wildland Development Areas. However, among all the alternatives and 

the Proposed RMP, the differences are slight and largely reflect the different extents and varied patterns 

resulting from management within the Harvest Land Base. The BLM’s management within the planning 

area is unable to provide more than slight variation to fire hazards within the planning area due to the 

checkerboard pattern of the landscape within the planning area and the small Harvest Land Base relative 

to a larger Late-Successional Reserve. The Harvest Land Base effects on fire hazard patterns are 

diminished at the scale of all BLM-administered Lands within Wildland Development Areas, particularly 

in the coastal/north. 

Issue 4 

How would the alternatives affect the number of acres at risk from residual activity fuels associated with 

timber management?

Summary of Analytical Methods 

In this analysis, the BLM determined the potential fire risk associated with residual activity fuels resulting 

from timber management activities, treatment locations relative to Wildland Development Areas (WWRA 

2013), and the Wildland Fire Potential (USDA FS and FMI 2012) for all BLM-administered lands within 

the decision area.

Fire risk describes the likelihood, susceptibility, and intensity for wildfire and adverse effects to human 

values. In this analysis, the BLM assumed that Wildland Development Areas are a highly valued 

resource, the Wildland Fire Potential describes the likelihood for wildfire, and activity fuel loading has 

the potential to increase fire intensity.

In addition to proximal location of treatments to developed areas, the Wildland Fire Potential (USDA FS 

FMI 2013) is an important factor in determining the risk from residual fuel loading. The Wildland Fire 

Potential depicts the relative probability of experiencing extreme fire behavior with torching and 

crowning, and the potential for wildfire that would be difficult for suppression resources to contain during 

weather conditions favorable for fire growth. This data is based on past fire occurrence, 2008 fuels data 

from LANDFIRE, and 2012 estimates of wildfire likelihood and intensity from the large fire simulator 

(Finney et al. 2011). The interior/south has more acreage in the Very High and High Wildland Fire 

Potential categories than the coastal/north, closely resembling the distribution of moist and dry vegetation 

(Table 3-36 and Figure 3-39). 
265 | Page

Figure 3-39. Wildland Fire Potential for BLM-administered lands in the planning area 

Table 3-36. Wildland Fire Potential acres for BLM-administered lands in the planning area 

Wildland Fire Potential Interior/South

(Acres)

Coastal/North

(Acres)

Very Low/Low 154,398 377,879

Moderate 385,572 450,944

High 499,709 205,162

Very High 399,605 1,675

In this analysis, the BLM determined a relative weighting of residual activity fuel that would remain 

following timber management activities (Table 3-37), based on the management type and intensity. 

Timber harvest prescriptions that remove greater basal area from stands leave more surface fuels. This 

increase in surface fuels has the potential to result in higher rates of spread and greater flame lengths in 
266 | P a g e

the event of a wildfire (Weatherspoon and Skinner 1995, Raymond and Peterson 2005, Prichard et al.

2010), increasing the risk to firefighters and public safety (Graham et al. 1999 and 2004). Many different 

treatments can accomplish surface fuel reduction, including prescribed fire, biomass removal, and 

mechanical mastication or manipulation.

Table 3-37. Relative weighting of residual surface fuel loading by timber management type and intensity

Timber Management Type

(Intensity)

Residual Fuel Load

(Weighted Value)

Selection (Moderate/Light) 2

Thinning 2

Thinning with No Extraction 3

Selection (Heavy) 3

Pre-commercial Thinning 3

Two-age (Light) 3

Clearcut/Two-age (Heavy/Moderate) 4

The weighting represents the probable amount of fuel loading based on the retention associated with the 

timber management type, where less retention has more residual fuel loading. Clearcut harvest would 

occur in the High Intensity Timber Area in Alternatives A and C. Heavy and moderate two-age 

regeneration harvest would occur in the Matrix in the No Action alternative and the Medium Intensity 

Timber Area in Alternatives B and D. Light two-age regeneration harvest would occur in the Low 

Intensity Timber Area in Alternative B. Heavy selection harvest would generally occur in the UnevenAged Timber Area in all action alternatives and the Proposed RMP. Moderate selection harvest would 

generally occur in the Owl Habitat Timber Area in Alternative D. Light selection harvest would occur in 

reserves in all alternatives and the Proposed RMP. Thinning and pre-commercial thinning would occur 

throughout the Harvest Land Base in all alternatives and the Proposed RMP. These harvest intensities are 

rough generalizations used as analytical assumptions, but are not intended to replace or supplement 

management direction in each alternative or the Proposed RMP.

Additional factors influence the need and ability to mitigate residual fuel loading, such as stand structure, 

yarding method, harvest unit size, biomass utilization, topographic position, road proximity, soil 

composition, fuel decomposition rates, fuel compaction, airshed restrictions, and weather conditions. 

However, the BLM cannot accurately forecast these site-specific and market-driven variables for analysis 

and modeling at this scale.

The BLM determined the relative risk of residual fuel (Table 3-38) based on the weighted combination of 

Wildland Fire Potential (USDA FS FMI 2013), treatment location relative to the zone within 1 mile of 

Wildland Development areas (WWRA 2013), and the probable residual activity fuel loading associated 

with timber management activities. The BLM assigned a weight of 1 to areas beyond 1 mile of 

development areas and a weight of 2 to areas within 1 mile of wildland development areas. Wildland Fire 

Potential weights followed the classification scheme (e.g., Very Low/Low = 1 and High = 4). The BLM 

assigned weights to the harvest activities based on probable residual fuel loading relative to proportional 

basal area removed (Table 3-37). The BLM derived a risk matrix by multiplying these weighted variables 

and grouping them numerically into four categories. The BLM quantified the average decade total 

acreage within each risk category over 50 years for each of the alternatives and the Proposed RMP. The 

BLM evaluated the effects on the relative risk posed from residual activity fuel loading associated with 

management activities throughout the decision area.
267 | P a g e

Table 3-38. Risk category based on predicted residual activity fuel following harvest, proximal location 

to Wildland Development Areas, and Wildland Fire Potential

Wildland Fire 

Potential

Proximity to Development 

Areas

(WWRA WDA)*

Residual Activity Fuel from

Timber Management Activities

Low Moderate High

Very Low/Low Outlying Low Low Low

Within Low Low Low

Moderate Outlying Low Low Low

Within Low Moderate Moderate

High Outlying Low Moderate Moderate

Within Moderate High High

Very High Outlying Low Moderate Moderate

Within Moderate High Very High

* Source: Wildland Development Areas (WWRA 2013) and Wildland Fire Potential (USDA FS FMI 2013)

Background

Historically, the BLM has treated a portion of residual activity fuels following timber management

activities for both site preparation and hazardous fuels reduction purposes. The BLM incorporated these 

assumptions into the modeling as a reasonable expectation of future levels of treatments (Appendix C). 

The treatment of slash from pre-commercial thinning is highly dependent on the residual stand structure, 

topographic location, and cost/benefit trade-offs of hazard reduction.

Affected Environment and Environmental Consequences

The current fire risk based on Wildland Fire Potential and proximity to WUI, for BLM-administered lands 

follows a similar pattern to the moist and dry forest distribution across offices (Table 3-39). The 

coastal/north has over 60 percent of BLM-administered lands in the Low risk category. Most of the 

remaining acres in the coastal/north are at Moderate risk. In the interior/south, nearly half of all BLMadministered lands are at Moderate risk. Nearly a quarter of this area is in the Very High (10 percent) and 

High (13 percent) risk categories.

Table 3-39. Current fire risk categories for BLM-administered lands

Planning

Area Region

Low Risk Moderate Risk High Risk Very High Risk

(Acres) (Percent) (Acres) (Percent) (Acres) (Percent) (Acres) (Percent)

Coastal/North 675,325 66% 295,099 29% 56,926 6% 1,432 < 1%

Interior/South 407,824 28% 684,619 48% 192,465 13% 147,642 10%

Over 50 years, the alternatives and the Proposed RMP would differ substantially in the acreage of timber 

management activities, and, consequently, the acreage with residual activity fuels. Alternative A would 

have the fewest average acres of timber management activities per decade in both the coastal/north and 

interior/south. Alternative C would result in the highest average acres of timber management activities per 

decade in the coastal/north, and Alternative B would have the highest average acres of timber

management activities per decade in the interior/south (Figure 3-40 and Figure 3-41).
268 | P a g e

Figure 3-40. Activity fuel risk categories for BLM-administered lands in the coastal/north, decadal 

average 2013–2063

Figure 3-41. Activity fuel risk categories for BLM-administered lands in the interior/south, decadal 

average 2013–2063

84,338

54,342

77,838

102,853

70,678 64,305

13,764

19,555

17,878

32,750

11,073 16,179

2,187

3,905

3,477

7,236

1,624 2,862

0

5

56

58

34 25

0

40,000

80,000

120,000

160,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Activity Fuel Risk (Acres)

Low Moderate High Very High

42,587

31,601

53,354 54,022 50,635 52,927

34,412

24,067

60,030 53,974

25,505

51,682

17,469

13,157

39,392

36,234

13,296

31,949

2,113

1,473

32

875

315

60

0

40,000

80,000

120,000

160,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Activity Fuel Risk (Acres)

Low Moderate High Very High
269 | P a g e

For the coastal/north, the majority of managed acres would be at Low risk from residual activity fuel 

under all alternatives and the Proposed RMP (Figure 3-40). Alternative C would result in the most acres 

of Moderate and High risk for the coastal/north. Alternative D would result in the fewest average acres 

per decade of Moderate and High residual fuel risk for the coastal/north. Alternatives A and B and the 

Proposed RMP would result in similar amounts of Moderate and High residual fuel risk acreage between 

Alternative C and D. Alternative C would result in the largest amount of Low risk acreage per decade in 

the coastal/north.

In the interior/south, over the course of 50 years, both Alternatives B and C, followed by the Proposed 

RMP, would result in the most acres of Moderate and High risk from residual activity fuel. Alternatives A 

and D would result in the fewest average acres per decade of Moderate and High residual fuel risk 

(Figure 3-41). Alternatives B, C, D, and the Proposed RMP would result in the largest amount of Low

risk acreage. The No Action alternative and Alternative A would create a very small amount of acres in 

very high risk.

The size of the Harvest Land Base and the timber management type and intensity are factors influencing 

the amount of acres in each risk category by alternative and the Proposed RMP. For example, alternatives 

or the Proposed RMP that would have the largest amount of timber harvest and pre-commercial thinning 

per decade, would also have the most acres in Moderate and High risk activity fuel categories. This is true 

of Alternative C in both the coastal/north and interior/south, and Alternative B and the Proposed RMP in 

the interior/south. While Alternative A has the smallest Harvest Land Base, a larger portion of it is the 

High Intensity Timber Area. Consequently, Alternative A would have amounts of Moderate and High risk 

similar to alternatives and the Proposed RMP with a larger Harvest Land Base, but less intensive harvest 

management.

By generating residual activity fuels, timber management activities would have the potential to add to the 

current fire risk if not adequately treated (Agee 1993, Weatherspoon and Skinner 1995, Raymond and 

Peterson 2005). The acres in residual fuel risk categories provide an estimate of potential future work

needed to reduce the risk associated with activity fuels. A variety of follow-up treatments could mitigate 

most residual activity fuel, depending on the risk and amount of remaining fuel. Depending on the 

residual stand structure, allocating resources to mitigate the activity fuel loading, particularly through 

prescribed burning, could result in some level of post-treatment mortality to the residual stand. This could 

have the effects of reducing the risk and developing stand structural diversity. Alternatively, mitigation of 

activity fuels might not reduce the hazard or could result in unacceptable levels of tree mortality. In some 

cases, the Wildland Fire Potential would be minor, and treating activity fuels may not be necessary to 

reduce risk. For example, under Alternative A, trees cut for restoration thinning in the Late-Successional 

Reserve in the moist forest would remain on-site. This situation would likely result in low risk, given the 

districts with greater proportions of moist forest have lower Wildland fire Potential (Figure 3-23 and 

Figure 3-39).

Coupling the activity fuel risk with stand-level hazard or resistance (see Issues 2 and 3) illustrates the 

costs and benefits of doing the work to mitigate the risk. For example, in the interior/south, Alternatives B 

and C, and the Proposed RMP would result in similar amounts of Moderate and High risk residual 

activity fuel acres. Treatment of activity fuel in Alternative C would clearly reduce a portion of the risk, 

but the remaining stand structure would be less fire resistant and of higher fire hazard than in Alternative 

B or the Proposed RMP. Treatment of residual activity fuels in Alternative B and the Proposed RMP may 

provide a greater overall benefit in reducing risk within the planning area, and the remaining stand 

structure would be more fire resistant and of lower fire hazard than in Alternative C. In addition, in the 

interior/south, Alternative D would have the fewest acres in High or Moderate activity fuel risk, as well as 

improvement in stand-level fire resistance and hazard. This combination might also provide increased 

stand-level fire resistance and lower risk activity fuel loading. For the coastal/north, Alternative C would 
270 | P a g e

have the largest residual fuel load risk and the highest relative stand-level hazard. For the coastal/north, 

the No Action alternative, Alternatives B and D, and the Proposed RMP would have lower amounts of 

both activity fuel risk and stand-level hazard ratings. 

In summary, the size of the Harvest Land Base and the timber management type and intensity influence 

the amount of acres in each risk category by alternative and the Proposed RMP. The acreage in activity 

fuel risk categories provides an estimate of potential future work needed to reduce the risk associated with 

activity fuels. Alternative C for the entire decision area, and Alternative B and the Proposed RMP in the 

southern portion would result in the greatest need for treatment of activity fuel to reduce risk. Coupling 

the stand-level fire hazard and resistance results with the activity fuel risk helps to illustrate the 

cost/benefit of doing work to mitigate the risk.

Issues Considered but not Analyzed in Detail

How would the alternatives affect the implementation and effectiveness of hazardous fuels treatments?

All of the alternatives and the Proposed RMP have similar management objectives and management 

direction regarding non-commercial natural hazardous fuels reduction treatments. Therefore, the BLM 

assumed in this analysis that similar types and amounts of treatments that have occurred over the past 

decade would continue in the future under any of the alternatives and the Proposed RMP (Table 3-40), 

despite substantial year-to-year variation in acres treated. For example, acres of under-burning may 

increase and acres of hand pile burning decrease, as programs shift into the maintenance of previouslytreated non-commercial hazardous fuels units.

Table 3-40. Non-commercial natural hazardous fuels treatment acres by treatment type, 2003–2012

District/

Field Office

Biomass 

Removal

(Acres)

Hand Pile 

and Burn 

(Acres)

Machine Pile 

and Burn 

(Acres)

Mechanical 

Manual50

(Acres)

Mechanical 

Mastication 

(Acres)

Underburn/

Broadcast Burn 

(Acres)

Coos Bay 1,161 595 63 122 1,680 1,092

Eugene - 192 1 10,354 813 15

Klamath Falls 5,443 4,163 17,071 4,592 2,198 9,371

Medford 1,190 62,497 - 15,032 3,161 22,064

Roseburg - 422 - 2,313 - 3,235

Salem - 438 - 3,733 280 -

Increasing landscape-level fire resilience and stand-level fire resistance and decreasing stand-level fire 

hazard would increase the effectiveness of hazardous fuels treatments. To the extent that changes in 

landscape-level fire resilience, stand-level fire resistance, stand-level fire hazard, and residual activity fuel 

loading influence the effectiveness of hazardous fuels treatments, the previous issues in this section 

describe the effects of these factors. However, it is not possible at this scale of analysis with the data 

available to describe specifically how such changes together would alter the effectiveness of hazardous 

fuels treatments or to consider how differing combinations of outcomes would alter the effectiveness of 

hazardous fuels treatments (e.g., increased stand-level fire resistance within a landscape of decreased fire 

resilience). Therefore, it is not possible to determine any specific change in the effectiveness of hazardous 

fuels treatments resulting from the alternatives and the Proposed RMP.

 

50 Mechanical manual includes thinning, mowing, chipping, lop and scatter, etc. See Glossary for additional 

treatment descriptions.
271 | P a g e

How would the alternatives affect wildfire response?

There is no accurate way to predict the exact location and timing of wildfires. However, treatments that 

reduce flame lengths and decrease the probability of crown fire potential would minimize risk to wildland 

firefighters and the public, and provide more effective fire management opportunities, including safe 

engagement of suppression resources. These treatments would also increase the potential to utilize all fire 

management tools, including utilizing wildfires to meet resource objectives. The previous issues in this 

section describe effects to landscape-level fire resilience, stand-level fire resistance, stand-level fire 

hazard, and residual activity fuel loading. To the extent that changes in landscape-level fire resilience, 

stand-level fire resistance, stand-level fire hazard, and residual activity fuel loading potentially influence 

wildfire response, the previous issues in this section describe the effects these factors. The full range of 

wildfire response tactics would be available under all alternatives and the Proposed RMP. Maintenance of 

fire management related infrastructure would not change among alternatives and the Proposed RMP. The 

ability to conduct salvage harvest in the Late Successional Reserve for purposes of protecting human 

health and safety within the dry forest would be available under all alternatives and the Proposed RMP. 

Because these factors would not differ, there is no reasonable basis on which to identify a difference in 

the effect of the alternatives and the Proposed RMP on wildfire response at this scale of analysis, beyond 

the effects to landscape-level fire resilience, stand-level fire resistance, and stand-level fire hazard already 

described above.

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Fisheries

Key Points

 All alternatives and the Proposed RMP would increase the potential large wood and small 

functional wood contribution to streams relative to the current conditions over time.

 Sediment production from road construction and operation would increase by less than 1 percent 

under all alternatives and the Proposed RMP, and the effects to fish would not differ by 

alternative. These effects to fish would be short-term and localized and could result from 

increases in turbidity or deposition of fines in the stream channel substrates affecting habitat in 

the short term.

 Under the No Action alternative, and Alternatives A and D, and the Proposed RMP, less than 0.5 

percent of all perennial and fish-bearing stream reaches in the decision area would be susceptible 

to shade reductions that could affect stream temperature if the BLM applies thinning in the outer 

zone of the Riparian Reserve based on current conditions. Under Alternative B and C, 

approximately 5 percent of all perennial and fish-bearing reaches in the decision area would be 

susceptible to shade reductions that could affect stream temperature if the BLM applies thinning 

in the outer zone of the Riparian Reserve based on current conditions. Short-term and indirect 

non-lethal effects from minor increases in stream temperature could include reduced growth rates, 

a reduction in juvenile survival, or a reduction in reproductive success.

Summary of Notable Changes from the Draft RMP/EIS

The BLM has expanded the discussion of fish species other than anadromous salmonids and has added an 

appendix (Appendix I), which includes a list of the Bureau Sensitive and Bureau Strategic fish species 

and maps of the designated critical habitat for ESA-listed anadromous salmonid fish. The BLM has also 

added explanation that the effects to Essential Fish Habitat designated under the Magnuson-Stevens 

Fishery Conservation and Management Act would be similar to the effects to designated critical habitat.

Background

Threatened and endangered anadromous fish species in the planning area include: 

 Lower Columbia River chinook salmon

 Lower Columbia River coho salmon

 Lower Columbia River steelhead trout

 Columbia River chum salmon

 Upper Willamette River chinook salmon

 Upper Willamette River steelhead trout

 Southern Oregon/Northern California coho salmon

 Oregon Coast coho salmon

 North American green sturgeon

 Pacific eulachon (smelt)

In 2011, National Marine Fisheries Service conducted a formal status review of ESA-listed anadromous 

salmon and steelhead. The analysis and summaries of that review are incorporated here by reference 

(USDC NMFS 2011). Oregon Coast coho salmon and Southern Oregon/Northern California Coho salmon 

were not included in that analysis. Of the six anadromous salmon and steelhead in the planning area that 

were analyzed in that review, none warranted a change in the biological risk category from the previous 
278 | P a g e

review in 2005. The Lower Columbia coho has a biological risk assessment of in danger of extinction, 

and the remaining five species are likely to become endangered.

The National Marine Fisheries Service has designated critical habitat for seven of the eight ESA-listed 

anadromous salmonid species within the planning area (Table 3-41 and Appendix I). Critical habitat is 

not mapped for Southern Oregon/Northern California Coho salmon; however, steelhead trout distribution 

provides a surrogate. The National Marine Fisheries Service has published recovery plans for Lower 

Columbia River chinook, Lower Columbia River steelhead, Lower Columbia River coho, Upper 

Willamette chinook, Upper Willamette steelhead, and Southern Oregon Northern California coho salmon 

(USDC NMFS 2011, 2013, and 2014) and has developed a Proposed ESA Recovery Plan for the Oregon 

Coast coho salmon (USDC NMFS 2015). The U.S. Fish and Wildlife Service has published recovery 

plans for bull trout (USDI FWS 2014) and the Lost River sucker and shortnose sucker (USDI FWS 2013).

Recovery plans for ESA-listed fish include the identification of limiting factors for each recovery unit and 

include recommendations for recovery actions. Limiting factors for the eight anadromous salmonid 

species include temperature, spawning and rearing habitat, and off-channel habitat.

Table 3-41. Federal Register notices for listing status, critical habitat designation, and ESA protective 

regulation for ESA-listed anadromous fish in the planning area.

Species Listing Status Critical Habitat Protective

Regulation

Lower Columbia River chinook salmon June 28, 2005;

70 FR 37160 September 02, 2005;

70 FR 52630

June 28, 2005;

70 FR 37160

Upper Willamette River chinook salmon

Columbia River chum salmon

Lower Columbia River steelhead trout January 05, 2006;

Upper Willamette River steelhead trout 71 FR 834

Lower Columbia River coho salmon June 28, 2005;

70 FR 37160

January 14, 2013;

78 FR 2726

Southern Oregon/Northern California 

coho salmon

May 05, 1999;

64 FR 24049

Oregon Coast coho salmon June 20, 2011;

76 FR 35755 February 11, 2008; 73 FR 7816

Pacific eulachon March 18, 2010;

75 FR 13012

October 20, 2011;

76 FR 65324

June 28, 2005;

70 FR 37160

Threatened or endangered resident fish species in the planning area include:

 Bull trout

 Lost River sucker

 Shortnose sucker

The amount of critical habitat for ESA-listed non-salmonid fish species or resident salmonid fish species 

on BLM-administered lands is less than 5 percent of all critical habitat for fish in the decision area (Table 

3-42). A total of 3.6 miles of bull trout (Salvelinus confluentus) critical habitat occur on BLMadministered lands within the Coastal and Klamath recovery units, comprising less than 0.1 percent of 

bull trout critical habitat. The reintroduction of bull trout in the Clackamas River constitutes a 

nonessential experimental population and does not have any adjacent BLM-administered lands. Bull trout 

require colder temperatures and tolerate fine sediment less than most other salmonids in the planning area,

and are therefore more sensitive to changes in temperature and sediment. Despite this greater sensitivity, 
279 | P a g e

bull trout are affected by the same key ecological processes as the ESA-listed anadromous salmonids in 

the decision area, allowing them to be analyzed together at this scale of analysis.

Table 3-42. ESA-listed fish species (other than anadromous salmonids) with miles and percent of critical 

habitat on BLM-administered lands.

Species

Critical 

Habitat 

(Miles)

Critical Habitat on

BLM-administered 

Lands in the

Planning Area

(Miles)

Critical Habitat

on BLM-administered 

Lands in the

Planning Area

(Percent)

Bull trout (Salvelinus confluentus) 4,954 3.6 < 0.1%

Shortnose sucker (Chasmistes 

brevirostris)

135 9.0 6.6%

Lost River sucker (Deltistes luxatus) 145 - -

Pacific eulachon (Thaleichthys pacificus) 335 0.12 < 0.1%

Green sturgeon (Acipenser medirostris) 1,107 0.07 < 0.1%

The southern distinct population segment (DPS)51 of green sturgeon (Acipenser medirostris) occurs in 

lower reaches of coastal rivers and estuaries and has limited interaction with BLM-administered lands. 

Critical habitat for green sturgeon extends in to the lower Columbia River, Nehalem Bay, Yaquina Bay,

Winchester Bay, and Coos Bay. The only interaction between green sturgeon critical habitat and BLMadministered lands is a boat ramp on the Coos Bay District.

Similarly, the southern DPS of Pacific eulachon (Thaleichthys pacificus) is limited to ocean and lower 

estuary use and the interaction with BLM-administered lands is very limited. Critical habitat for eulachon 

extends in to the lower Umpqua River and Tenmile Creek along the Oregon coast. Less than 0.1 percent 

of the critical habitat for each species is adjacent to BLM-administered lands (Table 3-42).

Because of the very limited distribution of the southern DPS of green sturgeon and the southern DPS of 

Pacific eulachon in the decision area, the BLM would have very limited ability to affect these fish through 

land management actions. There is no reasonable basis upon which the BLM could predict any difference 

in these potential effects among the action alternatives, the No Action alternative, or the Proposed RMP 

on the southern DPS of green sturgeon and the southern DPS of Pacific eulachon or their critical habitat. 

Any effects on the southern DPS of green sturgeon and the southern DPS of Pacific eulachon or their 

critical habitat would result from very limited site-specific implementation actions within or affecting the 

very limited distribution of the southern DPS of green sturgeon and the southern DPS of Pacific eulachon 

in the decision area. The BLM cannot forecast any such possible effects at this scale of analysis, and 

would address any such effects in project-specific analyses.

In addition to fish species listed under the Endangered Species Act, the BLM has designated Bureau 

Sensitive and Bureau Strategic fish species in the decision area. There are ten Bureau Sensitive fish 

species, evolutionarily significant units (ESUs), or distinct population segments (DPSs) within the 

decision area and one Bureau Strategic fish species. Appendix I lists these species, ESUs, or DPSs. 

Based on BLM Manual 6840, the BLM shall address Bureau Sensitive species and their habitats in land 

use plans and shall implement measures to conserve these species and their habitats, to promote their 

conservation, and reduce the likelihood and need for these species to be listed under the Endangered 

 

51 A distinct population segment (DPS) is a discrete population of a species and the smallest portion of a vertebrate 

species that can be protected under the Endangered Species Act.
280 | P a g e

Species Act. Bureau Strategic species are not special status for management purposes (IM-OR-2015-028). 

The only requirement for this group of species is that information for species sites located during any 

survey efforts shall be entered into the BLM corporate database. The BLM updates its Special Status 

Species list on a regular schedule, when state heritage programs publish new rankings or when other 

information indicates a need. The life history and habitat usage of these Bureau Sensitive and Bureau 

Strategic fish species are sufficiently similar to ESA-listed fish species to allow them to be analyzed 

together.

Pacific lamprey (Entosphenus tridentatus), though not an ESA-listed species, is a Bureau Sensitive

species and is an important fish for Tribes within the planning area. The Pacific lamprey was historically 

an abundant food source and played an important role in the daily lives of Tribal members. Though 

complete and accurate counts throughout the range do not exist, anecdotal information suggests the 

population of Pacific lamprey is declining across its range, from Washington to California (Luzier et al.

2009). In 2012, the BLM, along with other states, Federal agencies, and tribes, entered into a conservation 

agreement for Pacific lamprey with the U.S. Fish and Wildlife Service. The agreement identified 11 

regional management units, including the Coastal Oregon Regional Management Unit, which 

encompasses Pacific lamprey populations in the planning area. Pacific lamprey life history and habitat 

usage is sufficiently similar to ESA-listed fish species in the decision area to allow them to be analyzed 

together.

Columbia River chum salmon and Oregon chub, although occurring in the planning area, are not present 

in streams adjacent to BLM-administered lands, and thus have little to no potential to be affected by BLM 

management actions. Additionally, the U.S. Fish and Wildlife Service recently removed the Oregon chub 

from the list of threatened and endangered species because of improvements in the species’ status (80 FR 

9126).

Several other non-salmonid fish species occur in a relatively small percentage of streams on BLMadministered lands (Table 3-42). These populations, based on the very low interaction with BLMadministered lands, have very little potential to be affected by BLM management actions.

Although a wide variety of other anadromous and resident fish species occur within the planning area, 

they share similar life histories and habitat requirements. These fish species all spawn in rivers or streams, 

utilizing clean gravel substrates free of fine sediment, and juveniles spend at least a portion of their lives 

rearing in pool or off-channel habitat, created primarily by large wood and boulders. For this analysis, the 

habitat requirements are sufficiently similar to be analyzed together.

Under section 305(b) of the Magnuson-Stevens Fishery Conservation and Management Act, the BLM 

must analyze the effects to Essential Fish Habitat for coho and chinook salmon. Across the decision area, 

designated critical habitat for ESA-listed species encompasses the vast majority of designated Essential 

Fish Habitat, and, for the purposes of this analysis, effects on designated Essential Fish Habitat would be 

similar to the effects on designated critical habitat.

Large wood, stream temperature, sediment, and water flow have the greatest influence on aquatic habitat 

and the ability of aquatic habitat to support fish populations in the planning area. The abundance and 

survival of salmonids in the planning area is often closely linked to the abundance of large woody debris 

in stream channels. The Analysis of the Management Situation (USDI BLM 2013, pp. 32–36) and the

2008 FEIS (USDI BLM 2008, pp. 372–390) provide more detailed explanations of the influence of key 

ecological processes on fish habitat and fish populations, and those discussions are incorporated here by 

reference.
281 | P a g e

The BLM has implemented in-stream fish habitat restoration projects on about 230 miles of fish-bearing 

streams on BLM-administered lands and on adjacent private lands. This accounts for about 7 percent of 

fish-bearing streams in the decision area and about 1 percent of all fish-bearing streams in the planning 

area. The BLM has thinned 17,461 acres forest stands within the Riparian Reserve in the decision area 

since 1995. This accounts for approximately 2 percent of the 927,721 acres within the Riparian Reserve 

under the 1995 RMPs. The BLM has implemented much smaller acreages of other silvicultural treatments 

within the Riparian Reserve, including approximately 1,000 acres of hardwood conversion within the 

Riparian Reserve since 1995 (USDI BLM Annual Program Summaries 2005–2013). The BLM has 

removed or replaced 544 stream crossings within the planning area between 1995 and 2012 to allow 

passage for all life stages of fish at a range of flows (USDI BLM 2008, pp. 390–392; USDI BLM Annual 

Program Summaries 2005–2007; USDI BLM Aquatic Restoration Biological Opinion II Reporting 2008 

to 2012, unpublished). These include removal or replacement of stream crossings on BLM-administered 

lands or removal or replacement of stream crossings on adjacent private lands in which the BLM worked 

cooperatively with adjacent landowners and the removal or replacement benefited fish passage on BLMadministered lands.

Under all alternatives and the Proposed RMP, the BLM would continue to remove or replace fish barriers. 

The rate of removal or replacement would be contingent on funding levels and the ability of the BLM to 

work cooperatively with adjacent landowners; the BLM has no reasonable basis on which to forecast a 

difference in funding or opportunities for cooperative work with other landowners. Therefore, the BLM 

has no reasonable basis for forecasting any difference among the alternatives or Proposed RMP in the 

amount or rate of removal or replacement of fish barriers. Management direction in all alternatives and 

the Proposed RMP direct the BLM, when replacing barrier culverts, to install crossings that provide fish 

passage at a range of flows. For these reasons, the number of crossings and miles of fish habitat opened 

and the resultant effects on fish habitat would be similar among all alternatives and the Proposed RMP.

Since the adoption of the Northwest Forest Plan, there has been a robust debate about effective riparian 

management strategies for conservation and recovery of ESA-listed fish. Some reviews have argued that 

active management in riparian forests results in short-term adverse effects on fish habitat and water 

quality, and have proposed increased restrictions on active management within the Riparian Reserve to 

maximize stream shading and the total number of trees available for recruitment to streams (e.g., Frissell 

et al. 2014 and Pollock and Beechie 2014). Other reviews have argued that a reliance of passive 

restoration will compromise attainment of long-term ecological goals and have proposed more and varied 

active management approaches within the Riparian Reserve to create larger trees and more complex and 

diverse riparian forests (e.g., Reeves et al. in press).

Frissell et al. (2014) is an unpublished report to the Coast Range Association, which provides a collection 

of policy recommendations and critiques of administrative policies and legislative proposals. Some action 

alternatives are consistent with some of the recommendations in Frissell et al. (2014), such as the 

prohibiting commercial timber harvest within the Riparian Reserve, which is consistent with the design of 

Alternative A, and prohibiting livestock grazing in the Riparian Reserve, which is consistent with the 

design of Alternative D. However, the design of the action alternatives and the Proposed RMP are not 

consistent with some of the recommendations in Frissell et al. (2014), including expanding the size of the 

Riparian Reserve to protect stream temperature. These policy recommendations and critiques are reflected 

in the comments summarized in Appendix W, which include the BLM response to these 

recommendations. For those instances in which none of the alternatives or the Proposed RMP are 

consistent with these recommendations, Appendix W details the BLM’s explanation of why such 

recommendations are contrary to the purpose and need for the RMP revision or are not supported by the 

analysis. Although Frissell et al. (2014) presents numerous citations to existing scientific information 

(many of which are also cited in this section and in the Hydrology section of this chapter), it does not 

present any new scientific information.
282 | P a g e

Issue 1

How do the alternatives vary in the contribution of large and small functional wood to fish-bearing and 

non-fish-bearing streams?

Summary of Analytical Methods

In this analysis, the BLM evaluated the effects of the alternatives and the Proposed RMP on the potential 

contribution of large and small functional wood to fish-bearing and non-fish-bearing streams at the 

watershed scale (Hydrologic Unit Code (HUC) 10).52 The BLM conducted this analysis at the watershed 

scale, because at finer scales (e.g., individual stream reaches), the BLM would not be able to interpret 

how changes in the amount of wood available for delivery to streams would affect fish habitat or 

populations. Wood delivery to individual stream reaches is highly variable, episodic, and unpredictable. 

Additionally, anadromous fish travel through multiple watersheds along their migrations, and the effects 

on spawning or rearing habitat would only be discernible once fish reach streams suitable in size for 

spawning or rearing. This generally occurs in streams at the HUC 10 watershed scale.

The BLM analyzed the potential contribution of wood to streams over time, but did not attempt to model 

actual wood delivery to streams over time under each alternative and the Proposed RMP. Wood delivery 

to streams is influenced by myriad factors, including riparian stand conditions, individual tree processes, 

disturbance events, and geomorphic processes. Many of these influential factors are inherently 

unpredictable, and several would not be affected by the alternatives or the Proposed RMP. Instead, this 

analysis, like the 2008 FEIS, evaluated the potential contribution of wood to streams by assessing the 

condition of forest stands that could potentially deliver wood to streams. The alternatives and the 

Proposed RMP would directly and substantially affect the condition of these forest stands, and the BLM 

can more accurately forecast changes to forest stand condition than wood delivery to streams under the 

alternatives and the Proposed RMP.

The BLM analyzed the potential contribution of wood to streams over 100 years to provide a meaningful 

comparison of the effects of the alternatives and the Proposed RMP on fish habitat. Wood loading in 

streams is highly variable, and wood delivery is only one component. Breakdown of wood, large floods, 

and debris flows can alter the amount or effectiveness of large wood in the stream, and these processes 

can take place over large spatial scales. Therefore, analyzing the potential contribution of wood to streams 

over a shorter time period would not accurately compare the effects of alternatives and the Proposed RMP 

in their ability to affect in-stream fish habitat through wood delivery. The effects of land management to 

the landscape could take up to 100 years to show any discernable change in the amount or quality of fish 

habitat created by large or small functional wood.

The ability to analyze the effects of the alternatives and the Proposed RMP on potential wood delivery to 

streams is limited by several factors, including the data available at this scale of analysis on both stream 

reach and riparian stand conditions, uncertainties about the extent, location, and timing of riparian stand 

thinning under each alternative and the Proposed RMP, and the indirect connection between riparian 

stand conditions and wood amounts in streams. For example, data available at this scale of analysis is not 

sufficiently site-specific and detailed to evaluate whether the trees in a specific riparian stand are of 

sufficient size to provide stable instream habitat structure in the specific adjacent stream reach. Instead, 

the BLM must make generalizations and assumptions, to describe current riparian stand conditions, future 

riparian stand conditions, and stream conditions. In addition, riparian stand thinning under each 

 

52 Hydrologic Unit Codes (HUCs) are a U.S. Geological Survey classification based on a hierarchy of nested 

watersheds.
283 | P a g e

alternative and the Proposed RMP would affect riparian stand conditions and consequently the wood 

available for delivery to streams. However, forecasting the extent, specific location, and timing of riparian 

stand thinning required the BLM to make assumptions about a plausible scenario for implementation 

under each alternative and the Proposed RMP, adding uncertainty to the effects in any specific location. 

Finally, the analysis addressed the riparian stand conditions, which identified the wood available for 

delivery to streams, but actual delivery of wood to streams and consequently, the habitat structure in 

streams, depends on many factors in addition to riparian stand condition, including stochastic processes, 

which adds an additional layer of uncertainty to the effects in any specific location.

In this analysis, the BLM assumed that the analytical results in the 2008 FEIS for potential wood 

contribution provide an approximation of the effects of the alternatives in this analysis. The 2008 FEIS 

utilized a spatially explicit GIS model to estimate large and small wood delivery to BLM-administered 

and non-BLM-administered streams for all HUC 10 watersheds within the planning area. The 2008 FEIS 

analyzed potential large wood and small functional wood contribution to streams considering the effects 

of forest management and stand growth over time in portions of the landscape capable of delivering wood

to streams. That analysis is incorporated here by reference (USDI BLM 2008, pp. 779–797). The Riparian 

Reserve land use allocation designs and management direction relevant to potential wood contribution for 

Alternatives B and C in this analysis are roughly comparable to the Riparian Management Area design 

and management direction in the 2008 Proposed RMP. The Riparian Reserve land use allocation designs 

and management direction for Alternatives A and D and the Proposed RMP are intermediate between the 

No Action alternative and the 2008 Proposed RMP. Thus, the analytical results from the 2008 FEIS for 

the potential wood contribution of the No Action alternative and the 2008 Proposed RMP bracket the 

effects that would occur under the alternatives and the Proposed RMP in this analysis.

In this analysis, the BLM evaluated the structural stage condition and several forest stand metrics within 

one site-potential tree height distance of streams. The BLM used one site-potential tree height distance of 

streams to approximate the area likely to deliver wood to streams. The BLM evaluated four stand metrics:

 The density of large trees (greater than 20” diameter breast height (DBH))

 The percentage of forest stand canopy cover in hardwoods (e.g., red alder and big leaf maple)

 The quadratic mean diameter (QMD) of trees (a weighted average of the size of trees in the 

stand)

 The number of trees per acre

These metrics provide a broad measure of the potential for forest stands to provide large wood and small 

functional wood to streams. The BLM used the results of these simpler analyses to validate the 

assumption that the results from the more complex analysis in the 2008 FEIS for potential wood 

contribution provides a reasonable approximation of the effects of the alternatives and the Proposed RMP 

in this analysis.

Background

Woody debris is an important channel-forming component in forested streams in the Pacific Northwest. 

Wood traps and stores gravel, generates scour that creates pool habitat, provides overhead cover, and 

protects banks by reducing stream energy. In headwater streams, small wood can retain fine sediment and 

prevent downstream transport to fish-bearing reaches. Conifer species persist the longest in stream 

channels. However, hardwood trees, such as red alder and big leaf maple, provide wood, as well as leaf 

litter, that serve as a nutrient base for macroinvertebrates, which in turn provide food for anadromous fish.

The size of wood that can provide stable structure and induce habitat change in a stream (i.e., functional 

wood) varies by channel width. Generally, wider streams require larger pieces of wood (Beechie et al.
284 | P a g e

2000, Table 3-43). Smaller pieces of wood can also be functional if the stream channel is narrow or if the 

smaller wood interacts with larger, stable debris jams. Some small instream wood that is not entrained in 

a debris jam is flushed from the system during high flows. The remaining large pieces of instream wood 

are depleted at an average rate of 1.5 percent per year (Murphy and Koski 1989). For most streams in the 

planning area, a 20” DBH tree can provide functional wood in the stream.

Table 3-43. Diameter of functional wood piece as it relates to width of active stream channel.

Width of

Stream Channel

(Feet)

Diameter of

Functional Wood

(Inches)

15 4.5

20 6.0

30 9.0

40 12.0

50 15.0

> 50 > 20.0

Trees closer to the stream have a higher probability of falling into the stream. Wood is delivered to stream 

channels generally from distances less than one site-potential tree height53 in width from the edge of the 

active channel (Reeves et al. in press). Beyond a distance of one site-potential tree height from the stream, 

contribution of wood in the form of whole trees is rare and results from episodic debris flows and slope 

failures. These debris flows result from oversaturation of soils or unstable underlying geology, where 

large wood along with small wood, boulders, and other substrates can be delivered over longer distances. 

The 2008 FEIS analyzed land management alternatives using a wood model that accounted for the 

delivery of wood in the form of whole trees from a variety of sources (USDI BLM 2008, pp. 779–799). 

That analysis identified three primary sources of instream large wood: riparian tree fall, channel 

migration, and debris flows (USDI BLM 2008, pp. 376–384, 781–797).

In 2013, the Interagency Regional Executive Team released a series of technical summaries by a Science 

Review Team on the issue of the effects of riparian thinning and those analyses and findings are 

incorporated here by reference (Spies et al. 2013). The Science Review Team’s findings are a compilation 

of empirical data, relevant studies, and recently modeled wood input. The Science Review Team found 

that up to 95 percent of instream wood comes from distances ranging from 82 to 148 feet from the edge of 

the stream bank (i.e., generally less than one site-potential tree height). The primary near-stream inputs of 

large wood are from tree mortality and bank erosion, along with landslides and debris flows.

Headwater streams that are prone to debris flow delivery can contribute a large proportion of in-stream 

wood downstream in fish-bearing stream reaches (Benda et al. 2003, Reeves et al. in press). In these 

streams, debris flows will capture wood and sediment from the debris flow area and deliver it to streams. 

May and Gresswell (2004) estimated debris flow recur at an interval of up to 357 years for headwater 

basins in the Oregon Coast Range.

Riparian tree mortality and subsequent recruitment to streams can represent the primary contribution of 

large wood in low-gradient meandering streams, while upslope and debris flow contributions can be 

greatest in higher gradient streams (Reeves et al. 2003, Bigelow 2007).

 

53 Site-potential tree-heights generally range from 140 feet to 240 feet across the decision area, depending on site 

productivity.
285 | P a g e

During the last century, many streams were ‘cleaned’ of large wood to make the downstream transport of 

harvested logs more efficient. Without large wood to retain gravel and other woody material, many 

streams were scoured to bedrock and have correspondingly poor habitat for fish. Active restoration to 

offset the loss of habitat has involved the placement of logs and whole trees in addition to boulders into 

these bedrock channels. These restorative efforts persist for several decades as riparian stands develop 

that are capable of supplying long-term sources of wood to streams.

Past timber harvest of riparian stands has resulted in the replacement of structurally-complex stands (with 

large diameter trees) to young stands (with small diameter trees). These young riparian stands have a 

preponderance of smaller diameter trees resulting from high tree densities and competition, limiting the 

ability of these riparian stands to provide functional wood to streams. These young riparian stands are 

developing at higher densities than the stand conditions under which the existing structurally-complex 

stands developed (Tappeiner et al. 1997, Poage and Tappeiner 2002). The 2008 FEIS described the 

effects of past harvest on forest stands across the landscape and riparian forest stands specifically (USDI 

BLM 2008, pp. 202–212, 375–376), and those discussions are incorporated here by reference.

Monitoring results conclude that the ecological condition of approximately two-thirds of the watersheds 

in the Northwest Forest Plan area have improved in condition in the past two decades. One of the primary 

factors responsible for this improvement has been the increase in the number of large trees (greater than 

20” DBH) within the Riparian Reserve (Reeves et al. 2006, Lanigan et al. 2012, Miller et al. 2015, 

Reeves et al. in press). 

Affected Environment and Environmental Consequences

Currently, riparian stands that are within one site-potential tree height of streams average about 316 trees 

per acre, of which 19 trees per acre are greater than 20” DBH (Figure 3-42). Conifers in riparian stands 

have an average diameter of 8” quadratic mean diameter (QMD). Hardwood trees provide approximately 

20 percent of riparian canopy cover. In general, current riparian stand conditions are denser, with smaller 

diameter trees, than riparian stands historically.
286 | P a g e

Figure 3-42. Stand conditions within one site-potential tree height for the current condition, the No 

Action alternative in 2113, and the No Timber Harvest reference analysis in 2113

Stands within one site-potential tree height currently have a relatively even distribution of structural 

stages with early successional having the least (Table 3-44, Figure 3-43). Over the next 100 years, the 

No Action alternative and the No Timber Harvest reference analysis would have a very similar 

distribution of Young, Mature, and Structurally-Complex stand types, because all stands within one sitepotential tree height of streams would be within the Riparian Reserve under the No Action alternative and 

the BLM would not implement any regeneration harvest which would create new early successional 

stands.

19.0 20.0 21.6

316.0

36.3

15.0

29.9

130.0

39.5

15.4

30.3

121.9

0

50

100

150

200

250

300

350

Average Trees Per

Acre > 20" DBH

Hardwood Canopy

Cover (Percent)

QMD Conifers

(Inches)

Trees Per Acre

Value

Stand Conditions

Current Condition No Action in 2113 No Timber Harvest in 2113
287 | P a g e

Table 3-44. Acres in each structural stage for stands within one site-potential tree height from all streams 

for the current condition and in 2113

Alternative/

Proposed RMP

Early 

Successional 

(Acres)

Stand 

Establishment 

(Acres)

Young

(Acres)

Mature 

(Acres)

Structurallycomplex 

(Acres)

Current Condition 11,973 139,839 231,555 180,366 208,640

No Action 2 988 39,508 340,841 391,034

Alt. A - 988 38,807 332,580 399,998

Alt. B 20,800 988 61,785 314,877 373,923

Alt. C 32,570 36,353 74,360 291,095 337,996

Alt. D - 988 38,420 333,200 399,765

PRMP 1,206 2,148 40,506 335,475 393,038

No Timber Harvest - - 39,354 332,784 400,620
288 | P a g e

Figure 3-43. Relative proportion of structural stage acres under the current condition, the alternatives, the 

Proposed RMP, and the No Timber Harvest reference analysis in 2113 for stands within one site-potential 

tree height from all streams

27%

51% 52%

48%

44%

52% 51% 52%

23%

44% 43%

41%

38%

43% 43% 43%

30%

5% 5%

8%

10%

5% 5% 5%

18%

5%

2% 3% 4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Current

Condition

2013

No Action

2113

Alt. A

2113

Alt. B

2113

Alt. C

2113

Alt. D

2113

PRMP

2113

No

Timber

Harvest

2113

Structural Stage Acres Within 1 SPTH of Streams (Percent)

Structurally-complex Mature Young Stand Establishment Early Successional
289 | P a g e

All alternatives and the Proposed RMP would increase the potential large wood and small functional 

wood contribution to streams from the current conditions. There is no meaningful difference discernible 

at this scale of analysis among the alternatives and the Proposed RMP in their effect on overall potential 

wood contribution. The BLM based this conclusion on the analytical results in the 2008 FEIS for 

potential wood contribution, which provide an approximation of the effects of the alternatives in this 

analysis, as discussed above under analytical methods, and that analysis is incorporated here by reference 

(USDI BLM 2008, pp. 779–797). The 2008 FEIS found that the No Action alternative and 2008 Proposed 

RMP would have nearly identical effects on potential large wood and small functional wood contribution, 

and that the potential wood contribution would be only slightly lower than the No Timber Harvest 

reference analysis. Specifically, that analysis found that potential large wood contribution would increase 

from the current 5.4 pieces/mile/year to 8.0 pieces/mile/year under both the No Action alternative and the 

2008 Proposed RMP and to 8.3 pieces/mile/year under the No Timber Harvest reference analysis in 100 

years. Because the analytical results from the 2008 FEIS for the No Action alternative and the 2008 

Proposed RMP bracket the effects that would occur under the alternatives and the Proposed RMP in this 

analysis, and the No Action alternative and 2008 Proposed RMP had indistinguishable effects on potential 

wood contribution, the alternatives and the Proposed RMP in this analysis would all have the same effects 

on overall potential wood contribution as those identified in the 2008 FEIS for the No Action alternative 

and 2008 Proposed RMP.

The relative proportion of structural stages within one site-potential tree height would be similar over 

time across all alternatives and the Proposed RMP (Figure 3-43, Table 3-44). The similar proportion of 

structural stages over time under all alternatives and the Proposed RMP is consistent with the analytical 

conclusion that the overall potential wood contribution from the alternatives would be similar. Under 

Alternatives B and C, a higher proportion of those stands within one site-potential tree height would be 

Early Successional and Stand Establishment. Alternative C has the least acres in the Mature and 

structurally-complex stand types (i.e., those stands with the most capability to grow and deliver large 

wood to streams).

All alternatives and the Proposed RMP would increase the number of trees per acre greater than 20 inches 

DBH near streams from the current condition (Figure 3-44). Alternatives A and D would result in a 

similar increase in the number of large trees near streams, slightly greater than the other alternatives, and 

only very slightly less than the No Timber Harvest reference analysis. The No Action alternative and 

Alternatives B and C would result in a smaller increase in the number of large trees near streams. In 20 

years, the No Action alternative would result in the least increase in the number of large trees near 

streams, barely above current levels. In 100 years, Alternative C would result in the least increase in the 

number of large trees near streams (Figure 3-45).
290 | P a g e

Figure 3-44. Trees per acre greater than 20” DBH within one site-potential tree height over time for all 

alternatives, the Proposed RMP, and the No Timber Harvest reference analysis

Figure 3-45. Trees per acre greater than 20” DBH for stands within one site-potential tree height of 

streams for the current condition in 2013, and the alternatives, the Proposed RMP, and the No Timber 

Harvest reference analysis in 2113

The Proposed RMP would increase the number of trees per acre greater than 20” DBH near streams more 

than the No Action alternative, Alternatives B and C, but slightly less than Alternatives A and D. As 

explained in the introduction to Chapter 3, the BLM updated baseline forest age and structural conditions 

resulting from 2013/2014 wildfires for the analysis of the Proposed RMP, which has resulted in changes 

to affected environment descriptions throughout this document, when compared to the Draft RMP/EIS. 

0

5

10

15

20

25

30

35

40

2013 2023 2033 2113

Trees Per Acre > 20" DBH

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

19.0

36.3

39.2

34.9

31.5

39.4

37.0

39.5

0

5

10

15

20

25

30

35

40

45

Year 2113

Trees Per Acre > 20" DBH

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Year 2013
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Because of this updating of the baseline conditions, there is currently a slightly lower (5 percent) current 

average number of large trees near streams for the Proposed RMP than was analyzed for the action 

alternatives and No Action alternative. Therefore, this analysis may slightly underestimate the number of 

large trees near streams for the Proposed RMP compared to the results to the No Action alternative or the 

action alternatives. Given the very small relative differences among the alternatives and the Proposed 

RMP, this slight difference in starting conditions could result in a slight underestimate of the number of 

large trees near streams for the Proposed RMP throughout the analytical time period. Because of 

similarities in design, the Proposed RMP would have essentially identical effects as Alternatives A and D 

on the number of trees per acre greater than 20” DBH near streams in Class I and Class II subwatersheds 

(which constitute approximately 91 percent of the decision area excluding the east side of the Klamath 

Falls Field Office). In Class III subwatersheds, the Proposed RMP would have effects on the number of 

trees per acre greater than 20” DBH near streams intermediate between Alternatives A and D, and 

Alternatives B and C. Thus, while the number of large trees per acre near streams averaged across the

decision area would be slightly lower under the Proposed RMP than under Alternatives A and D, it would 

actually only be lower in a small number of watersheds (< 10 percent of the decision area). In summary, 

the results shown in Figure 3-45 display the relative outcomes for large trees near streams over time, but 

likely overstate the absolute magnitude of the difference in outcomes between Alternatives A and D and 

the Proposed RMP.

All alternatives and the Proposed RMP would result in a similar decrease in the percentage of canopy 

cover in hardwoods (Figure 3-46).

Figure 3-46. Percent hardwood canopy cover for stands within one site-potential tree height of streams 

for the current conditions in 2013 and in 2113

All alternatives and the Proposed RMP would increase the average diameter of trees in stands within one 

site-potential tree height of streams (Figure 3-47); that increase would be similar under the No Action 

alternative, and Alternatives A and D, and would be only very slightly less than the increase under the No 

Timber Harvest reference analysis. Alternative C and Alternative B would result in a smaller increase in 

the average diameter of trees in stands within one site-potential tree height of streams, reflecting the 

20.0

15.1 15.4

14.1

12.8

15.5 16.0 15.5

0

5

10

15

20

25

Year 2113

Hardwood Canopy Cover (Percent)

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Year 2013
292 | P a g e

influence of timber harvest in portions of the Harvest Land Base that are outside of the Riparian Reserve 

along non-fish-bearing intermittent streams, but within one site-potential tree height of streams. As 

explained above for the number of large trees near streams, the results shown in Figure 3-47 display the 

relative outcomes for the average diameter of trees near streams over time, but likely overstate the 

absolute magnitude of the difference in outcomes between Alternatives A and D and the Proposed RMP.

Figure 3-47. Quadratic mean diameter (QMD) of conifers for stands within one site-potential tree height 

of streams for the current condition in 2013, and in 2113

The trees per acre within one site-potential tree height of streams would decrease substantially from 

current conditions under all alternatives and the Proposed RMP (Figure 3-48); that decrease would be 

similar under Alternatives A and D and the Proposed RMP, and would be only very slightly less than the 

decrease under the No Timber Harvest reference analysis. The No Action alternative and Alternatives B 

and C would result in slightly less decrease in the density of trees in stands within one site-potential tree 

height of streams. As explained above for the number of large trees near streams, the results shown in 

Figure 3-48 display the relative outcomes for total trees per acre near streams over time, but likely 

overstate the absolute magnitude of the difference in outcomes between Alternatives A and D and the 

Proposed RMP.

22.0

29.9 30.2

23.2

27.1

30.3 29.0

30.3

0

5

10

15

20

25

30

35

Year 2113

QMD Conifers (Inches)

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Year 2013
293 | P a g e

Figure 3-48. Total trees per acre for stands within one site-potential tree height of streams for the current 

condition in 2013, and in 2113

The similar trends for these stand metrics within one site-potential tree height of streams over time under 

all alternatives and the Proposed RMP is generally consistent with the analytical conclusion that the 

overall potential wood contribution from the alternatives would be similar. However, these stand metrics 

reveals some specific differences among the alternatives and the Proposed RMP in the potential to 

provide wood to streams.

There are differences in the design of the alternatives that may have differential effects on potential wood 

contribution that the BLM cannot quantitatively evaluate at this scale of analysis. Notably, the alternatives 

differ in Riparian Reserve widths, inner zone widths, and management direction for Riparian Reserve 

thinning.

Riparian Reserve Width

The No Action alternative has wider Riparian Reserve widths on fish-bearing streams than all action 

alternatives or the Proposed RMP. The No Action alternative and Alternatives A and D have wider 

Riparian Reserve widths on non-fish-bearing intermittent streams than Alternatives B and C. As a result, 

the No Action alternative and Alternatives A and D would include within the Riparian Reserve the largest 

proportion of the landscape capable of delivering wood to the stream. Alternative B would explicitly 

provide debris-flow-prone non-fish-bearing intermittent streams with a wider Riparian Reserve than other 

non-fish-bearing intermittent streams. The Riparian Reserve on these debris-flow-prone streams under 

Alternative B would be narrower than the Riparian Reserve under the No Action alternative and 

Alternatives A and D, but wider than under Alternative C. Under the Proposed RMP, Riparian Reserve 

widths in Class I and II watersheds would be the same as Alternatives A and D. In Class III 

subwatersheds under the Proposed RMP, the Riparian Reserve would be the same width on fish-bearing 

streams and perennial streams as Alternatives A, B, and D, but the same width on non-fish-bearing 

intermittent streams as Alternative C. In the various metrics shown above, these differences among the 

alternatives and the Proposed RMP in Riparian Reserve widths, results in only modest differences in 

316.0

130.8

123.4 128.7

134.3

122.5 125.0 122.8

0

50

100

150

200

250

300

350

Year 2113

Total Trees Per Acre

Current Condition No Action Alt. A Alt. B Alt. C Alt. D PRMP No Timber Harvest

Year 2013
294 | P a g e

potential wood contribution. It is possible that there would be circumstances in which there could be 

differences in wood delivery to streams not revealed by this analysis. For example:

 Substantial channel migration could move the stream closer to harvested stands outside of the 

Riparian Reserve. Under the action alternatives, which would measure the width of the 

Riparian Reserve from the edge of the active stream channel, this could reduce the potential 

wood contribution to the stream. This could however be offset in the short term by additional 

large wood recruited from channel migration. The Proposed RMP would measure the width of 

the Riparian Reserve from the ordinary high water line, including the channel migration zone 

for low gradient alluvial shifting channels, which would effectively widen the Riparian Reserve 

width on streams that would likely experience substantial channel migration compared to the 

action alternatives. This difference would reduce or eliminate the likelihood that substantial 

channel migration could move the stream closer to harvested stands outside of the Riparian 

Reserve under the Proposed RMP compared to the action alternatives.

 Tree fall on extremely steep slopes could result in delivery of wood to non-fish-bearing 

intermittent streams from beyond 50 feet from the stream. Under Alternatives B and C and in 

Class III subwatersheds under the Proposed RMP, this could result in fewer trees and smaller 

diameter wood delivered to some streams if the upslope area includes recently harvested stands 

outside the Riparian Reserve.

 Debris flows could exceed 100 feet in width. Under Alternative C and in Class III 

subwatersheds under the Proposed RMP, this could result in fewer trees and smaller diameter 

wood delivered to streams if the debris flow area along non-fish-bearing intermittent streams 

includes recently harvested stands outside the Riparian Reserve.

These examples represent exceptional or low-probability circumstances. Furthermore, actual wood 

loading on streams results from multiple factors and wood delivery from multiple sources, further 

lowering the probability that any of these exceptional circumstances would result in any discernible 

difference in actual wood loading in streams at the watershed scale.

Inner Zone Widths

All action alternatives and the Proposed RMP delineate an inner zone near streams in which stand 

thinning would not occur. Alternatives B and C generally delineate a smaller inner zone than Alternatives 

A and D and the Proposed RMP. The No Action alternative does not specify any such inner zone. The 

vegetation modeling of the No Action alternative in this analysis did make assumptions based on recent 

projects that Riparian Reserve stand thinning would not occur near streams. However, such assumptions 

about thinning under the No Action alternative are more uncertain than under the action alternatives or the 

Proposed RMP, given the absence of specific management direction for an inner zone under the No 

Action alternative. Over time, the wider inner zone along perennial and fish-bearing streams under 

Alternatives A and D and the Proposed RMP could result in some stands that are capable of delivering 

wood to streams developing without thinning and thus providing smaller wood available for delivery to 

streams. Alternatively, the narrower inner zone under Alternatives B and C could result in some stands 

that are capable of delivering wood to streams being thinned and having fewer trees available for delivery 

to streams. Identifying any such differences in the influence of differing inner zone widths on potential 

wood contribution would require stand-specific and stream-specific data coupled with modeling of a 

specific thinning prescription, which is not possible at this scale of analysis. Nevertheless, using the 

generalized stand and stream data available, and the modeling assumptions about the extent, location, and 

prescriptions for thinning, this analysis identified only modest differences in the effect of differing inner 

zone widths on potential wood contribution to streams.
295 | P a g e

Management Direction for Riparian Reserve Thinning

The No Action alternative would include thinning for a variety of broad-based ecological purposes, 

including the nine Aquatic Conservation Strategy objectives. Alternatives B and C and the Proposed RMP

in Class II and III watersheds would direct thinning in the outer zone for a differing but comparable set of 

purposes, including increasing the diversity of riparian species and developing structurally-complex 

stands. Alternatives B and C, and the Proposed RMP direct that a portion of the trees in stand thinning in 

the outer zone would be directionally felled to the stream. The Proposed RMP would specifically require 

a portion of the stand from the inner zone to be felled toward the stream or require a portion of the stand 

in the outer zone to be made available for instream restoration in order to meet the tree tipping 

management direction. This would result in more large wood actively being placed in the stream to 

benefit fish habitat under the Proposed RMP than under the alternatives. Alternatives A and D and the 

Proposed RMP in Class I subwatersheds would direct thinning in the outer zone as needed for the purpose 

of ensuring that stands are able to provide stable wood to the stream. Alternative A would generally limit 

this thinning to non-commercial treatments (i.e., all cut trees would be left in the stand), except in the dry 

forest, where thinning would also occur as needed for fuels treatments. As with inner zone widths, the 

management direction under Alternatives A and D, and the Proposed RMP in Class I subwatersheds 

could result in some stands that are capable of delivering wood to streams developing without thinning 

and thus providing smaller wood available for delivery to streams. On the other hand, over time, the 

management direction under the No Action alternative, Alternatives B and C, and the Proposed RMP in 

Class II and III watersheds could result in some stands that are capable of delivering wood to streams 

being thinned and having fewer trees available for delivery to streams. As with inner zone widths, 

identifying any such differences in the influence of differing management direction for riparian thinning 

on potential wood contribution would require stand-specific and stream-specific data coupled with 

modeling of a specific thinning prescription, which is not possible at this scale of analysis. Nevertheless, 

using the generalized stand and stream data available, and the modeling assumptions about the extent, 

location, and prescriptions for thinning, this analysis identified only modest differences in the effect of 

differing management direction for thinning on potential wood contribution to streams.

Based on the condition of forest stands in the Riparian Reserve and the management direction in the 

alternatives, there is a limited acreage of Riparian Reserve stands in the decision area that would be 

thinned over the next five decades under all alternatives and the Proposed RMP (Figure 3-49 and Table 

3-45). The acreages in Figure 3-49 and Table 3-45 represent forecasts from the Vegetation Modeling 

based on modeling assumptions related to the availability of acres suitable for thinning in light of the 

management direction for each alternative and the Proposed RMP (see Appendix C). Because Riparian 

Reserve thinning under all alternatives and the Proposed RMP would be conducted only for specific stand 

management purposes and the need for such thinning would depend on stand-specific conditions, these 

forecasts of the amount and rate of Riparian Reserve thinning are highly approximate. In any decade, the 

No Action alternative would thin the most Riparian Reserve acres than any action alternative or the 

Proposed RMP. Alternative D would thin the fewest Riparian Reserve acres. The Proposed RMP would 

thin an intermediate number of acres of the Riparian Reserve per decade when compared to the No Action 

alternative and action alternatives.

All alternatives and the Proposed RMP would thin less than 4.2 percent of the Riparian Reserve in any 

one decade, and the Proposed RMP would thin less than 1.3 percent of the Riparian Reserve in any 

decade. In total, the Proposed RMP would thin 5.3 percent of the Riparian Reserve over a period of five 

decades. This very small amount of acres treated under all alternatives and the Proposed RMP supports 

the analytical conclusion that there would be only modest differences in the effect of differing 

management direction for thinning on potential wood contribution to streams.
296 | P a g e

Figure 3-49. Thinning within the Riparian Reserve by decade

Note: Alternative A and the Proposed RMP include non-commercial and habitat enhancement thinning acres

Table 3-45. Thinning within the Riparian Reserve by decade

Decade No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

2023 31,407 7,219 15,958 7,146 3,655 10,561

2033 29,137 6,731 14,933 6,630 3,405 10,036

2043 24,773 6,017 13,132 5,644 2,961 9,060

2053 19,578 4,944 10,816 4,497 2,424 7,543

2063 12,959 3,289 7,455 2,915 1,542 5,434

The tiered subwatershed approach in the Proposed RMP would result in more protection of Riparian 

Reserve adjacent to critical habitat and streams with high intrinsic potential. Management direction under 

the Proposed RMP for tree tipping from inner zones and making available logs or trees for restoration 

from the outer zone would result in a direct contribution of large wood to streams, in addition to the longterm protection afforded by retention of the no-harvest inner zone.

In summary, the analysis demonstrates only modest differences among the alternatives and the Proposed 

RMP in the potential wood delivery to streams over time. To the extent that this analysis is able to predict 

accurately the potential wood contribution, all alternatives and the Proposed RMP would increase the 

large wood and small functional wood contribution to streams over time. Increases in wood delivery to 

streams would improve fish habitat by creating deep pools, providing cover, and capturing sediment that 

provides spawning habitat. Such improvements in habitat would improve fish survival and production 

and, over time, would contribute to increases in fish populations. The 2008 FEIS described the effects of 

increasing wood delivery to streams on fish (USDI BLM 2008, pp. 372–374), and that discussion is

incorporated here by reference. This analytical conclusion that all alternatives and the Proposed RMP 

would increase the large wood and small functional wood contribution to streams over time is based on 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Riparian Reserve Thinned (Acres)

2023 2033 2043 2053 2063
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high-quality information using robust analytical methodology and provides an accurate, albeit 

generalized, description of the effects of the alternatives and the Proposed RMP across the decision area 

and a sound basis for comparing the alternatives and the Proposed RMP. However, because of the 

limitations on available data and analytical methodologies and the uncertainties described above, there 

may be more substantial differences among the alternatives and the Proposed RMP on wood delivery to 

streams than is apparent in this analysis in some locations and under some circumstances. Such 

circumstances are exceptional or not conducive to analysis at this scale with the data available. Where 

such circumstances would be relevant, the BLM would address these site-specific effects on potential 

wood delivery more fully in the analysis for specific implementation actions.

Issue 2

How would delivery of sediment to fish-bearing and non-fish-bearing streams affect fish under the 

alternatives?

Summary of Analytical Methods

The delivery of sediment to fish-bearing and non-fish-bearing streams is presented in the Hydrology 

section. That analysis describes the amount of new road construction and use within a 200-foot delivery 

distance to streams to estimate the contribution of fine sediment to stream channels.

In this analysis, the BLM assumed that increases in fine sediment less than 1 percent would not result in 

measurable or meaningful effects on fish survival and that every 1 percent increase in fine sediment from 

management activities would result in a 3.4 percent decrease in fish survival. The 2008 FEIS summarized 

the effects of sediment on fish and aquatic habitat and that summary is incorporated here by reference 

(USDI BLM 2008, pp. 385–388, 799–800). Thresholds for lethal and sub-lethal effects on fish from 

increases in sediment delivery have not been well established at the scale of this analysis. Cederholm 

(1981) concluded that there was a 2 percent decrease of egg to emergence survival of salmonids for each 

1 percent increase in fine sediment over natural levels at the watershed scale. Suttle et al. (2004) suggest 

there is no threshold below which fine sediment is harmless to fish, and the deposition of fine sediment in 

the stream channel (even at low concentrations) can decrease the growth of salmonids. Such sub-lethal 

effects on individual fish would occur under every alternative and the Proposed RMP from timber harvest 

activities, broadcast burning, grazing, culvert replacements, and other management activities, but it is not 

possible to describe quantitative changes in sub-lethal effects under the alternatives and the Proposed 

RMP over time at this scale of analysis. Therefore, this analysis focuses on the sediment levels that would 

measurably affect fish survival.

Background

Sediment occurs naturally in stream systems and can affect fish directly by increasing turbidity and 

inhibiting foraging and breathing functions, or indirectly by embedding in stream substrates, thereby 

reducing macroinvertebrate productivity, or smothering eggs and fry. Fine sediment in streams can affect 

fish habitat by filling interstitial spaces in gravel substrate, reducing oxygen flow to incubating eggs, and

by physically preventing newly hatched fish from emerging. In suspension, fine sediment reduces 

visibility, reduces foraging ability, and impairs oxygen uptake in gill membranes (Waters 1995).

Affected Environment

In 2009, the Oregon Department of Environmental Quality published an assessment of water quality 

indicators for forested lands in Western Oregon (ODEQ 2009). The ODEQ modeled sediment using the 
298 | P a g e

PREDATOR model, which uses known preferences and tolerances of aquatic macroinvertebrates to 

predict stream sediment and other water quality indicators. The model showed that over two-thirds of 

sites on all Federal lands had less than 10 percent fines, which would be considered ideal for salmonids. 

Federal lands had the highest percentage of sites in excellent water quality condition, higher than either 

State or private forestlands (ODEQ 2009).

The ODEQ report summarized conditions by ownership and grouped BLM-administered lands and Forest 

Service lands into a single category of Federal lands; therefore, conditions may not precisely reflect 

BLM-administered lands independently. The Willamette region has the highest percent of sites in 

excellent condition (less than 10 percent fines) with 92 percent, followed by the South Coast with 81 

percent, and the North Coast with 69 percent. Although the ODEQ report did not break down the Lower 

Columbia region by ownership, 81 percent of sites in that region are in excellent condition across all 

ownerships (ODEQ 2009).

In 2015, the Aquatic and Riparian Effectiveness Monitoring Program, a joint monitoring program of the 

BLM and Forest Service, released their 20-year monitoring summary, and the analysis and findings 

contained are incorporated here by reference (Miller et al. 2015). That monitoring summary evaluated 

habitat on Federal lands and found that a majority of watersheds showed an increase in Watershed 

Condition Scores. In-channel substrate showed an overall positive score indicating that conditions are not 

only improving but also are trending toward more historical conditions. Substrate scores take into account 

percent fine sediment, median substrate size, and presence of macroinvertebrates.

Environmental Consequences

Under each of the action alternatives and the Proposed RMP, the estimated amount of additional sediment

delivered to streams channels from roads in the first decade would be less than a 1 percent increase from 

the current amounts (see the Hydrology section in this chapter). At this level, there would be no 

detectable effect to fish or stream channels from additional sediment. At the site scale, small 

accumulations of fine sediment could begin to fill pool-tails, or these fines could become embedded in 

gravel substrates used for spawning. These sediments would be flushed during subsequent high flows and 

dispersed downstream, where no discernable effect would be detected. Under all alternatives and the 

Proposed RMP, the increase in fine sediment delivery to streams would not increase more than 1 percent 

above the current conditions, and would therefore be below the threshold for measurable effects on fish 

survival at this scale of analysis.

As sediments are flushed from road surfaces, there could be some short-term increases (i.e., lasting 

several hours) in stream turbidity that would be dispersed within tens to hundreds of feet downstream 

from the source depending on flow, channel gradient, channel complexity including the amount of woody 

debris, and other factors (Duncan et al. 1987, Gomi et al. 2005). This would result in a short-term and 

localized effect to fish that would elicit non-lethal stress or physical movement out of the stream reach 

until turbidity levels return to ambient levels. Given that these short-term and localized non-lethal effects 

on fish would depend on site-specific road conditions, and the total mileage of roads within the sediment

delivery distance of streams would vary only slightly among alternatives and the Proposed RMP, there 

would be no measurable difference in effects from short-term flushing of sediment from road surfaces on 

fish under any of the alternatives or the Proposed RMP.

Pacific lampreys require sediment accumulations in slow water habitat to complete juvenile rearing. 

Juvenile lampreys bury themselves in thick sediment deposits where they rear for up to seven years while 

filter feeding (Luzier et al. 2009). Since none of the alternatives of the Proposed RMP would increase 

sediment contribution above the site level, there would be no measurable difference in effects on Pacific 

lamprey under any of the alternatives or the Proposed RMP.
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Watershed restoration actions, such as log and boulder placement and fish passage improvements that are 

beneficial to fish habitat, would also result in short-term increases in sediment delivery to stream 

channels. Removal of culverts and other in-stream structures like blockages would cause stream channel 

disturbance during summer in-stream operating periods (ODFW 2008). Juvenile fish rearing in these 

reaches would be displaced moving either upstream or downstream during the time of elevated turbidity 

and these juveniles would return shortly after disturbance. This could be up to 8 hours in duration and the 

elevated turbidity could extend tens to hundreds of feet downstream from the site of the disturbance. 

Application of BMPs (Appendix J) would help meet ODEQ water quality standards (see the Hydrology 

section of this chapter) and further reduce the effects of elevated turbidity on juvenile fish. Additionally, 

because the BLM does not forecast any difference among the alternatives in watershed restoration 

actions, there would be no difference in effects on turbidity because of restoration actions under any of 

the alternatives or the Proposed RMP.

Under all of the alternatives and the Proposed RMP, the effect on stream sediment from livestock grazing

would remain the same or decrease. Heavy livestock grazing can consume and trample riparian vegetation 

and displace soil in riparian and upland areas, potentially creating sources of sediment and reducing the 

ability of the riparian vegetation to filter sediment. As discussed in the Livestock Grazing section, under 

all and the Proposed RMP, livestock grazing (acres for grazing, number of allotments, animal unit 

months, and permittees/lessees) would remain the same or decrease. Under the No Action alternative, 

Alternatives A, B, and C, and the Proposed RMP, the BLM would manage livestock grazing in 

accordance with the Standards for Rangeland Health and Guidelines for Livestock Grazing Management 

for Public Lands in Oregon and Washington (USDI 1997) included in Appendix L. Standard #5 of the 

rangeland health standards (Native, T&E, and Locally Important Species; 1.j.) includes guidance to 

provide for the life cycle requirements, and maintain or restore the habitat elements of native (including 

threatened and endangered, Bureau Special Status, and locally important species) and desired plants and 

animals. This guidance would allow the BLM to restrict the timing of livestock grazing to avoid impacts 

to ESA-listed fish species and Bureau Sensitive fish species. The BLM assumes the current level of 

livestock grazing would continue under the No Action alternative, Alternatives A, B, and C and the 

Proposed RMP (see the Livestock Grazing section of this chapter). Under Alternative D, the BLM would 

eliminate livestock grazing. Because the BLM would adjust grazing practices under the No Action 

alternative, Alternatives A, B, and C, and the Proposed RMP as needed to manage livestock grazing in 

accordance with the rangeland health standards, including maintaining and restoring habitat for threatened 

and endangered fish species and Bureau Sensitive fish species, the effects of livestock grazing on 

sediment delivery that could affect fish would be similar to Alternative D at this scale of analysis.

Where livestock grazing would be restricted or eliminated, there would be some recovery of streamside

vegetation, which would result in a reduction of stream bank erosion and sediment contribution to 

streams. This would result in improved spawning substrate for fish through a reduction in fine sediment in 

gravels. However, at the scale of the planning area, there would be no discernable difference among any 

of the alternatives or the Proposed RMP in the effects to fish from livestock grazing.

The extraction of minerals on BLM-administered lands adjacent to streams could generate sediment from 

operations that involve bank excavation with heavy machinery or in-channel suction dredge mining. 

Operation of heavy machinery and suction dredges for mining within the active channel or floodplain of 

streams containing ESA-listed fish or critical habitat for ESA-listed fish would result in addition of 

sediment from stream banks and elevated turbidity from disturbance of the stream bed. The scale and 

extent of mining is variable and therefore difficult to predict. The amount of sediment generated could 

result in similar turbidity related stress or effects to the stream by reducing substrate quality for spawning 

or pool habitat volume. There is no reasonable basis upon which the BLM could predict any difference in 
300 | P a g e

these potential effects from mining among the action alternatives, the No Action alternative, or the 

Proposed RMP at this scale of analysis.

Issue 3

How would the alternatives vary in maintaining stream temperatures for fish-bearing and non-fishbearing streams?

Background

The 2008 FEIS described the effects of temperature to fish and that discussion is incorporated here by 

reference (USDI BLM 2008, pp. 388–389). Salmon and steelhead require relatively narrow ranges of 

temperature at multiple life stages for optimal migration, growth, and reproduction. The Oregon 

Department of Environmental Quality has defined those ranges in their cold-water protection standards 

(Table 3-46).

Table 3-46. State of Oregon cold-water protection criteria for trout and salmon species

Salmonid Beneficial Use Criteria

Salmon and Steelhead Spawning 55.4 F

Core Coldwater Habitat 60.8 F

Salmon and Trout Rearing and Migration 64.4 F

Salmon and Steelhead Migration Corridor 68.0 F

Lahontan Cutthroat Trout or Redband Trout 68.0 F

Bull Trout Spawning and Juvenile Rearing 53.6 F

Affected Environment and Environmental Consequences

As stated in the Hydrology section, the riparian management strategies under the No Action alternative 

and Alternatives A and D and the Proposed RMP would be highly protective of stream shade and would 

have little risk of increasing stream temperatures. Under these alternatives and the Proposed RMP, less 

than 0.5 percent of all perennial and fish-bearing reaches in the decision area would be susceptible to 

shade reductions that could affect stream temperature if the BLM applies thinning in the outer zone of the 

Riparian Reserve, based on the current condition. However, this limited stream mileage reflects areas 

with currently low canopy cover in the inner zone, which are the riparian stands least likely to be thinned 

under the management direction of the No Action alternative, and Alternatives A and D and the Proposed 

RMP. As discussed in the Hydrology section, this result does not reflect an actual reduction in stream 

shading, but a susceptibility to such a reduction in stream shading if the BLM thins the outer zone along 

these streams. If the BLM does not thin the stand in the outer zone, no reduction in stream shading would 

occur. Even if the outer zone adjacent to inner zone with low canopy cover were thinned, not all of the 

susceptible reaches would be treated in a given year. In addition, as some stream reaches are treated other 

stream reaches would recover, reducing the overall effect of canopy removal. This limited stream mileage 

susceptible to shade reductions would decrease over time as the stands in the inner zone increase in 

canopy cover. The stream mileage susceptible to shade reductions would decrease to almost zero in 20 

years under Alternatives A and D, and the Proposed RMP, and in 30 years under the No Action 

alternative. Intermittent streams that only flow during colder, generally overcast winter months are much 

less able to contribute to temperature increases downstream (see the Hydrology section in this chapter). 

Narrower Riparian Reserve widths on non-fish-bearing intermittent streams under Alternatives B and C 
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and in Class III subwatersheds under the Proposed RMP would therefore not have any measurable effect 

on stream temperature.

Under Alternatives B and C, approximately 5 percent of fish-bearing and perennial streams would be 

susceptible to shade reductions that could affect stream temperature if the BLM applied thinning in the 

outer zone of the Riparian Reserve, based on the current condition. This larger stream mileage does not 

reflect greater effects of thinning under Alternatives B and C, but a greater susceptibility to shade 

reductions because of the combination of the current condition of low canopy cover in the inner zone 

along these streams, combined with the narrower inner zone width under Alternatives B and C. As noted 

above, areas with low canopy cover in the inner zone are the riparian stands least likely to be thinned 

under the management direction of Alternatives B and C. Even if the outer zone adjacent to inner zone 

with low canopy cover was thinned, not all of the susceptible reaches would be treated in a given year. In 

addition, as some stream reaches are treated other stream reaches would recover, reducing the overall 

effect of canopy removal. The stream mileage susceptible to shade reductions would decline within the 

first 20 years under Alternatives B and C, and then would remain relatively constant.

At the stream reach scale, a loss in stream shade that could affect stream heating might result in non-lethal 

stress for juvenile salmonids rearing (e.g., lowered disease resistance and reduced growth rate) where 

stream temperatures already exceed ODEQ standards for fish use. However, relatively few miles of 

streams susceptible to shade reductions that could affect stream temperature are coincident with 

temperature impaired. Under the No Action alternative, Alternatives A and D, and the Proposed RMP, 

30–34 miles of stream reaches in the decision area would be susceptible to shade reductions that could 

affect stream temperature, and less than 9 percent of these susceptible stream reaches (2.4 miles) overlap 

temperature impaired reaches. Under Alternatives B and C, 370–372 miles of stream reaches would be 

susceptible to shade reductions that could affect stream temperature, and about 10 percent of these 

susceptible reaches (36.8 miles) overlap temperature impaired reaches. Effects from canopy removal 

would be most noticeable in smaller headwater perennial streams that have a continuous canopy over the 

channel. Shade reductions on intermittent streams that are dry during the hotter summer months would 

not result in a measurable increase in stream temperatures or affect fish.

Larger order channels would have a sufficient buffer to temperature increases from the large volume of 

water that the overall effect on salmonids would be negligible. Additionally, larger streams have more 

open canopy over the center of the channel and a small reduction in shade would represent a relatively 

small change in the overall amount of sunlight reaching the steam.

Issues Considered but not Analyzed in Detail

How would peak streamflows affect fish habitat?

The effect of changes in peak streamflows on fish habitat was not analyzed in detail, because the slight 

changes in peak streamflow susceptibility under the alternatives and the Proposed RMP would not result 

in any measurable difference in effects on fish habitat. The Hydrology section identifies watersheds that 

would be susceptible to peak flow increases from rain-on-snow events and evaluated how each of the 

alternatives would affect the potential for peak flow increases. Atypically high stream flows can modify 

stream channels by scouring banks and substrate, altering fish habitat. The 2008 FEIS provided a 

summary of the potential effects of stream flow and peak flows on fish habitat. That discussion is 

incorporated here by reference (USDI BLM 2008, pp. 390, 800–801). The Hydrology section contains the 

conclusion that a very small acreage of BLM-administered lands in the planning area would be 

susceptible to peak streamflow increases under any alternative or the Proposed RMP. Consistent with the 

conclusions in the 2008 FEIS, there would be no identifiable difference among the alternatives and the 

Proposed RMP in the effects on fish from peak flow increases for the following two reasons: (1) there is 
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no methodology for detecting differences in effects on fish habitat at this scale of analysis, given the small 

acreage susceptible to peak flow increases and the relatively small difference in peak flow susceptibility 

among the alternatives; and (2) the causal connection between watershed susceptibility to increases in 

peak flow and fish habitat is too speculative and tenuous to describe direct or indirect effects that would 

differ among the alternatives and the Proposed RMP.

How would stream productivity resulting from nutrient and sunlight influences vary between the 

alternatives?

The effect of changes in stream productivity was not analyzed in detail, because there would be no 

measurable difference in effects among the alternatives and the Proposed RMP. In addition to primary 

productivity, there are other sources of nutrient input and food web stimulus into small fish-bearing 

streams. Opening the riparian overstory and increasing the available light that reaches the stream can 

increase primary productivity (Hill et al. 1995), hasten breakdown of litter and leaf material (Lagrue et al.

2011) and translate to increases in macroinvertebrate and fish biomass (Wootton 2012, Kiffney et al.

2014). Fish-bearing stream reaches can receive nutrient influxes from headwater reaches. Both 

invertebrates and detritus can be exported downstream from non-fish-bearing, headwater reaches yearround and, in turn, support large numbers of juvenile fish (Wipfli and Gregovich 2002). Thinning riparian 

stands, especially near streams, could potentially increase the primary productivity in streams by 

increasing sunlight to streams and altering the litter fall composition. All action alternatives and the 

Proposed RMP would limit near-stream thinning to maintain stream shading. However, Alternatives B 

and C, which could partially reduce streamside shade, could result in increased primary productivity and 

growth rates of juvenile salmonids. However, as described above under stream shading, such effects 

under Alternative B and C are uncertain, and it is not possible to identify any specific change in stream 

productivity under any of the alternatives or the Proposed RMP.

Historic salmon runs would have also added a large nutrient component to headwater streams that could 

be utilized by macroinvertebrates and juvenile fish. The ODFW has added spent hatchery carcasses to 

streams since salmon carcasses could potentially increase growth and abundance of macroinvertebrates 

that provide forage for juvenile salmonids (Chaloner and Wipfli 2002, Kiffney et al. 2014). The addition 

of salmon carcasses by ODFW could happen under all of the alternatives, and there is no basis for 

identifying any difference among the alternatives in nutrient inputs to streams.

How would Lost River sucker and shortnose sucker be affected by BLM management actions?

The effects of BLM management on Lost River (Deltistes luxatus) and shortnose sucker (Chasmistes 

brevirostris) were not analyzed in detail, because there would be no measurable difference in effects 

under the alternatives or the Proposed RMP. The primary effects to Lost River and shortnose sucker 

adjacent to or downstream of BLM-administered lands on the east side of the Klamath Falls Field Office 

would be through management of livestock grazing allotments. As noted previously, livestock could 

trample streamside vegetation and disturb stream banks causing erosion and sediment delivery to adjacent 

streams. This would reduce spawning substrate quality where fine sediment becomes entrained in gravel 

and pool habitats by reducing pool volume through deposition of sediment.

Within the decision area, grazing on allotments in the Klamath Falls Field Office would have no effect on 

Lost River sucker critical habitat. However, where Lost River sucker occupy habitat in the Klamath 

River, there is potential for grazing to cause an effect in very limited areas where livestock could 

potentially access the Klamath River.
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Four grazing allotments in the Klamath Falls Field Office could adversely affect shortnose sucker or its 

critical habitat (USDI FWS 2013). The Pitchlog, Dry Prairie, and Horsefly allotments are adjacent to 

streams designated as critical habitat, and the Paddock allotment is adjacent to Gerber Reservoir, which is 

designated critical habitat for the shortnose sucker. Together these four allotments comprise 7.5 stream 

miles and 147.1 acres of critical habitat for shortnose sucker in reservoirs.

Grazing is not a causal factor for non-attainment of Rangeland Health Standards on any of these four 

allotments. A Rangeland Health assessment found that Pitchlog, Dry Prairie, and Horsefly allotments are 

meeting or substantially meeting criteria for Riparian/Wetland Areas (see the Livestock Grazing section

of this chapter). Water Quality is not being met on any of the three allotments, with summer stream 

temperature exceeding state standards. However, the causal mechanism for elevated water temperature is 

regulation of the upstream Gerber Reservoir, over which the BLM has no control. Grazing practices 

specifically are not considered a factor in the non-attainment of the standard (USDI FWS 2013). The 

Paddock allotment is meeting both Riparian and Wetland Areas and Water Quality Rangeland Health

Standards (USDI BLM 2003).

As described above, the BLM would eliminate livestock grazing under Alternative D and would manage 

livestock grazing under all other alternatives and the Proposed RMP in accordance with the Standards for 

Rangeland Health and Guidelines for Livestock Grazing Management for Public Lands in Oregon and 

Washington (USDI 1997) included in Appendix L. This guidance would allow the BLM to restrict the 

timing of livestock grazing to avoid impacts to Lost River sucker and shortnose sucker. Because the BLM 

would adjust grazing practices under the No Action alternative, Alternatives A, B, and C, and the 

Proposed RMP as needed to manage livestock grazing in accordance with the rangeland health standards, 

including maintaining and restoring habitat for threatened and endangered species, the effects of livestock 

grazing on Lost River sucker and shortnose sucker would be similar to Alternative D at this scale of 

analysis.
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Forest Plan–the first 20 years (1994–2013): watershed condition status and trend. Gen. Tech. Rep. PNW-GTR-932. USDA

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management. North American Journal of Fisheries Management 9(4): 427–436. http://dx.doi.org/10.1577/1548-

8675(1989)009<0427:IADOWD>2.3.CO;2.

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National Marine Fisheries Service. Seattle, WA. 281 pp.

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Salmon (Oncorhynchus kisutch). National Marine Fisheries Service, Arcata, CA.

USDI BLM. 1997. Standards for Rangeland Health and Guidelines for Livestock Grazing Management for Public Lands in 

Oregon and Washington. http://www.blm.gov/or/resources/recreation/csnm/files/rangeland_standards.pdf.

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76 pp. http://www.oregondeq.org/lab/techrpts/docs/10-lab-003.pdf.

Oregon Department of Fish and Wildlife (ODFW). 2008. Oregon Guidelines for timing of in-water work to protect fish and 

wildlife resources. Portland, OR. 12 pp.

Poage, N. J., and J. C. Tappeiner. 2002. Long-term patterns of diameter and basal area growth of old-growth Douglas-fir trees in 

western Oregon. Canadian Journal of Forest Research 32: 1232–1243.

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Reeves, G. H. 2006. The Aquatic Conservation Strategy of the Northwest Forest Plan: an assessment after ten years. General 

Technical Report PNW-GTR-577. USDA Forest Service, Pacific Northwest Research Station, Portland, OR.

Reeves, G. H., K. M. Burnett, and E. V. McGarry. 2003. Sources of large wood in the main stem for a fourth-order watershed in 

coastal Oregon. Canadian Journal of Forest Research 33: 1363–1370.

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Reeves, G. H., B. R. Pickard, and K. N. Johnson. In press. An Evaluation of Potential Options for Managing Riparian Reserves of 

the Aquatic Conservation Strategy of the Northwest Forest Plan. General Technical Report PNW-GTR-XXX. USDA Forest 

Service, Pacific Northwest Research Station, Portland, OR.

Spies, T., M. Pollock, G. Reeves, and T. Beechie. 2013. Effects of riparian thinning on wood recruitment: a scientific synthesis. 

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juvenile salmonids. Ecological Applications 14(4): 969–974. http://dx.doi.org/10.1890/03-5190.

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young-growth forests in coastal Oregon. Canadian Journal of Forest Research 27: 638–648.

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---. 2012. Revised Recovery Plan for the Lost River sucker (Deltistes luxatus) and shortnose sucker (Chasmistes brevirostris). 

USDI FWS, Pacific Southwest Region, Sacramento, CA. 122 pp.

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---. 2013. Formal Endangered Species Consultation on the Effects of Grazing Management for Allotments in the Bureau of Land 

Management Klamath Falls Resource Area. Klamath Falls, OR. 61 pp.

---. 2014. Revised Draft Recovery Plan for the coterminous United States population of bull trout (Salvelinus confluentus). 

Portland, OR. xiii + 151 pp.

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Waters, T. F. 1995. Sediment in streams: sources, biological effects, and control. American Fisheries Society Monograph 7.

Wipfli, M. S., and D. P. Gregovich. 2002. Export of invertebrates and detritus from fishless headwater streams in southeastern 

Alaska: implications for downstream salmonid production. Freshwater Biology 47(5): 957–969.

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Forest Management

Key Points

 Even-aged management systems with clear-cutting would produce more uniform stands in a mix 

of age classes without structural legacies. Two-aged management systems with variable-retention 

regeneration harvesting would produce stands in a mix of age classes with legacy structures and 

multiple canopy layers. Uneven-aged management systems with selection harvesting regimes 

would produce mostly older, structurally-complex stands and mature forests with multiple canopy 

layers.

 The allowable sale quantity (ASQ) under the alternatives would range from 120 million board 

feet (MMbf) per year under Sub-alternative B to 486 MMbf per year under Alternative C. The 

ASQ under the Proposed RMP would be 205 MMbf per year. The ASQ is primarily determined 

by the size of the Harvest Land Base, the intensity of forest management practices, and 

restrictions on timber harvest.

 Non-ASQ timber harvest volumes in the first decade would range from 4 MMbf per year under 

Alternative D to 122 MMbf per year under the No Action alternative. Non-ASQ timber harvest 

volume in the first decade for the Proposed RMP would be 73 MMbf per year.

 The proportion of harvest volume coming from large logs (i.e., > 20” diameter at the small end 

of the log inside the bark) would be lowest under Sub-alternative C, at 5 percent of total harvest 

volume, and highest under the No Action alternative and Alternative C, at 14 percent of total 

harvest volume. The proportion of harvest volume coming from large logs would be 9 percent 

under the Proposed RMP.

Summary of Notable Changes from the Draft RMP/EIS

 BLM revised the 2006 net inventory value in Table 3-51. In Table 3-52, the BLM revised 

inventory values by district, removed the acreage column and the gross inventory column, and 

added 2006 inventory data by district for direct comparison. The BLM revised the calculation of 

the 2006 value and the 2013 value directly from collected inventory data for a more accurate 

comparison between the 2 measurement periods.

 BLM added information about how reforestation of disturbed areas would be achieved in each 

alternative and the Proposed RMP, and how this relates to the abundance of the early successional 

structural stage under Issue 1.

 BLM added Table 3-48 reporting average regeneration harvest ages through time under each 

alternative and the Proposed RMP under Issue 1.

 BLM added discussion and analysis in Figure 3-60 regarding small inclusions of early 

successional forest created through implementation of group selection openings in the LateSuccessional Reserve, Riparian Reserve, and Uneven-aged Timber Area, which are not reflected 

in stand average structural stage categories under Issue 1.

Issue 1

How would the age classes, structural stages, and inventory of merchantable timber volumes in forest 

stands change among alternatives in the Harvest Land Base and reserve land use allocations?
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Summary of Analytical Methods

The BLM used Current Vegetation Survey plots and the Forest Operations Inventory to create a data set 

representing the current condition of the forest. The BLM then modeled a variety of silvicultural 

treatments, stand growth, and forest development through time using the ORGANON growth and yield 

model in conjunction with the Yield Table Generator (YTG Tools) and the Woodstock model. The BLM 

modeled silvicultural treatments to simulate the management that would occur under the various 

alternatives and the Proposed RMP, based on the management direction found in Appendix B.

For several aspects of this analysis, the BLM categorized the decision area into the ‘coastal/north’ areas 

(the Coos Bay, Eugene, and Salem Districts) and the ‘interior/south’ areas (the Klamath Falls Field 

Office, and the Medford and Roseburg Districts). This division represents a general divide in forest 

productivity and the current stand conditions within the decision area. The interior/south currently 

contains a higher proportion of lower productivity/fire-prone dry forests than the coastal/north areas.

For other aspects of this analysis, the BLM categorized the decision area into moist and dry forest areas. 

This division of the decision area is consistent with the discussion of moist and dry forest in the Fire and 

Fuels section in this chapter.

The BLM analyzed changes in age classes, structural stages, and standing inventory over a period of 200 

years to provide a meaningful comparison of the effects of the alternatives and the Proposed RMP. This 

length of analysis is necessary given the varying and sometimes long periods between forest management 

treatments to capture forest structural development. The combined effects of forest management and 

forest growth across the landscape would take this longer analysis period to show meaningful changes in 

forest condition.

Acreage summaries in this section do not include Eastside Management Lands, non-forested lands, or 

other areas not given an age or structural stage classification in the Forest Operations Inventory. In the 

majority of this analysis, the BLM reports structural stage classifications as stand level averages.

For selection harvesting and commercial thinning, where development of structural complexity and high 

quality late-successional habitat are primary treatment objectives, implementation would include the 

creation of group selection openings > 0.25 acre in size. These group selection openings would function 

as small inclusions of early successional habitat within young, mature, and structurally-complex stands. 

Therefore, the BLM analyzed the abundance of acres in functional created canopy openings54 to 

supplement the data presented as stand average structural classifications. In order to analyze the 

abundance of this condition in the decision area reported in Figure 3-60, the BLM calculated the area in 

functional created canopy openings as a percentage of harvest acres by land use allocation. The BLM 

based this calculation on management objectives and direction included for each alternative and the 

Proposed RMP in Appendix B. For this analysis, the BLM assumes that these created canopy openings 

are functional for two decades after the harvest entry is completed.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which are incorporated here by reference (USDI BLM 

2014, pp. 56–61).

 

54 These represent openings > 0.25 acre embedded in a larger stand which provide early successional habitat, but do 

not change the structural classification of the stand as a whole and are therefore not in the acreage calculation of the 

early successional structural stage.
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Background

A wide variety of forest conditions exist within the decision area, which includes a variety of forest types, 

ages, structural stages, and productive capacity for timber production. While the forest conditions in many 

areas are the result of past fires and other natural disturbances, the BLM has altered much of the 

landscape through a variety of management activities and harvest. Timber harvest levels in the decision 

area have fluctuated substantially over the past 80 years, with a generally flat trend over the past two 

decades (Figure 3-50).

Figure 3-50. BLM historical timber sales; 1942–1961 data represents volume sold while 1962–2012 data 

represents volume harvested

Between 1962 and 1994, the BLM timber harvest from the planning area was 16 percent of western 

Oregon totals and averaged 980 MMbf per year. Since adoption of the 1995 RMPs, the BLM contribution 

has been less than 5 percent of western Oregon totals and has averaged 144 MMbf per year (Figure 3-

51).

Figure 3-51. Western Oregon timber harvests by landowner, 1962–2011 (Tuchman and Davis 2013)

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

194219471952195719621967197219771982198719921997200220072012

BLM Timber Sales (Mbf)

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

1962196719721977198219871992199720022007

Timber Harvests (MMbf)

Grand Total Private USFS BLM State
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Affected Environment and Environmental Consequences

Age Classes

The natural disturbance and management history of the decision area has resulted in a mix of stand ages. 

The current age class distribution of lands in the decision area is shown in Figure 3-52.

Figure 3-52. 2013 age class distribution for forested acres within the decision area (10-year increments)

The Coos Bay, Medford, and Roseburg Districts currently have the highest proportion of stands 160 years 

old and older with 24 percent, 29 percent, and 32 percent respectively. The Salem District has the lowest

proportion of stands 160 years old and older with 9 percent. With the exception of the Klamath Falls Field 

Office, the districts only have 1–2 percent of their forested lands in the 0- to 10-year age class (Table 3-

47). This is mostly due to the low levels of regeneration harvesting that the BLM has implemented since 

1994 (Figure 3-64).

Table 3-47. 2013 age class distribution (10-year increments); forested acres and percent

District/Field Office 10 20–40 50–70 80–110 120–150 160+ Grand Total

Coos Bay Acres 3,288 91,747 79,527 21,370 34,978 73,119 304,030

Percent 1% 30% 26% 7% 12% 24%

Eugene Acres 2,669 78,887 112,471 41,556 17,022 44,617 297,222

Percent 1% 27% 38% 14% 6% 15%

Klamath Falls Acres 5,442 4,100 7,643 17,819 6,691 5,077 46,773

Percent 12% 9% 16% 38% 14% 11%

Medford Acres 22,889 105,129 91,529 142,002 164,556 214,014 740,119

Percent 3% 14% 12% 19% 22% 29%

Roseburg Acres 4,490 106,530 74,120 34,980 50,640 128,403 399,163

Percent 1% 27% 19% 9% 13% 32%

Salem Acres 2,406 89,082 123,325 64,751 59,641 35,186 374,392

Percent 1% 24% 33% 17% 16% 9%

Totals Acres 41,184 475,474 488,616 322,478 333,529 500,418 2,161,699

Percent 2% 22% 23% 15% 15% 23%

41,184

475,474 488,616

322,478 333,529

500,418

0

100,000

200,000

300,000

400,000

500,000

600,000

0–10 20–40 50–70 80–110 120–150 160+

Decision Area (Acres)

Age Class Groupings
311 | P a g e

The alternatives and the Proposed RMP vary in their approach to protection of older, more structurallycomplex forest, affecting the distribution of older forests among the reserves and the Harvest Land Base. 

The No Action alternative allocates the largest acreage of forests 80 years old and older to the Harvest 

Land Base, while Sub-alternative C allocates the least (Figure 3-53). Of the forests 80 years old and older 

in the Harvest Land Base in Alternative B and the Proposed RMP, 90 percent and 74 percent of the 

acreage, respectively, are located in the interior/south portion of the decision area. The interior/south 

portion of the decision area contains the majority of dry forest types on BLM-administered lands.
312 | P a g e

20 172 202 157 140 147

13

304 287

163 195

357

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (No Action)

2013 Harvest Land Base 2013 Reserves

17 130 146 104

16

347 345

216

336

505

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Alt. A)

2013 Harvest Land Base 2013 Reserves

19 186 206

139 92 63

14

290 285

181 244

442

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Alt. B)

2013 Harvest Land Base 2013 Reserves

17 116 121 83 56 34

17

360 370

238 280

471

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Sub. B)

2013 Harvest Land Base 2013 Reserves
313 | P a g e

Figure 3-53. 2013 age class distribution by age class grouping and by the Harvest Land Base and the 

reserves (10-year increments)

Dry forests typically are the product of relatively frequent low- to mixed-severity fire, which produces 

stands with multiple cohorts of trees of varying ages (Franklin and Johnson 2012, Sensenig et al. 2013). 

Therefore, the concept of stand age in these forests is less useful to approximate structural complexity or 

northern spotted owl habitat value. The BLM’s approach to the protection of older, more structurally23

246 267

178 153

11

231 224

142 183 505

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Alt. C)

2013 Harvest Land Base 2013 Reserves

23

246 267

11

231 224

320 336

505

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Sub. C)

2013 Harvest Land Base 2013 Reserves

25

271 267

181

90

9

206 224

140

246

505

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (Alt. D)

2013 Harvest Land Base 2013 Reserves

19 149 157

93 45 31

22

326 331

230 289

469

0

100

200

300

400

500

600

Forested Acres (Thousands)

Age Class (PRMP)

2013 Harvest Land Base 2013 Reserves
314 | P a g e

complex forests in Alternative B and the Proposed RMP is based on district-defined55 maps, rather than 

stand age, which explains why Alternative B and the Proposed RMP would allocate some older stands, 

especially in the dry forest, to the Harvest Land Base. 

Over time, the age class distribution in the decision area would represent the product of management 

under the different alternatives and the Proposed RMP. In 100 years, the forest stands in reserve land use 

allocations would be mostly greater than 120 years old, since the harvest types employed would not result 

in an alteration of stand structure sufficient to cause a reset of stand age. The BLM expects that wildfire 

would also play a role in shaping the future age class distribution of the decision area, but it would be a 

relatively limited role. The BLM did not simulate other large-scale episodic natural disturbances 

including wind-throw or insect and disease damage in the vegetation modeling.56

The BLM’s simulations of wildfire impacts in the decision area reveal that a relatively small number of 

acres of BLM-administered lands are forecasted to experience high-severity wildfire per decade. On 

average, roughly 150 acres of BLM-administered lands in the coastal/north area and 2,950 acres in the 

interior/south area are forecasted to experience high-severity wildfire per decade. Appendix H contains 

more details of wildfire modeling on these simulations. In the absence of timber harvest, these and other 

natural disturbances would create the only areas in reserve land use allocations containing young stands. 

In the Harvest Land Base, the future age class distribution would be determined by the harvest intensity 

and cutting cycle under each alternative and the Proposed RMP (Figure 3-54).

 

55 Districts defined “older, more structurally-complex forests” as stands meeting the definition high-quality northern 

spotted owl habitat as described in Recovery Action 32: “These high-quality spotted owl habitat stands are 

characterized as having large diameter trees, high amounts of canopy cover, and decadence components such as 

broken-topped live trees, mistletoe, cavities, large snags, and fallen trees” (USDI FWS 2011, p. III-67). Within the 

landscape of the entire planning area, forest types do not equally meet the definition of Recovery Action 32, 

meaning that there is not one age class or one measure of canopy cover that ensures this definition has been met, for 

the BLM to apply unilaterally across the Coos Bay, Eugene, Medford, Roseburg, and Salem Districts and the 

Klamath Falls Field Office of the Lakeview District. For example, a Douglas-fir stand near the Cascade Mountains 

may meet the definition of Recovery Action 32 at a different age, diameter, canopy cover, or decadence components 

than a Douglas-fir stand near the coast. BLM staff applied locally sourced information to stands within each district 

to determine which stands met this definition of Recovery Action 32 on their landscapes, and which ones did not. 

56 In the Woodstock vegetation modeling, the BLM accounted for reductions to timber growth and yield due to 

endemic levels of insects and diseases, but the BLM did not model large-scale episodic insect or disease outbreaks 

or windthrow that would affect stand structural stage classifications or age class distributions. The BLM modeled 

the predicted effects from wildfire and associated timber salvage for the first five decades in the planning area. 
315 | P a g e

93 149 150 109 124 213

0 4 16

431

869

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands)

Age Class (No Action)

2113 Harvest Land Base 2113 Reserves

69 113 96

21 28 72

7

20

498

1,239

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands)

Age Class (Alt. A)

2113 Harvest Land Base 2113 Reserves

54 77 85 69 133

4 17 288

417

1,019

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands)

Age Class (Alt. B)

2113 Harvest Land Base 2113 Reserves

30 48 48 41

77 182

6

20

522

1,188

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands)

Age Class (Sub. B)

2113 Harvest Land Base 2113 Reserves
316 | P a g e

Figure 3-54. 2113 age class distribution by age class grouping, and broken out by the Harvest Land Base 

and the reserves (10-year increments) 

In the long-term, the age class distribution in the Harvest Land Base in the No Action alternative (the 

Matrix and the Adaptive Management Areas) would approach forest regulation (i.e., an equal number of 

acres in each age class grouping). This would be the result of long-rotation, two-aged management on the 

entire Harvest Land Base. The portions of the Harvest Land Base in Alternatives A and C in the High 

Intensity Timber Area (HITA) would trend towards regulation in age classes 0–70 years, which would be 

the product of relatively short-rotation, even-aged management. In Alternatives B and D, and the 

Proposed RMP, the portions of the Harvest Land Base in the Moderate Intensity Timber Area (MITA) 

133 206 172 58

82

214

4 13 329

949

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands) 

Age Class (Alt. C) 

2113 Harvest Land Base 2113 Reserves

100 158 135 21 84 38

0 0 8 14 329

1,275 

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands) 

Age Class (Sub. C) 

2113 Harvest Land Base 2113 Reserves

23 47 54 39

312 358

5 11

300

1,013 

0

200

400

600

800

1,000

1,200

1,400

Forested Acres (Thousands) 

Age Class (Alt. D) 

2113 Harvest Land Base 2113 Reserves

42 72

85

56

96 143

0 0 

6 

25 470

1,167 

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

Forested Acres (Thousands) 

Age Class (PRMP) 

2113 Harvest Land Base 2113 Reserves
317 | P a g e

and Low Intensity Timber Area (LITA) would generally trend towards regulation in age classes 0–140 

years in the dry forest, and 0–100 years in the moist forest. Table 3-48 displays average regeneration 

harvest age by decade, which reflects the trend towards longer rotations in the No Action Alternative, 

Alternatives B and D, and the Proposed RMP, when compared to the trend towards shorter rotations in 

Alternatives A and C, and Sub-alternative C. 

Table 3-48. Average regeneration harvest age in years by decade in the decision area 

Alternative/

Proposed 

RMP

2023

(Age)

2033 

(Age)

2043 

(Age)

2053 

(Age)

2063 

(Age)

2073 

(Age)

2083 

(Age)

2093 

(Age)

2103 

(Age)

2113 

(Age)

2213 

(Age)

No Action 162 167 157 136 117 130 125 130 125 125 123

Alt. A 65 74 74 75 77 75 78 64 61 61 51

Alt. B 87 79 75 73 89 96 89 103 97 100 99

Sub. B 82 70 70 72 82 85 77 98 99 99 98

Alt. C 80 91 88 87 86 85 86 78 71 76 54

Sub. C 61 65 70 70 73 75 76 67 67 67 65

Alt. D 71 83 74 78 76 82 61 122 124 120 122

PRMP 88 80 78 89 93 105 76 101 93 101 125

The portions of the Harvest Land Base in the Uneven-aged Timber Area (UTA) in all action alternatives 

and the Proposed RMP, and the Owl Habitat Timber Area (OHTA) in Alternative D would tend to get 

older at a similar rate as stands within reserve land use allocations, because stands in the Uneven-aged 

Timber Area and Owl Habitat Timber Area would be partially cut on a perpetual re-entry cycle. Stands 

partially cut under uneven-aged management regimes would never be reset to stand age zero by standwide regeneration harvest. These stands would transition to multi-aged, multi-cohort stands. The 

following table shows the percentage of the Harvest Land Base in each land use allocation category 

grouped in a way that is relevant to describe effects on the future age class distribution (Table 3-49).

Table 3-49. Percentage of Harvest Land Base in each land use allocation category 

Alternative/

Proposed RMP

Longer Rotation Two-aged;

GFMA, NGFMA, SGFMA,

CONN, AMA, LITA, MITA

(Percent)

Shorter Rotation Even-aged;

HITA

(Percent)

Uneven-aged;

UTA, OHTA

(Percent)

No Action 100% - -

Alt. A - 84% 16%

Alt. B 51% - 49%

Sub. B 54% - 46%

Alt. C - 75% 25%

Sub. C - 81% 19%

Alt. D 25% - 75%

PRMP 69% - 31%

In summary, progression of the age class distribution of the decision area through time would be dictated 

by the harvesting practices directed in each land use allocation. Reserves and allocations dedicated to 

uneven-aged management regimes and associated selection harvesting, the Uneven-aged Timber Area and 

Owl Habitat Timber Area, would continue to age since the stand age would never be reset to zero, barring 
318 | P a g e

an intense natural disturbance event. The relatively short rotation even-aged management regimes and 

associated clear-cutting in the High Intensity Timber Area land use allocation in Alternatives A and C 

would result in roughly an equal number of acres in each age class up to the 70-year class.

The emphasis on longer rotation two-aged management regimes and associated variable-retention 

regeneration harvesting would result in roughly an equal number of acres in each 10-year age class up to 

the 100-year age class in moist, higher productivity forest, and up to the 140-year age class in drier, lower 

productivity forests. This would occur in the No Action alternative, in the Moderate Intensity Timber 

Area and Low Intensity Timber Area in Alternative B, Sub-alternative B, and the Proposed RMP, and in 

the Moderate Intensity Timber Area in Alternative D. The more clear-cutting and variable-retention 

regeneration harvesting57 in an alternative or the Proposed RMP, the more acres would be in the younger 

age classes in 100 years. Therefore, the overall age class distribution in Alternative C would contain the 

most acres in stands less than or equal to 40 years old in 100 years (Figure 3-54).

Structural Stages

In this analysis, the BLM evaluated the development of the forest categorized by structural stages (Table 

3-50). Appendix C has a more detailed discussion of the structural stage classification system.

Table 3-50. Structural stage classification generalized definitions.

Code Structural Stage Classification Label

ES-WSL Early Successional with Structural Legacies

ES-WOSL Early Successional without Structural Legacies

SE-WSL Stand Establishment with Structural Legacies

SE-WOSL Stand Establishment without Structural Legacies

YHD-WSL Young High Density with Structural Legacies

YHD-WOSL Young High Density without Structural Legacies

YLD-WSL Young Low Density with Structural Legacies

YLD-WOSL Young Low Density without Structural Legacies

M-SINGLE Mature Single-layered Canopy

M-MULTI Mature Multi-layered Canopy

SC-DEV Structurally-complex, Developed Structurally-complex

SC-OF Structurally-complex, Existing Old Forest

SC-VOF Structurally-complex, Existing Very Old Forest

The natural disturbance and management history of the decision area has affected the mix of structural 

stages similarly to age classes. The decision area is currently comprised predominately of Stand 

Establishment without Structural Legacies, Young without Structural Legacies, Mature, and Structurallycomplex forest (Figure 3-55).

 

57 The BLM uses the term variable-retention regeneration harvest in this analysis to describe regeneration harvest 

practices in the Matrix and Adaptive Management Area land use allocations under the No Action alternative, and the 

Moderate Intensity Timber Area and Low Intensity Timber Area land use allocations in the action alternatives and 

the Proposed RMP. The 1995 RMPs require retention of green trees in regeneration harvests based on a range of 

trees per acre, while the Moderate Intensity Timber Area and Low Intensity Timber Area base retention levels on a 

target proportion of pre-harvest basal area.
319 | P a g e

Figure 3-55. Current structural stage distribution for the decision area

Note: See Table 3-50 for label definitions and Appendix C for more details on structural stage classifications.

17,828

35,630

67,371

319,876

128,419

441,610

11,672

37,930

240,825

277,069

239,004

325,835

18,620

0

100,000

200,000

300,000

400,000

500,000

ES-WSL

ES-WOSL

SE-WSL

SE-WOSL

YHD-WSL

YHD-WOSL

YLD-WSL

YLD-WOSL

M-Single

M-Multi

SC-Dev

SC-OF

SC-VOF

Forest Structure (Acres)

Structural Stage Classification
320 | P a g e

The BLM management has the potential to cause substantial changes to the structural stage distribution of 

forested lands in the decision area over time. The 2008 FEIS contains a robust spatial and temporal 

analysis regarding Forest Structure and Spatial Pattern compared to historic condition, which is 

incorporated here by reference (USDI BLM 2008, pp. 501–536).

The structural stage progression in the reserve land use allocations would represent the majority of the 

forested land in the decision area, because the BLM would allocate no more than 30 percent of the 

decision area to the Harvest Land Base in any alternative or the Proposed RMP. Since the majority of 

forested land resides in reserve land use allocations, structural stage differences between alternatives and 

the Proposed RMP are muted when the Harvest Land Base and reserves are combined, therefore they will 

be discussed and shown separately. Figure 3-56 highlights the structural stage progression through time 

for each alternative and the Proposed RMP, grouped into similar categories, and broken out by the 

Harvest Land Base and reserves.

The proportion of the Harvest Land Base composed of Mature Multi-layered Canopy and Structurallycomplex forests in 2013 in each alternative and the Proposed RMP would be mostly driven by the 

alternative-specific approach to the protection of older, more structurally-complex forests. The BLM has 

grouped Mature Multi-layered Canopy with Structurally-complex stands in the following figures and 

discussion due to their similarities related to northern spotted owl habitat quality.
321 | P a g e

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

No Action-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

No Action-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. A-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. A-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL
322 | P a g e

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. B-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. B-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Sub. B-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Sub. B-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL
323 | P a g e

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. C-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. C-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Sub. C-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Sub. C-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL
324 | P a g e

Figure 3-56. Structural stage progression over 200 years in the Harvest Land Base and reserves

Note: See Table 3-50 for label definitions.

The No Action alternative contains the highest proportion of the Harvest Land Base in Mature Multilayered Canopy and Structurally-complex structural stages (35 percent). Sub-alternative C contains the 

smallest proportion of these stands in the Harvest Land Base, with approximately 5 percent, since the 

BLM would reserve all stands greater than 80 years old in this sub-alternative. It is notable that while 

close to 25 percent of the Harvest Land Base is in the Mature Multi-layered Canopy and Structurallycomplex structural stages in Alternative B and the Proposed RMP, over 70 percent of those acres are in 

the interior/south portion of the decision area. Alternative B and the Proposed RMP include a district0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. D-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

Alt. D-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

PRMP-HLB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

20132023203320432053206321132213

PRMP-Reserve

M-Multi/SC

M-Single

YHD/YLD-WOSL

YHD/YLD-WSL

ES/SE-WOSL

ES/SE-WSL
325 | P a g e

defined designation of older, more structurally-complex forests. See Chapter 2 for a more thorough 

explanation of the varying approaches to older forest protection.

In the Harvest Land Base, the patterns of structural stage progressions would follow three distinct patterns 

(Figure 3-57). In Alternatives A and C, the Harvest Land Base would mostly trend towards single-story 

stands and structural stages without structural legacies, in almost equal parts of Early Successional, Stand 

Establishment, Young, Mature, and Structurally-complex in 100 years. In the No Action alternative, 

Alternative B, and the Proposed RMP, the Harvest Land Base would mostly trend towards multi-layered 

stands and structural stages with structural legacies, with Mature Multi-layered Canopy and Structurallycomplex stands occupying around 50 percent of the area in 100 years. In Alternative D, in which 75 

percent of the Harvest Land Base would be managed using uneven-aged management regimes (Table 3-

49), the majority of the Harvest Land Base would develop into Mature Multi-layered Canopy or

Structurally-complex stands in 100 years.
326 | P a g e

Figure 3-57. Proportion of the Harvest Land Base as Mature Multi-layered Canopy or Structurallycomplex through time

Under Alternatives A and C, clear-cutting in the High Intensity Timber Area would produce relatively 

uniform, single–story stands, with little to no structural legacies. In contrast, the variable-retention 

regeneration harvesting in portions of the No Action alternative, Alternatives B and D, and the Proposed 

RMP would produce heterogeneous, multi-layered stands with structural legacies (Figure 3-58). This is 

consistent with the analytical conclusions about the effect of different regeneration harvest approaches on 

structural stage development in the 2008 FEIS (USDI BLM 2008, pp. 505–506, 508–513, 517) and recent 

publications on retention forestry (Gustafsson et al. 2012).

0%

10%

20%

30%

40%

50%

60%

70%

80%

2013 2023 2033 2043 2053 2063 2113 2213

Mature Multi-layered Canopy or Structurally-complex Harvest Land Base (Percent)

Year

No Action Alt. A Alt. B Sub. B

Alt. C Sub. C Alt. D PRMP

No Action

Alt. D

Sub. C

Alt. C

Alt. A

Alt. B

Sub. B

PRMP
327 | P a g e

Figure 3-58. Proportion of the Harvest Land Base sub-allocations with structural legacies or multiple 

layers through time

Note: The data is not shown for Alt. B Low Intensity Timber Area, Alt. B and D Moderate Intensity Timber Area, Alt. A, B, C, 

and D Uneven-aged Timber Area since the land use allocation development trends within the Harvest Land Base sub-allocations 

are nearly identical among the action alternatives and would be indiscernible from the Proposed RMP on this graph.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2013 2023 2033 2043 2053 2063 2113 2213

Harvest Land Base with Structural Legacies and Multiple Layers (Percent)

Year

No Action HLB Alt. A HITA Alt. C HITA Alt. D OHTA

PRMP LITA PRMP MITA PRMP UTA

No Action 

HLB

Alt. A HITA Alt. C HITA

Alt. D OHTA

PRMP MITA

PRMP UTA

PRMP LITA
328 | P a g e

Clear-cutting under Alternatives A and C would produce different post-harvest conditions than variableretention regeneration harvesting under the No Action alternative, Alternatives B and D, and the Proposed 

RMP. Alternative C would produce the most Early Successional conditions, while Alternative B would 

produce the most Early Successional with Structural Legacies. Alternative D would produce the least 

amount of acres in Early Successional conditions of the alternatives and the Proposed RMP, the majority 

of which would contain structural legacies. The Proposed RMP would produce the second least number of 

acres of Early Successional condition, and the majority would be Early Successional with Structural 

Legacies (Figure 3-59).

Figure 3-59. Structural complexity and abundance of the Early Successional structural stage in 2063

Reforestation practices after regeneration harvest would vary depending on the Harvest Land Base suballocation, and the alternatives and the Proposed RMP, which would affect duration and quantity of the 

Early Successional structural stage. For the Low Intensity Timber Area in Alternative B, the BLM would 

achieve reforestation using natural regeneration only, prohibiting tree planting. In addition, the BLM 

would delay canopy closure of regenerated trees on a portion of the harvest area for three decades after 

harvesting. In the Moderate Intensity Timber Area in Alternative B, the BLM would allow tree planting, 

but would delay canopy closure by three decades after harvesting. The BLM would achieve delayed 

canopy closure in Alternative B through altering the timing and intensity of pre-commercial thinning. The 

combination of delayed canopy closure of regenerated trees in the Low Intensity Timber Area and 

Moderate Intensity Timber Area, and the prohibition on planting trees in the Low Intensity Timber Area 

in Alternative B, would act to extend the duration and increase the abundance of the Early Successional 

structural stage, when compared with the other alternatives and the Proposed RMP. In the No Action 

alternative, the High Intensity Timber Area in Alternatives A and C, the Moderate Intensity Timber Area 

in Alternative D, and the Low Intensity Timber Area and Moderate Intensity Timber Area in the Proposed 

RMP, the BLM would require adequate reforestation within 5 years of completion of harvest. This 

explains why the Proposed RMP would produce fewer acres in the Early Successional structural stage 

110,272

6,155

117,064

70,664

9,554 10,490

44,831

63,557

286

69,967

1,248

1,255

121,447 111,770

1,169

1,861

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Acres

Early Successional without Structural Legacies Early Successional with Structural Legacies
329 | P a g e

through time than Alternative B, despite the fact that the Proposed RMP would result in more 

regeneration harvesting per decade than Alternative B. Forest Management Issue 2 further discusses 

reforestation practices as they relate to intensity of management.

In the reserves, the pattern of structural stage development would vary little because the BLM would 

implement silvicultural treatments in the reserve land use allocations only for restoration purposes under 

all alternatives and the Proposed RMP. Therefore, the reserve land use allocations would generally trend 

towards Mature and Structurally-complex conditions, while Early Successional, Stand Establishment, and 

Young stands would mostly disappear over time.

Natural disturbances, especially wildfire, would create some Early Successional stands, regardless of land 

use allocation designation. Because the acreage of reserve allocations would vary by alternative and the 

Proposed RMP, the acreage of reserve allocations affected by wildfire would vary as well. Based on 

wildfire simulation, on average, between 41–115 acres of reserve land use allocations on BLMadministered lands in the coastal/north area and between 911–2,317 acres of reserve land use allocations 

on BLM-administered lands in the interior/south area would experience high-severity wildfire per decade. 

Assuming burned stands remain in an Early Successional structural stage for three decades, this would 

only yield up to 345 acres of Early Successional stands in the coastal/north areas, and 6,951 acres of Early 

Successional stands in the interior/south areas in any given decade. With the exception of wildfire, the 

BLM did not simulate the impacts of large-scale episodic natural disturbances (e.g., windthrow or insect 

and disease outbreaks) in the vegetation modeling to determine effects to stand structural development.

In the vegetation modeling, the BLM calculated structural stage classifications based on stand level 

average conditions. However, the BLM recognizes that selection harvesting and commercial thinning 

would create functional canopy openings resulting in small inclusions of Early Successional habitat in 

Young, Mature, and Structurally-complex stands. The amount of functional canopy openings the BLM 

would create through silvicultural treatments varies by the primary objectives for forest management. For 

selection harvesting and commercial thinning where production of a stable wood supply is the primary 

objective, forest management would create few functional canopy openings. For selection harvesting and 

commercial thinning, where development of structural complexity and high quality late successional 

habitat are primary treatment objectives, implementation would involve the creation of group selection > 

0.25 acres in size. These group selection openings would function as small inclusions (i.e., functional 

created canopy openings) of Early Successional habitat within Young, Mature, and Structurally-complex 

stands, but do not show up in the calculation of acres by stand level average structural stage classification. 

Created canopy openings would enhance structural development by contributing to multiple layered 

canopies, creating growing space for desirable understory vegetation and hardwoods, and increasing 

edge-tree limb development and diameter growth. Figure 3-60 reports the number of acres of functional 

created canopy openings > 0.25 acres in size in 2043 by land use allocation or sub-allocation. Alternative 

B would produce the highest acreage in functional created canopy openings in 2043, followed by the 

Proposed RMP, Alternative D, and Alternative C, with the No Action alternative producing the fewest 

acres.
330 | P a g e

Figure 3-60. Acreage of functional created canopy openings > 0.25 acres in 2043 by alternative and land 

use allocation

Management direction for stand treatments within the Late-Successional Reserve would vary. The No 

Action alternative, Alternatives B and C, and the Proposed RMP would include timber harvesting as a 

tool for attainment of Late-Successional Reserve management objectives. Alternative A would achieve 

these management objectives in the moist forest Late-Successional Reserve through non-commercial 

management (i.e., cutting trees but not removing them from the stand). In Alternative D, the LateSuccessional Reserve is comprised of older, more structurally-complex forest and thus would not require 

the same treatments to attain Late-Successional Reserve management objectives. However, the Owl 

Habitat Timber Area within the Harvest Land Base in Alternative D includes management direction to 

apply selection harvesting to speed the development of and then maintain northern spotted owl habitat, 

similar to the management direction within the Late-Successional Reserve in other action alternatives and 

the Proposed RMP. Therefore, the outcomes for the Owl Habitat Timber Area in Alternative D provide a 

relevant comparison to the outcomes for portions of the Late-Successional Reserve under other 

alternatives and the Proposed RMP.

The following figure (Figure 3-61) illustrates the differences in the proportion of forested acres in Mature 

Multi-layered Canopy and Structurally-complex conditions in 2013 and 2213. The BLM grouped the 

Mature Multi-layered Canopy and Structurally-complex structural stages together because they generally 

represent the highest quality spotted owl habitat. The difference in structural conditions in the moist forest 

Late-Successional Reserve managed using commercial thinning is indistinguishable from structural 

1,174

4,538

8,353 6,693

8,505

4,090

22,023

14,588

23,584

16,009

2,986

255

2,807

1,227

127

573

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Functional Created Canopy Openings in 2043 (Acres) 

LSR UTA/OHTA Riparian Reserve
331 | P a g e

conditions in the Late-Successional Reserve using non-commercial thinning only (Alternative A). 

However, 98 percent of stands develop into Mature Multi-layered Canopy and Structurally-complex 

stands in response to the uneven-aged management prescriptions in the Owl Habitat Timber Area in 

Alternative D.

Figure 3-61. Proportions of owl habitat management land use allocations in Mature Multi-layered 

Canopy or Structurally-complex structural stages in 2013 and 2223

Figure 3-62 shows that the proportions of acres in Mature Multi-layered Canopy and Structurallycomplex conditions in the Late-Successional Reserve, the Uneven-aged Timber Area, and the Owl 

Habitat Timber Area would range between 60 percent and 81 percent in 100 years. In the High Intensity 

Timber Area under Alternatives A and C, the acreage of Mature Multi-layered Canopy and Structurallycomplex stands would decline to zero in 100 years due to the emphasis on relatively short-rotation clearcutting harvest practices. The Low Intensity Timber Area and Moderate Intensity Timber Area in 

Alternative B, and the Moderate Intensity Timber Area in alternative D, would achieve moderately higher 

proportions in Mature Multi-layered Canopy and Structurally-complex forest than the High Intensity 

Timber Area under Alternatives A and C, with around 10 percent, due the trend towards longer rotation 

lengths and variable-retention regeneration harvest practices. The proportion of acres in Mature Multilayered Canopy and Structurally-complex conditions in the Low Intensity Timber Area and Moderate

Intensity Timber Area in the Proposed RMP in 100 years would be 22 percent and 28 percent 

respectively.

48% 51% 52%

47%

56% 55%

22%

55%

84% 83% 86% 83% 86% 85%

98%

84%

0%

20%

40%

60%

80%

100%

No Action

LSR

Alt. A

LSR

Alt. B

LSR

Sub. B

LSR

Alt. C

LSR

Sub. C

LSR

Alt. D

HLBOHTA

PRMP

LSR

Owl Habitat LUAs Mature

or Structurally-complex (%)

2013 2223
332 | P a g e

Figure 3-62. Proportions of land use allocations in Mature Multi-layered Canopy or Structurally-complex 

structural stages through time

Note: LSR is only shown for Alternative B since developmental trajectory within LSR land use allocations is nearly identical 

between alternatives and the Proposed RMP. The Uneven-aged Timber Area, Moderate Intensity Timber Area, and Low Intensity 

Timber Area are only shown for Alt. B and the PRMP, since structural development in the Uneven-aged Timber Area is nearly 

identical among the action alternatives and the Proposed RMP, and the Moderate Intensity Timber Area in Alternatives B and D 

show very similar trends.

The Harvest Land Base in the No Action alternative would contain 38 percent in Mature Multi-layered 

Canopy and Structurally-complex structural stage conditions within 100 years. This is due to the 

interaction between starting age class distribution and minimum rotation age assumptions in the 

vegetation modeling for the Harvest Land Base in the No Action alternative. Having a substantial acreage 

of stands beyond the culmination of mean annual increment (CMAI) of net timber volume in land use 

allocations dedicated to two-aged management regimes would allow the BLM to implement long 

rotations right away. Reserving older forests in the action alternatives and the Proposed RMP would 

reduce BLM’s available acreage of older stands eligible for regeneration harvest, reducing average 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2013 2023 2033 2043 2053 2063 2113 2213

LUA Mature Multi-layered Canopy or Structurally-complex (%)

Year

No Action HLB Alt. A HITA Alt. B LITA Alt. B MITA

Alt. B UTA Alt. B LSR Alt. C HITA Alt. D OHTA

PRMP LITA PRMP MITA PRMP UTA

No Action HLB

Alt. B LSR

Alt. D OHTA

Alt. B UTA

PRMP UTA

PRMP MITA

PRMP LITA

Alt. A HITA Alt. C HITA Alt. B LITA

Alt. B MITA
333 | P a g e

regeneration harvest age for 100 years or more before the BLM could transition completely to longer 

rotations. See Table 3-48 for more details on regeneration harvest ages by decade, alternative and the 

Proposed RMP, and land use allocation.

In summary, the mix of silvicultural systems and harvesting practices applied will determine the future of 

the structural stage distribution within the decision area. Wildfire is projected to play a relatively small 

role in the creation of early seral structural stages when compared to timber harvest, especially in the 

coastal/north areas. Early Successional stands in the High Intensity Timber Area in Alternatives A and C 

would not contain structural legacies. There is a substantial difference in the structural complexity of most 

future stands when comparing even-aged management (e.g., clear-cutting) practices in the High Intensity 

Timber Area in Alternatives A and C, to two-aged practices (e.g., variable retention-regeneration harvest) 

in the No Action alternative, the Low Intensity Timber Area and Moderate Intensity Timber Area in 

Alternative B, Sub-alternative B, and the Proposed RMP, and the Moderate Intensity Timber Area in 

Alternative D.

Even-aged management with clear-cutting would result in relatively simple structured stands lacking 

legacy structures, while two-aged harvesting would produce stands with multiple layered canopies and 

legacy structures. Land use allocations dedicated to uneven-aged management regimes in the Harvest 

Land Base, the Uneven-aged Timber Area and Owl Habitat Timber Area, would eventually produce 

Mature Multi-layered Canopy and Structurally-complex stands in proportions equal to or greater than 

Late-Successional Reserve management. The structural stage development of the moist Late-Successional 

Reserve would be similar among all alternatives and the Proposed RMP. Retention of cut trees in 

Alternative A versus commercial removal in other alternatives and the Proposed RMP would not result in 

differences in structural stage development. The Harvest Land Base in the No Action alternative would 

contribute a higher proportion of Mature Multi-layered Canopy and Structurally-complex stands to the 

decision area when compared to the action alternatives and the Proposed RMP because there are 

substantial acreages of stands beyond CMAI of net timber volume in the Harvest Land Base. This would 

allow the BLM to implement long rotations right away, rather than the gradual trend towards longer 

rotations that would be required in the Moderate Intensity Timber Area and Low Intensity Timber Area in 

Alternative B, Sub-alternative B, and the Proposed RMP, and in the Moderate Intensity Timber Area in 

Alternative D.

Inventory of Merchantable Timber

The inventory of merchantable timber volume in the decision area has increased since 1940 (Table 3-51).

Table 3-51. The standing net timber inventory at each measurement period

Historic Estimates 1940 1960 1970 1980 1990 2006

Timber Volume (MMbf) 46,000 49,100 50,300 46,900 49,900 64,854

Acres Considered in Calculation 2,165,900 2,145,072 2,391,172 1,771,657 1,794,420 2,478,857

A combination of factors caused the large increase between the 1990 and 2006 inventory of timber 

volumes. These include—

 The increase in acres included in the determination of volume;

 The increase in growth and volume resulting from the increase in faster-growing, younger stands; 

and

 Harvest levels below the maximum potential annual productive capacity (Table 3-54 and Figure 

3-64).
334 | P a g e

Although these inventories were conducted using different inventory systems, different assumptions, and 

occurred on different portions of the BLM-administered lands, the inventories provide the basis for broad 

comparisons and general trends. These historical records of timber inventories show that overall growth 

on the BLM-administered lands has exceeded harvest levels, especially in the last two decades. Current 

standing net timber inventory based on 2013 data is approximately 13 percent higher than the 2006 

estimate, which reflects an average annual inventory increase of almost 2 percent per year since 2006 

(Table 3-52).

Table 3-52. 2006 and 2013 Scribner 16’ scale net standing timber volume MMbf inventory estimates

District/

Field Office

2006 Net Inventory

(MMbf)

2013 Net Inventory

(MMbf)

Coos Bay 11,358 13,036

Eugene 10,915 12,792

Klamath Falls 694 750

Medford 15,133 16,347

Roseburg 11,322 12,634

Salem 15,431 17,660

Totals 64,854 73,220

The amount of current timber inventory within the Harvest Land Base varies primarily with the extent of 

the Harvest Land Base under each alternative and the Proposed RMP. Alternative C contains the highest 

timber inventory within the Harvest Land Base of any alternative and the Proposed RMP, with 

approximately 24 billion board feet. Sub-alternative B has the lowest timber inventory within the Harvest

Land Base, with approximately 9 billion board feet. The current timber volume in the Harvest Land Base 

ranges between 13–33 percent of total timber inventory in the decision area among the alternatives and 

the Proposed RMP. Conversely, reserve land use allocations contain between 67–87 percent of total 

timber inventory (Figure 3-63).
335 | P a g e

Figure 3-63. 2013 and 2113 net inventory broken out between the Harvest Land Base and reserves in the decision area

49

98

62

123

55

104

63

125

48

89

60

107

51

94

59

114

23

33

10

9

17

24

9

14

24

22

12

13

21

44

13

19

0

20

40

60

80

100

120

140

2013 2113 2013 2113 2013 2113 2013 2113 2013 2113 2013 2113 2013 2113 2013 2113

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

2013/2113 Net Timber Inventory (Billion Board Feet)

Reserve Harvest Land Base
336 | P a g e

The timber inventory would increase under all alternatives and the Proposed RMP. This is mostly due to 

timber volume accumulation in the reserve land use allocations. Timber volume would increase between 

58-100 percent in the reserves over the next 100 years, since the BLM would only be harvesting timber to 

achieve restoration purposes.

Table 3-53. Percent change in inventory between 2013 and 2113 broken out between the Harvest Land 

Base and reserves in the decision area

Inventory

No Action

(Percent 

Change)

Alt. A 

(Percent 

Change)

Alt. B 

(Percent 

Change)

Sub. B 

(Percent 

Change)

Alt. C 

(Percent 

Change)

Sub. C 

(Percent 

Change)

Alt. D 

(Percent 

Change)

PRMP 

(Percent 

Change)

Reserve 100% 99% 88% 96% 86% 78% 86% 58%

Harvest 

Land Base 45% -13% 37% 56% -9% 6% 108% 12%

Overall 82% 83% 76% 91% 54% 66% 92% 44%

Note: Positive numbers indicate inventory increase, while negative numbers indicate inventory decrease.

The timber inventories in the Harvest Land Base would slightly decline in Alternatives A and C; they 

would remain relatively stable in Sub-alternative C, because of shorter rotations and even-aged timber 

harvest in the majority of the Harvest Land Base. In these alternatives, the BLM would convert suboptimal timber production stands in the High Intensity Timber Area into fully stocked stands near the 

maximum timber production potential. The BLM would only hold the minimum inventory on the Harvest 

Land Base to ensure long-term sustainability of the timber harvest regime.

The timber inventory would increase in the Harvest Land Base under the No Action alternative, 

Alternative B, Sub-alternative B, the Proposed RMP, and, to the largest extent, Alternative D. For the No 

Action alternative, the modeling assumptions scheduling regeneration harvest at the CMAI of net harvest 

volume would interact with the modeling assumption for non-declining even flow to cause inventories to 

substantially increase on some districts. The Harvest Land Base inventory increases in Alternatives B and 

D, Sub-alternative B, and the Proposed RMP, is partly explained by the modeling assumptions guiding 

the transition to longer rotations on a relatively young Harvest Land Base, which would require an 

increase in the standing inventory on those stands as they age into the desired age classes for regeneration 

harvest. Appendix C contains more information on the modeling assumptions used for each alternative 

and the Proposed RMP.

Another contributing factor leading to the inventory increase in the Harvest Land Base in these 

alternatives and the Proposed RMP is the implementation of uneven-aged management regimes. The 

BLM would implement selection harvesting to achieve desired stand conditions in the Uneven-aged 

Timber Area in all the action alternatives and the Proposed RMP, and in the Owl Habitat Timber Area in 

Alternative D. Volume accumulation would outpace harvest until the desired conditions were reached, 

which could take 100 years or more, and then the inventory would flatten out as those conditions are 

maintained, where from that point forward timber harvest would equal growth. Since 75 percent of the 

Harvest Land Base would be in land use allocations dedicated to uneven-aged management regimes in 

Alternative D, this net inventory would increase more than any other alternative or and the Proposed 

RMP with a 108 percent increase in net timber inventory in the next 100 years (Table 3-53 and Figure 3-

63).

In summary, all alternatives and the Proposed RMP would result in an overall increase in net timber 

inventory of between 44 percent (Proposed RMP), and 92 percent (Alternative D) in the next 100 years. 

The net timber inventory in reserve land use allocations would increase more than 58 percent in all 
337 | P a g e

alternatives and the Proposed RMP. Net timber inventories in the Harvest Land Base in Alternatives A 

and C would remain stable or slightly decrease in the next 100 years as the High Intensity Timber Area 

land use allocation would transition into a fully regulated relatively short-rotation forest. Net timber 

inventories in the Harvest Land Base in the No Action alternative, Alternatives A, B, and D, Subalternative B, and the Proposed RMP would increase between 12 percent (Proposed RMP) and 108 

percent (Alternative D). The increase in net timber inventories in Alternatives B and D, and the Proposed 

RMP is due to the combination of the modeling assumptions guiding the transition of younger forests to 

long rotations and the implementation of uneven-aged management regimes. The increase in inventory in 

the No Action alternative’s Harvest Land Base is explained primarily by the combination of the nondeclining timber flow modeling assumption with the assumption that stands meet CMAI of net timber 

volume prior to implementing regeneration harvest, which causes inventories on some districts to increase 

substantially.

Issue 2

What would be the annual productive capacity for sustained-yield timber production under each 

alternative? How would different intensities of forest management and restrictions on timber harvest in 

the Harvest Land Base influence the annual productive capacity?

Analytical Methods

Through the RMPs, the BLM will determine and declare the annual productive capacity for sustainedyield timber production or allowable sale quantity (ASQ).

58 The ASQ is the annual timber volume that a 

forest can produce continuously under the intensity of management described in each alternative and the 

Proposed RMP for those lands allocated for sustained-yield timber production (i.e., the Harvest Land 

Base). The calculation of the ASQ is a direct output from the vegetation modeling analysis for each 

alternative and the Proposed RMP and would vary based on the timing and intensity of timber harvest, 

silvicultural practices, and restrictions on timber harvest in the Harvest Land Base. Because the ASQ 

volume reflects the capacity for sustained-yield timber production, it would not decline over time.

In contrast to the ASQ volume, timber volume produced as a by-product of silvicultural treatments in 

reserve land use allocations (i.e., non-ASQ volume) would change over time and eventually decline in 

moist forest areas. The calculation of the non-ASQ volume for each alternative and the Proposed RMP is 

also a direct output from the vegetation modeling, but reflects modeling assumptions about the intensity 

and extent of thinning or selection harvesting needed to achieve the management objectives of the reserve 

land use allocations.

The BLM calculated the ASQ and non-ASQ volume for each of the six sustained-yield units, which 

match the five western Oregon BLM district boundaries and the western portion of the Klamath Falls 

Field Office.

The vegetation modeling included forecasting future discovered marbled murrelet sites and North Coast 

Distinct Population Segment (DPS) red tree vole sites under alternatives and the Proposed RMP where 

surveys would occur. Under these alternatives and the Proposed RMP, the BLM would remove acres 

associated with discovered sites from the Harvest Land Base and manage them, instead, as LateSuccessional Reserve. Therefore, these acres would no longer contribute to the ASQ volume. See the 

Wildlife section in this chapter for more detail on site management for these species. In the vegetation 

modeling, these forecasted discovered sites were calculated using prediction rates, and acres the model 

 

58 The terms ‘annual productive capacity,’ ‘annual sustained yield capacity,’ and ‘allowable sale quantity’ are 

synonymous.
338 | P a g e

predicted as future discovered sites were not included in the contributions to the calculation of sustainedyield timber harvest.

The forecasting of future marbled murrelet sites required slightly different methodologies for the No 

Action alternative, the action alternatives, and the Proposed RMP, and inherently includes substantial 

uncertainty. The modeling of future marbled murrelet sites in the No Action alternative assumed all 

stands currently 120-years old and older in Matrix and Adaptive Management Areas within 35 miles of 

the coast were occupied by marbled murrelets and reserved from timber harvest. The modeling assumed 

stands currently less than 120-years old in the Matrix and Adaptive Management Area were not occupied 

by marbled murrelets, even those stands that would become 120-years old or older during the modeling 

period. The modeling also assumed no stands greater than 35 miles from the coast were occupied by 

marbled murrelets. The assumption of all stands currently 120-years old and older within 35 miles of the 

coast are occupied by marbled murrelets is likely an overestimation, and the assumption that no stands 

currently less than 120-years old and no stands greater than 35 miles from the coast are occupied by 

marbled murrelets is likely an underestimation. Overall, the forecasting of future marbled murrelet sites 

for the No Action alternative likely underestimates the acres that would be reserved from timber harvest 

and consequently overestimates the ASQ. However, the BLM lacks sufficient data at this time to refine 

these assumptions about the No Action alternative or quantitatively describe the overestimation of ASQ. 

The BLM used this age-based assumption for future occupancy, because the No Action alternative, in 

contrast to the action alternatives and the Proposed RMP, includes harvest of older, more structurallycomplex forest, which provides the highest quality marbled murrelet nesting habitat.

Because all of the action alternatives and the Proposed RMP would reserve older, more structurallycomplex forest, the forecasting of future marbled murrelet sites within the Harvest Land Base focused on 

younger stands than the forecasting for the No Action alternative. Therefore, this analysis used a different 

methodology for the action alternatives and the Proposed RMP, which extrapolated from previous 

marbled murrelet survey results using the proportion of survey stations that had marbled murrelet 

occupancy. This approach has the advantage of using consistent data that is currently available across the 

entire decision area. The station-based methodology provided an estimation of marbled murrelet sites 

based on the existing BLM corporate data, from the perspective of analyzing the effects on marbled 

murrelets. This methodology may underestimate the acres reserved from timber harvest under an action 

alternative and the Proposed RMP that includes surveys for marbled murrelet sites and reserves occupied 

sites. Estimating the acres of occupied marbled murrelet habitat is not the same as estimating the acres 

reserved from timber harvest around an occupied site. Much of the difficulty in developing an effective 

methodology for analysis is in translating a positive survey result into an estimation of acres reserved 

from timber harvest. The station-based methodology provides an estimate for the purpose of analyzing the 

effects on marbled murrelets, but may underestimate the effects on timber harvest. However, the BLM 

lacks sufficient data at this time to describe quantitatively the uncertainty associated with ASQ estimates 

in the alternatives and the Proposed RMP that would require protection of future marbled murrelet sites.

Additionally, the detection rates that the BLM used to calculate acres by land use allocation reported in 

Chapter 2, and impacts to timber harvest in Alternatives A, B, and D, and Sub-alternatives B and C (24.4 

percent 0–25 miles from the coast, and 5.6 percent 25–50 miles from the coast) are different than the 

detection rates the BLM used for these analyses in the Proposed RMP (54.8 percent 0–25 miles from the 

coast, and 10.2 percent 25–50 miles from the coast). The BLM updated marbled murrelet detection rates 

for the Proposed RMP to reflect recent survey results, in order to produce a more refined estimate of 

timber harvest volume. The BLM used the revised detection rates consistently across the action 

alternatives and the Proposed RMP in the Wildlife section in this chapter to analyze effects to marbled 

murrelets.
339 | P a g e

Under the No Action alternative, the BLM would conduct surveys to locate and manage for all 

populations of the Oregon red tree vole, not just the North Coast DPS of the red tree vole. The BLM did 

not quantitatively forecast the loss of Harvest Land Base area to future red tree vole sites in the vegetation 

modeling for the No Action alternative, and therefore likely overestimates the ASQ for this alternative. 

There is substantial variability in the detection rates of red tree voles and management requirements for 

detected red tree vole sites, which complicate any attempt to forecast the effects of future red tree vole 

sites on the ASQ under the No Action alternative. This analysis uses decision area-wide detection rates 

based on protocol surveys between 2000 and 2012 on BLM-administered lands irrespective of habitat 

condition outside of vegetation modeling. Detection rates range from 16.7 percent in the Salem District to 

76.1 percent in the Coos Bay District, with an average of 42.1 percent for the decision area. The BLM 

uses the assumption that 40 percent of stands with red tree vole detections would be unavailable for longterm sustained-yield timber harvest, in order to bracket the potential effects of red tree vole site 

management on the ASQ for the No Action alternative. This estimate is not included in Table 3-55, but is 

shown in Table 3-56

In order to calculate estimated reductions to ASQ levels from predictions of red tree voles and marbled 

murrelet site occupancy and protection in all alternatives and the Proposed RMP, the number of acres 

where timber harvest was precluded was determined using geographic information system (GIS) analysis. 

The BLM then performed GIS analysis to determine which Harvest Land Base sub-allocation those acres 

of forested land would have been in had the BLM not predicted occupancy. The BLM then multiplied 

those acres by the expected board feet per acre per year ASQ contribution estimated for that suballocation and region based on values derived for Figure 3-65. This methodology produced an estimated 

ASQ reduction for each alternative and the Proposed RMP for predictions of site protection associated 

with red tree voles and marbled murrelets reported in Table 3-56.

A similar methodology was also used to determine the ASQ reductions associated with northern spotted 

owl site protection in Alternative D, where areas were mapped as Owl Habitat Timber Area or LateSuccessional Reserve where needed to maintain spotted owl habitat around known, historic, and alternate 

sites. The BLM used GIS analysis to determine how many acres of Owl Habitat Timber Area or LateSuccessional Reserve were mapped due to proximity of northern spotted owl sites, and the BLM 

estimated how many acres would have otherwise been mapped as either Uneven-aged Timber Area or 

Moderate Intensity Timber Area. The difference in productive contribution of those acres were used to 

calculate the estimated ASQ reduction associated with northern spotted owl site management in 

Alternative D, reported in Table 3-56. In Sub-alternative B, the impacts to ASQ from northern spotted 

owl site protection were reported directly, since this was the single difference between this sub-alternative 

and Alternative B. Since the BLM made these deductions to the Harvest Land Base in the vegetation 

modeling, ASQ values reported in Table 3-55 include them, with the exception of red tree vole 

management in the No Action Alternative.

The BLM also made deductions to long-term yields based on both area lost and reduced growth and yield 

due to road construction and detrimental soil disturbances, endemic levels of insects and disease, defect 

and breakage, snag and downed wood requirements, and other factors. The Vegetation Modeling section 

earlier in this chapter and Appendix C provide more information on the calculations of ASQ and nonASQ timber volume.

Background

The BLM has implemented timber harvest levels and a mix of harvest types that has differed from those 

anticipated in the 1995 RMPs. Specifically; the BLM has implemented less regeneration harvest and more 

commercial thinning (Figure 3-64). In 2012, the BLM conducted an evaluation of the 1995 RMPs in 

accordance with its planning regulations, and concluded that continuation of these trends in timber 
340 | P a g e

harvest practices is not sustainable at the declared ASQ level. Implementation of timber harvest since the 

adoption of the 1995 RMPs is described in detail in the BLM plan evaluations and is incorporated here by 

reference (USDI BLM 2012, pp. 6–12, and Appendices 3–8).

Figure 3-64. Assumed vs. implemented annual average sold timber volume levels and mix of harvest 

types, 1995 through 2012, in the Harvest Land Base (HLB) and Reserves in the decision area

The 1995 through 2010 data in Figure 3-64 comes from district data requests for the 2012 plan 

evaluations. 2011 and 2012 data was generated from Forest Resource Information System data entered 

through 23 October 2014. Due to continual updates and data correction, these estimates may be different 

from other estimates generated at different times or from different sources.

Affected Environment and Environmental Consequences

The BLM performed a reference analysis of “Manage most commercial lands for maximizing timber 

production” in the 2008 FEIS (USDI BLM 2008, pp. 573–574) and that analysis is incorporated here by 

reference. This reference analysis evaluated the outcomes if all BLM-administered lands in the planning 

area capable of producing a long-term flow of commercial timber volume would be managed under 

intensive forest management, without regard for the requirements of other laws or the purpose and need 

for action. The results of this reference analysis concluded that the BLM-administered lands in the 

planning area are capable of producing approximately 1.2 billion board feet per year. Although there have 

been some changes in the decision area that would slightly alter these calculations resulting from timber 

harvest and growth since the calculations in the 2008 FEIS, these results provide an approximate outcome 

that is still relevant for the decision area.

157

54

16

48

66

112

0

14

73

0

25

50

75

100

125

150

175

200

225

1995 RMP Assumption 1995-2003 Average 2004-2012 Average

Annual Average Timber Volume Sold 

(MMbf)

HLB (ASQ) Regeneration Harvest HLB (ASQ) Thinning Reserve (Non-ASQ) Thinning
341 | P a g e

Table 3-54. Reference analysis: “Manage Most Commercial Lands for Maximizing Timber Production” 

and 1995 RMP declared ASQ

District/

Field Office

Scribner 16’ Scale (MMbf Per Year)

Reference Analysis ASQ 1995 RMP Declared ASQ

Coos Bay 257 27

Eugene 273 33

Klamath Falls 10 6

Medford 174 57

Roseburg 198 45

Salem 289 35

Totals 1,201 203

The 1995 RMPs declared ASQ levels for each of the sustained-yield units (Table 3-54). The ASQ for the 

No Action alternative calculated here (277 MMbf) is substantially higher than the ASQ declared in the 

1995 RMPs (203 MMbf) because of improvements in data and changes in forest conditions since 1995. 

Improved field validation and mapping of stream classification and fish presence has revealed that the 

analysis for the 1995 RMPs overestimated the extent of the Riparian Reserve and thereby underestimated 

the extent of the area available for sustained-yield timber production. In addition, new inventory data, 

revised growth and yield information, and increases in timber inventory in the decision area since 1995 

have increased the calculation of the ASQ under the No Action alternative. This is consistent with the 

conclusion in the 2008 FEIS, which calculated the ASQ for the No Action alternative to be 268 MMbf 

(USDI BLM 2008, p. 575), and that discussion is incorporated here by reference.

Alternative C would have the highest ASQ among the alternatives and the Proposed RMP, followed by 

Sub-alternative C, and the No Action alternative (Table 3-55). Major factors determining the ASQ 

include the size of the Harvest Land Base, the intensity of forest management practices, and restrictions 

on timber harvest (e.g., wildlife site protection, Visual Resource Management, and recreation 

management).

Table 3-55. First decade annual ASQ* timber harvest (MMbf/year Scribner 16’ scale) 59

District/

Field Office

No Action 

(ASQ)†

Alt. A 

(ASQ)

Alt. B 

(ASQ)

Sub. B 

(ASQ)

Alt. C 

(ASQ)

Sub. C 

(ASQ)

Alt. D 

(ASQ)

PRMP 

(ASQ)

Coos Bay 46 46 23 14 82 66 22 12

Eugene 58 63 56 25 138 103 45 53

Klamath Falls 8 3 7 4 10 3 5 6

Medford 73 27 42 15 54 24 28 37

Roseburg 55 25 35 14 78 51 22 32

Salem 37 71 71 47 124 85 54 65

Totals 277 234 234 120 486 332 176 205

* Reported ASQ volumes are rounded to the nearest MMbf, so there are minor errors associated with rounding.

† The BLM has made no deduction in the vegetation modeling for reductions due to management of future Survey and Manage

sites. This and other issues place uncertainty around the expression of ASQ for the No Action alternative.

 

59 These ASQ estimates for the alternatives and the Proposed RMP include modeled timber salvage from the first 

decade based on BLM’s simulation of wildfire and subsequent timber salvage. Given the unpredictable nature of 

wildfire and timber salvage, the eventual declaration of the ASQ will include an average of simulated salvage 

volume over the first five decades to account for this uncertainty. Therefore, the eventual declaration of ASQ may 

be slightly different from what is reported here.
342 | P a g e

Size of the Harvest Land Base

The size of the Harvest Land Base is dependent on a number of factors including Riparian Reserve widths 

and the size of the Late-Successional Reserve, including the threshold for protection of older, more 

structurally-complex forest, and the protection of future reserved sites for some wildlife species under 

some of the alternatives and the Proposed RMP. Chapter 2 contains a description of the design of each 

alternative and the Proposed RMP and a description of the acreage in each land use allocation. The 

Harvest Land Base under Alternative C would be the largest (30 percent of the decision area) and Subalternative B the smallest (12 percent of the decision area). The Harvest Land Base under the Proposed 

RMP would be 20 percent of the decision area. Predicted marbled murrelet and red tree vole sites are not 

included in the calculation of Harvest Land Base size.

Sub-alternative B would be identical to Alternative B, except that it would include protection of habitat 

within the home ranges of all northern spotted owl known, alternate, and historic sites that would be 

within the Harvest Land Base in Alternative B. This single change in design reduces the Harvest Land 

Base from 22 to 12 percent of the decision area, which is smaller than any other alternative or the 

Proposed RMP. This difference in the size of the Harvest Land Base reduces the ASQ in Sub-alternative 

B by 114 MMbf per year from the ASQ in Alternative B.

Although the size of the Harvest Land Base has an important influence on the ASQ, it does not entirely 

determine the ASQ. For example, Alternatives A and B have almost identical ASQ levels, but the size of 

the Harvest Land Base would differ substantially (14 percent and 22 percent, respectively). Nevertheless, 

the size of the Harvest Land Base determines the number of acres of eligible forest stands that would be 

available for harvesting to meet the declared ASQ. Therefore, all other things held equal, the larger the 

Harvest Land Base, the higher the ASQ.

Intensity of Forest Management Practices

The more intensive the forest management practices applied, the more timber volume produced on a 

given acre of ground within a fixed unit of time. Figure 3-65 shows a breakdown of calculated timber 

production rates by management intensity for the coastal/north areas, which generally have higher 

productivity lands, and the interior/south areas, which generally have lower productivity lands.
343 | P a g e

Figure 3-65. Timber production rates by management intensity (board feet per acre per year), broken out 

between coastal/north and interior/south areas

The highest timber yields per acre would come from the High Intensity Timber Area, because of evenaged management regimes including relatively short rotations, clear-cutting, rapid reforestation, 

fertilization, and control of competing vegetation. For every acre of High Intensity Timber Area in the 

Harvest Land Base, the ASQ contribution would be approximately 917 board feet per year in the 

coastal/north area, and 556 board feet per year in the interior/south areas.

The second-highest timber yields per acre would come from lands managed under two-aged management 

regimes, which includes variable-retention regeneration harvesting. This category includes the Matrix60

and Adaptive Management Areas in the No Action alternative, the Moderate Intensity Timber Area and 

Low Intensity Timber Area in Alternative B, Sub-alternative B, and the Proposed RMP, and the Moderate 

Intensity Timber Area in Alternative D. The reduction in timber yield per acre in these land use 

allocations compared to the High Intensity Timber Area would result from the retention of a portion of 

the stand during regeneration harvest and the trend towards longer rotations (Birch and Johnson 1992, 

Long and Roberts 1992). The overstory retention in these land use allocations would also suppress the 

growth rates of regenerated trees compared the High Intensity Timber Area, but this effect would be 

highly variable, and in part dependent on the arrangement of retention trees (Di Lucca et al. 2004, 

Temesgen et al. 2006, Urgenson et al. 2013). It is not possible at this scale of analysis with the data 

available to quantify the effects of varying levels of retention on the growth of the regenerating stand. The 

 

60 The Matrix in the No Action alternative includes the General Forest Management Area, and 

Connectivity/Diversity Blocks, which identify differing levels of tree retention and other practices in regeneration 

harvest.

917

719 704

447

280

556

332

450

205

124

0

100

200

300

400

500

600

700

800

900

1,000

HITA

Even-aged

Management

No Action

HLB

Two-aged

Management

MITA/LITA

Two-aged

Management

UTA

Fire Resiliency

Uneven-aged

Management

OHTA

NSO Habitat

Uneven-aged

Management

Timber Production (Board Feet per Acre per Year)

Coastal/North Interior/South
344 | P a g e

effects of varying retention levels in these land use allocations would also influence the timber yield per 

acre somewhat.

Nevertheless, for every acre of Moderate Intensity Timber Area or Low Intensity Timber Area land use 

allocations is in the Harvest Land Base in the action alternatives and the Proposed RMP, the ASQ 

contribution would average 704 board feet per year in the coastal/north area, and 450 board feet in the 

interior/south. For the No Action alternative, the ASQ contributions would be 719 board feet per acre per 

year in the coastal/north area, and 332 board feet per year in the interior/south. The reason the 

contribution from the interior/south is lower in the No Action alternative is that a substantial acreage of 

dry forest stands in the Harvest Land Base in the action alternatives and the Proposed RMP would be 

managed using uneven-aged management in the Uneven-aged Timber Area. In the No Action alternative, 

these dry forest stands are contained in lands dedicated to regeneration harvesting regimes. The dry 

forests tend to be lower productivity, thereby pulling the average production rate down in the 

interior/south in the No Action alternative.

Alternative B includes different reforestation practices after regeneration harvest than the other 

alternatives and the Proposed RMP. In the Moderate Intensity Timber Area in Alternative B, the BLM 

would delay canopy closure for at least three decades after regeneration harvest, in order to prolong and 

enhance the early successional stage of forest development. In the Low Intensity Timber Area in 

Alternative B, the BLM would rely on natural reforestation after regeneration harvest (i.e., natural seeding 

rather than planting). In all other alternatives and the Proposed RMP, the BLM would ensure rapid 

reforestation following regeneration harvest, consistent with current practices. There is no apparent 

difference in timber yields between delayed canopy closure in the Moderate Intensity Timber Area in 

Alternative B and prompt canopy closure in the other alternatives, including the Moderate Intensity 

Timber Area in Alternative D. The average delay in canopy closure in the Moderate Intensity Timber 

Area in Alternative B would be 10–15 years beyond what would typically occur with standard 

reforestation practices. This would theoretically delay attainment of timber merchantability and thereby 

reduce overall timber yield per acre (Miller et al. 1993). However, any effect of delaying timber harvest 

in the Moderate Intensity Timber Area would be diluted by the trend towards longer rotation lengths that 

would occur in the Moderate Intensity Timber Area. Additionally, there are so many factors affecting the 

varying timber yield per acre among the alternatives and the Proposed RMP that it is not possible to 

isolate the effect of this single factor.

The Low Intensity Timber Area would produce an average of 18 percent less timber yield per acre than 

the Moderate Intensity Timber Area in Alternative B, because of the higher level of retention and 

projected reforestation failures after regeneration harvest. Based on evaluation of past natural 

reforestation, the BLM concludes that an average of 10 percent of each regeneration harvest unit in the 

Low Intensity Timber Area would fail to reforest, 30 percent would reforest at very low levels of 

stocking, and 60 percent would reforest at target stocking levels. Appendix C contains more details about 

assumptions related to reforestation rates. Reforestation failures would eliminate future timber harvest 

opportunities; reforestation at very low levels of stocking would preclude commercial thinning 

opportunities. In addition to reductions in timber yield from reforestation failures in the Low Intensity 

Timber Area, the reliance on natural reforestation would limit the ability to manage the species 

composition of the regenerating stand. This would also preclude replanting stands with disease-resistant 

trees, such as rust-resistant sugar pine or root disease-resistant Port-Orford-cedar. This reliance on natural 

reforestation would also preclude the ability of the BLM to shift tree species composition or tree 

genotypes within stands to adapt to changing climate conditions (see the Climate Change section in this 

chapter). Since prompt reforestation using natural or artificial reforestation would be allowed under the 

Proposed RMP in the Low Intensity Timber Area and Moderate Intensity Timber Area, the only expected 

differences in timber yield between these two Harvest Land Base sub-allocations would come from the 
345 | P a g e

additional post-harvest retention requirements (15–30 percent basal area retention in the Low Intensity 

Timber Area and 5–15 percent basal area retention in the Moderate Intensity Timber Area).

The third-highest timber yields per acre would come from the uneven-aged management in the Unevenaged Timber Area, which is included in all action alternatives and the Proposed RMP. In this suballocation, the continuous retention of substantial portions of the stand would reduce the timber yields 

compared to the yields under regeneration harvest. For every acre of Uneven-aged Timber Area in the 

Harvest Land Base, the ASQ contribution would be approximately 447 board feet per year in the 

coastal/north area, or 205 board feet in the interior/south area.

The lowest timber yields per acre would come from uneven-aged management in the Owl Habitat Timber 

Area in Alternative D. In this sub-allocation, the continuous retention of substantial portions of the stand 

would reduce the timber yields, as in the Uneven-aged Timber Area. However, timber harvest would be 

further limited in the Owl Habitat Timber Area to meet direction to develop and then maintain northern 

spotted owl habitat function at the stand level, limiting the intensity of harvest and the size of openings, 

further reducing timber yield compared to the Uneven-aged Timber Area. Appendix B contains more 

details on management objectives and direction for each sub-allocation. For every acre of Owl Habitat 

Timber Area, the ASQ contribution would be approximately 280 board feet per year in the coastal/north 

area, or 124 board feet in the interior/south area.

The varying timber yield per acre of the different sub-allocations demonstrates the influence the intensity 

of forest management practices has on the ASQ. This influence on the ASQ can be as important as the 

size of the Harvest Land Base. For example, Alternative A has almost the same ASQ as Alternative B 

even though it has a much smaller Harvest Land Base because of the more intensive forest management 

practices in Alternative A. Alternative D, which has a larger Harvest Land Base than Alternatives A and 

B, and the Proposed RMP, has a lower ASQ because forest management practices would be less 

intensive.

Restrictions on Timber Harvest

The alternatives contain various potential restrictions on timber harvest in the Harvest Land Base that 

could influence the calculation of the ASQ. The restrictions in the action alternatives and the Proposed 

RMP include site protection for northern spotted owls, protection of future marbled murrelet sites, 

protection of future North Coast DPS red tree vole sites, management of Wild and Scenic Rivers, Visual 

Resource Management, and Recreation Management Areas. The calculation of the ASQ in this analysis 

predicted the quantitative effects of some of these potential restrictions. However, other potential 

restrictions are too uncertain to incorporate into the calculation of the ASQ. As a result, there are varying 

levels of uncertainty about the calculation of the ASQ among the alternatives and the Proposed RMP 

because of these potential restrictions on timber harvest, as detailed below.

The No Action alternative includes a variety of restrictions on timber harvest in the Matrix and Adaptive 

Management Areas, including protection of known spotted owl activity centers, protection of future 

marbled murrelet sites, Survey and Manage protections, and the retention of old-growth fragments in 

watersheds where little remains. The effects of implementation of these restrictions on timber harvest 

levels are difficult to forecast, especially the Survey and Manage protections. The 2004 Final 

Supplemental EIS to Remove of Modify the Survey and Manage Mitigation Measure Guidelines 

discussed the difficulties in evaluating the effect of the Survey and Manage measures on timber harvest 

and provided estimates (USDA FS and USDI BLM 2000, pp. 428–438), and those discussions are 

incorporated here by reference. Because of the difficulty in forecasting future site abundances and 

locations for Survey and Manage species and the uncertainty of specific site management approaches, the 

BLM did not attempt to forecast restrictions on timber harvest within the Matrix and Adaptive 

Management Areas in the vegetation modeling. Red tree vole detection rates across the decision area 
346 | P a g e

between 2000 and 2012 irrespective of habitat condition are 42.1 percent. Assuming that 40 percent of 

stands in the Harvest Land Base where red tree voles are found become unavailable for long-term 

sustained yield timber production, this indicates that ASQ levels in Table 3-55 for the No Action 

Alternative are 16.8 percent, or 47 MMbf/year too high (Table 3-56). Since the BLM did not include this 

assumption in vegetation modeling for the No Action alternative, the BLM believes that the ASQ 

predictions in Table 3-55 for the No Action alternative are an overestimate. For the Adaptive 

Management Areas, the 1995 RMPs specifically directed developing and testing unspecified approaches 

to timber harvest and restrictions on timber harvest, lending considerable uncertainty to timber harvest 

levels within the Adaptive Management Areas.

Table 3-56. Estimated reductions to annual ASQ from wildlife surveys and site protection

Alternative/

Proposed 

RMP

Marbled 

Murrelet

(MMbf/Year)

Northern Spotted 

Owl Site 

Management

(MMbf/Year)

Red Tree 

Vole*

(MMbf/Year)

Survey and 

Manage†

(MMbf/Year)

Totals

(MMbf/Year)

No Action 4 - 47 Unknown > 51

Alt. A - - - - -

Alt. B 6 - 6 - 12

Sub. B 6 115 6 - 127

Alt. C 2 - - - 2

Sub. C - - - - -

Alt. D 29 57 4 - 90

PRMP 14 - 4 - 18

* The potential 47 MMbf per year reduction in ASQ for the No Action alternative due to future Survey and Manage red tree vole 

site management shown in Table 3-56 was not deducted from the estimate of ASQ in Table 3-55. For the action alternatives and 

the Proposed RMP, red tree vole management and site protections varied around the North Coast DPS red tree vole population 

only. The estimated reductions to annual ASQ shown in this table for the action alternatives and the Proposed RMP are deducted 

from estimates of ASQ shown in Table 3-55.

† All other species on the Survey and Manage lists, including fish and plants

Northern Spotted Owl

Sub-alternative B includes protection of habitat within the home ranges of all northern spotted owl known 

and historic sites that would be within the Harvest Land Base in Alternative B, as described above. This 

would reduce the ASQ by approximately 115 MMbf per year (Table 3-56). Alternative D includes 

protection of habitat within the nest patch of all northern spotted owl known and historic sites, and sets 

thresholds for habitat within core areas and home ranges of all known and historic sites, limiting timber 

harvest. The BLM estimates that the combination of these two approaches to site management in 

Alternative D reduces the ASQ by 57 MMbf. None of the other action alternatives or the No Action 

alternative would require specific site management for known or historic northern spotted owl sites in the 

Harvest Land Base. 

Under the Proposed RMP, the BLM would not authorize timber sales that would cause the incidental take 

of northern spotted owl territorial pairs or resident singles from timber harvest until implementation of a 

barred owl management program consistent with the assumptions contained in the Biological Opinion on 

the RMP has begun. The BLM assumes that the barred owl management program would begin within 

approximately 5 years of the signing of the Record of Decision, and subsequently the BLM would remove 

the prohibition on incidental take of northern spotted owl territorial pairs or resident singles resulting 

from timber sales. Given this assumption, northern spotted owl site management would not reduce longterm sustained yield from the Harvest Land Base in the Proposed RMP. Under the Proposed RMP, 
347 | P a g e

avoiding incidental take of northern spotted owls from timber harvest would require avoiding timber 

harvest or reducing the intensity of timber harvest of nesting-roosting habitat within the home ranges of

most occupied northern spotted owl sites (depending on the quantity of nesting-roosting habitat within the 

home range). There is sufficient flexibility in scheduling the order in which stands would be harvested in 

the Harvest Land Base during the first half of the first decade of RMP implementation to avoid harvest 

that would result in incidental take of northern spotted owls without reducing the long-term sustained 

yield. This conclusion assumes that stands in the Harvest Land Base that the BLM would avoid 

harvesting during the first half of the first decade would be available for timber harvest in subsequent 

years. During the first half of the first decade of RMP implementation, the BLM would be able to conduct 

timber harvest that would not result in incidental take of northern spotted owls (e.g., by harvesting in 

stands that are not nesting-roosting habitat, in stands outside of occupied northern spotted owl sites, and

in stands within occupied northern spotted owl sites with sufficient habitat above threshold amounts, or 

by reducing the intensity of timber harvest to maintain nesting-roosting habitat). Because of the 

availability of stands in which harvest would not result in incidental take of northern spotted owls and the 

temporary duration on the avoidance of incidental take of northern spotted owls, the requirement to avoid 

incidental take of northern spotted owls from timber harvest until a barred owl management program has 

begun would not reduce the long-term sustained yield from the Harvest Land Base in the Proposed RMP.

Marbled Murrelet

All alternatives and the Proposed RMP, except Alternative A and Sub-alternative C require marbled 

murrelet surveys prior to habitat disturbing activities and site protection for newly discovered sites in a 

portion or the entirety of the range of the marbled murrelet in the decision area. The effect of protection of 

future marbled murrelet sites on the ASQ would vary with the extent of the Harvest Land Base subject to 

surveys and the extent of protection around newly discovered sites. Marbled murrelet surveys and site 

protection would have the greatest effect on the ASQ in Alternative D, which would require surveys in 

marbled murrelet Zones 1 and 2 and protection of habitat within 0.5 miles around newly-discovered 

occupied sites, with an estimated ASQ reduction of 29 MMbf per year. Alternatives B and C, Subalternative B, and the Proposed RMP would require surveys in marbled murrelet Zone 1 only, and 

protection of habitat within 300 feet around newly discovered occupied sites. The effect of this protection 

on the ASQ is predicted to be relatively small in Alternative B and C, and Sub-alternative B, compared to 

the Proposed RMP because, as discussed above, these alternatives model a lower detection probability 

rate (i.e., 24.4 percent 0–25 miles from the coast, and 5.6 percent 25–50 miles from the coast) than the 

Proposed RMP (i.e., 54.8 percent 0-25 miles from the coast, and 10.2 percent 25–50 miles from the 

coast). This explains the more-than-double ASQ reduction under the Proposed RMP from Alternative B 

when there are very similar Harvest Land Base acres and survey and protection requirements between 

them. The small reduction in ASQ projections in the No Action alternative relative to the action 

alternatives is due, in part, to the difference in modeling methodology used, as discussed above.

Red Tree Vole

Alternatives B and D, and Sub-alternative B require surveys prior to habitat-disturbing activities and site 

protection for newly discovered sites for the North Coast DPS red tree vole. The Proposed RMP requires 

surveys and site protection for the North Coast DPS red tree vole north of Highway 20 only. The site 

protection in these alternatives and the Proposed RMP would reduce the acres in the Harvest Land Base, 

thereby reducing the ASQ. Protection around newly discovered North Coast DPS red tree vole sites 

would reduce the ASQ in Alternative B and Sub-alternative B by 6 MMbf per year, and in Alternative D 

and the Proposed RMP by 4 MMbf per year. Red tree vole surveys and protection are required across the 

decision area in the No Action alternative under Survey and Manage measures and the potential 

reductions to the ASQ were not built into the vegetation modeling (Table 3-56).
348 | P a g e

Wilderness Characteristics

The alternatives and the Proposed RMP vary in the protection of lands identified with wilderness 

characteristics outside of designated Wilderness Areas (see the Lands with Wilderness Characteristics 

section of this chapter). However, the alternatives do not include the protection of lands identified with 

wilderness characteristics in the Harvest Land Base on O&C lands, as discussed in the section on the 

O&C Act and the FLPMA in Chapter 1. Therefore, there is no influence on the protection of wilderness 

characteristics on the calculation of the ASQ in any of the alternatives or the Proposed RMP.

Wild and Scenic Rivers

The BLM would vary by alternative and the Proposed RMP the types of rivers recommended for 

inclusion into the Wild and Scenic River System (see the Wild and Scenic Rivers section of this chapter). 

The decision area includes 9 congressionally designated Wild and Scenic Rivers under BLM 

administration. The 1995 RMPs recommended 13 segments for inclusion into the Wild and Scenic River 

System and the BLM currently manages these segments to protect their components until Congress 

designates or releases them for other purposes. Under all alternatives and the Proposed RMP, the BLM 

would retain these 13 segments’ recommendation for inclusion into the Wild and Scenic River System. 

Alternatives B, C, and the Proposed RMP would recommend for inclusion 6 eligible rivers also found to 

be suitable. Alternative D would recommend for inclusion all 51 eligible rivers within the decision area. 

Acres of BLM land associated with each Wild and Scenic River segment are not exactly known. In 

general, corridor widths for Wild and Scenic Rivers are 0.25 miles on either side of the river from the 

high water mark. This boundary, by Section 3(b) of the Wild and Scenic Rivers Act, may vary on either 

side of the river and be narrower or wider, as long as the total corridor averages no more than 320 acres 

per river mile. The BLM used the standard 0.25-mile distance as an assumption in the effects analysis of 

Wild and Scenic Rivers later in this chapter and in delineating the land use allocation (Congressionally 

Reserved lands and National Landscape Conservation System Lands) for the river segments in GIS under 

the alternatives and the Proposed RMP. The BLM excluded detailed assumptions for Wild and Scenic 

River corridors in the vegetation modeling calculation of ASQ timber harvest, because the complexity of 

the calculation for such a small acreage across the decision area was not warranted. For all segments, the 

near-distance portion of these corridors under all alternatives and the Proposed RMP would be Riparian 

Reserve and would not have been included in ASQ calculations. The acres of Harvest Land Base within 

0.25 miles of river segments recommended for inclusion into the Wild and Scenic River system varies by 

management direction for river recommendations described above, and the spatial arrangement of the 

Harvest Land Base under each alternative and the Proposed RMP. These variations in the river 

recommendations and arrangement of the Harvest Land Base result in variations of the amount of 

recommended Wild and Scenic River corridor acres that may have been modeled as part of the Harvest 

Land Base when determining ASQ. Therefore, potential reductions to total acreage to the modeled 

Harvest Land Base from rivers that would be recommended for inclusion in the Wild and Scenic River 

System adds some uncertainty to the ASQ calculations.

Visual Resource Management

The BLM would manage visual resources on the following special landscapes the same under all action 

alternatives and the Proposed RMP, as described in Appendix B: Congressionally Reserved lands; Wild 

and Scenic Rivers; District-Designated Reserve – Lands Managed for their Wilderness Characteristics; 

National Trails; Recreation Management Areas; and ACECs. The action alternatives and the Proposed 

RMP only differ in Visual Resources Management (VRM) outside of these landscapes in that Alternative 

D includes both VRM Class III and Class IV lands in the Harvest Land Base, whereas the other 

alternatives and the Proposed RMP only assign VRM Class IV to the Harvest Land Base (see the Visual 

Resource Management section of this chapter). Special landscapes listed above that overlap the Harvest 

Land Base, either through land use allocation designation or acres that may have been modeled as part of 

the Harvest Land Base, would be minimal under these alternatives and the Proposed RMP. However, 

BLM-administered lands within these special landscapes not managed as VRM Class IV may limit 
349 | P a g e

intensity of timber harvest (Table 3-57). The calculation of the ASQ did not attempt to account for 

restrictions in timber harvest in these areas where there may be conflict between Visual Resource 

Management and timber management. These restrictions would likely reduce but not preclude sustainedyield timber harvest contribution from these areas. Potential mitigation measures, such as adjusting timber 

harvest practices to include or increase retention levels in regeneration harvests in these overlapping areas 

could reduce or avoid this conflict. Nevertheless, potential restrictions on timber harvest in these areas 

add a small level of uncertainty to the ASQ calculations. 

Table 3-57. Compatibility of sustained-yield management regimes with VRM classifications 

Classification HITA (Even-aged 

Management)

LITA/MITA/No Action

(Two-aged Management)

OHTA/UTA

(Uneven-aged Management)

VRM I

VRM II

VRM III

VRM IV

Dark grey boxes indicate that the management regime would generally be incompatible. 

Cross-hatched boxes indicate that the management regime may be compatible. 

Light grey boxes indicate that the management regime would generally be compatible. 

Recreation Management Areas 

Within Special Recreation Management Areas (SRMA), the BLM would manage and protect specific 

recreation opportunities and recreation setting characteristics on a long-term basis. This recreation 

management may restrict timber harvest where SRMAs overlap with the Harvest Land Base, which 

occurs in varying amounts: no acres in Alternative A; 581 acres in Alternative B; 6,339 acres in 

Alternative C; 9,967 acres in Alternative D; and 7,926 acres in the Proposed RMP. In some areas of 

overlap, timber harvest may be compatible with recreation management. Where incompatible, recreation 

management would restrict, but not preclude, timber harvest. Potential mitigation measures, such as 

adjusting timber harvest practices to include or increase retention levels in regeneration harvests in these 

overlapping areas could reduce or avoid this conflict. The calculation of the ASQ did not attempt to 

account for restrictions in timber harvest in these areas for the No Action Alternative or Alternatives A, 

B, C, or D, but vegetation modeling did account for these effects for the Proposed RMP in order to ensure 

compatibility with SRMA management and produce a more accurate ASQ estimate. In the Proposed 

RMP, the BLM designated SRMAs overlapping the Harvest Land Base on O&C lands as Uneven-aged 

Timber Area in the western half of the Klamath Falls Field Office, the Medford District, and the South 

River Field Office of the Roseburg District. In the Coos Bay, Eugene, and Salem Districts, and the 

Swiftwater Field Office of the Roseburg District, the BLM designated these overlapping SRMAs as Low 

Intensity Timber Area. 

In summary, restrictions on timber harvest in the Harvest Land Base would have varying levels of 

influence on the ASQ and would present varying levels of uncertainty about the ASQ calculation among 

the alternatives and the Proposed RMP. The quantified effects on the ASQ would be substantial for 

protection of future marbled murrelet sites in Alternative D and the Proposed RMP, and the management 

of known and historic northern spotted owl sites in Alternative D and Sub-alternative B. The northern 

spotted owl site management direction under the Proposed RMP of avoiding incidental take from timber 

harvest until the beginning of a barred owl management program would have no effect on ASQ 

projections. Although the effect is quantified here, the potential restrictions related to future marbled 

murrelet sites in the No Action alternative, Alternatives B, C, and D, Sub-Alternative B, and the Proposed 

RMP present uncertainty. Also quantified here, the action alternatives and the Proposed RMP would have 

potential uncertainty regarding restrictions to future North Coast DPS red tree vole sites. Unquantified 
350 | P a g e

potential restrictions on timber harvest would present substantial uncertainty in the ASQ calculation for 

the No Action alternative, especially related to implementation of Survey and Manage measures and 

forest management within Adaptive Management Areas. Areas of modeled and overlapping designations 

could result in potential restrictions on timber harvest in some alternatives and the Proposed RMP, most 

notably where the High Intensity Timber Area in Alternative C would overlap with designations for Wild 

and Scenic Rivers, VRM Class II, VRM Class III, or SRMAs.

Issue 3

What would be the total timber harvest volume, including timber harvested from the reserve land use 

allocations, under each alternative?

Summary of Analytical Methods

In addition to the calculation of the ASQ described above, the Woodstock model also provided 

calculations of timber volume produced from reserve land use allocations. In contrast to the ASQ volume, 

timber volume that would be produced as a by-product of silvicultural treatments in reserve land use 

allocations (i.e., non-ASQ volume) would change over time and eventually decline in moist forest areas. 

Therefore, the volume from reserve land use allocations does not constitute sustained-yield timber 

production and does not contribute to the ASQ. The calculation of the non-ASQ volume for each 

alternative and the Proposed RMP was also a direct output from the vegetation modeling, but reflected 

modeling assumptions about the intensity and extent of thinning needed to achieve the management 

objectives of the reserve land use allocations.

Background

The management direction in the 1995 RMPs directed thinning in the Late-Successional Reserve and 

Riparian Reserve to attain the management objectives of those land use allocations and permitted timber 

salvage after disturbance under certain conditions. However, as noted in the BLM plan evaluations, the 

analysis for the 1995 RMPs did not include an assessment of the potential harvest volume from the 

reserve allocations, hardwood conversion, or reserve salvage harvest (USDI BLM 2012, p. 11).

Affected Environment and Environmental Consequences

Between 1995 and 2012, the BLM has sold an average of 167 MMbf of timber annually in the decision 

area, including both ASQ and non-ASQ volume. Between 2004 and 2012, the BLM sold an average of 73 

MMbf of non-ASQ timber annually, out of an average total timber volume sold of 201 MMbf. In 2011 

and 2012, non-ASQ volume averaged 38 percent of total timber volume sold in the decision area (Figure 

3-66).
351 | P a g e

Figure 3-66. Total ASQ vs. Non-ASQ timber volume sold in the decision area between 1995 and 2012

In Figure 3-66, the 1995 through 2010 data comes from office data requests for the 2012 Resource 

Management Plan Evaluation Report. 2011 and 2012 data was generated from Forest Resource 

Information System data entered through October 23, 2014. Due to continual updates and data correction, 

these estimates may be different from other estimates generated at different times or from different 

sources.

Alternative C would have the highest total harvest volume at 555 MMbf per year during the first decade, 

while Alternative D would have the least, with 180 MMbf per year. The Proposed RMP would produce 

278 MMbf of total timber harvest volume per year during the first decade (Figure 3-67 and Table 3-

58).61 The No Action alternative would provide the most non-ASQ volume in the first decade, followed 

by Alternative B, Sub-alternative B, and the Proposed RMP. Alternatives A and D would provide the 

least non-ASQ volume. The amount of non-ASQ volume under the alternatives and the Proposed RMP 

would be influenced heavily by management direction for reserve thinning and the forest conditions 

within the reserve.

 

61 Both Figure 3-67 and Table 3-58 contain minor errors associated with rounding.

0

50

100

150

200

250

300

1995 1997 1999 2001 2003 2005 2007 2009 2011

Timber Volume (MMbf)

Fiscal Year

HLB (ASQ) Regeneration Harvest HLB (ASQ) Thinning

Reserve (Non-ASQ) Thinning 1995 Declared ASQ

Average of Total Volume Sold Average ASQ Volume Sold
352 | P a g e

Figure 3-67. Total annual timber harvest in the decision area for the first decade compared to the 1995–

2012 sold timber sale average, broken out between ASQ and non-ASQ sources

124

277

234 234

120

486

332

176 205

43

122

15

97

98

69

67

4

73

0

100

200

300

400

500

600

1995-2012

Sales

No

Action

Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Timber Harvest (MMbf) 

ASQ Non-ASQ
353 | P a g e

Table 3-58. Total annual timber harvest volume for the first decade by ASQ and non-ASQ sources

Alternative/

Proposed 

RMP

Coos Bay Eugene Klamath Falls Medford Roseburg Salem

Totals 

(MMbf) ASQ 

(MMbf)

NonASQ 

(MMbf)

ASQ 

(MMbf)

NonASQ 

(MMbf)

ASQ 

(MMbf)

NonASQ 

(MMbf)

ASQ 

(MMbf)

NonASQ 

(MMbf)

ASQ 

(MMbf)

NonASQ 

(MMbf)

ASQ 

(MMbf)

NonASQ 

(MMbf)

No Action 46 22 58 31 8 - 73 12 55 17 37 41 400

Alt. A 46 - 63 - 3 1 27 11 25 3 71 - 249

Alt. B 23 24 56 26 7 - 42 16 35 12 71 19 332

Sub. B 14 24 25 26 4 - 15 16 14 12 47 19 218

Alt. C 82 15 138 17 10 - 54 12 78 10 124 15 555

Sub. C 66 15 103 17 3 - 24 10 51 9 85 15 399

Alt. D 22 - 45 1 5 - 28 1 22 1 54 1 180

PRMP 12 18 53 20 6 - 37 14 32 9 65 12 278
354 | P a g e

The non-ASQ timber volume under Alternative D would be very low (4 MMbf per year during the first 

decade), because few if any stands allocated to the Late-Successional Reserve would require silvicultural 

treatments. Most timber harvesting in reserves in this alternative would be restricted to a small outer zone 

in the Riparian Reserve. This Riparian Reserve thinning would provide almost all of the non-ASQ 

volume under Alternative D.

The non-ASQ timber volume under Alternative A would be low (15 MMbf per year during the first 

decade), because Alternative A would employ non-commercial silvicultural treatments in moist forest 

reserves. The small non-ASQ volume in Alternative A would be produced almost entirely in the 

interior/south areas where removal of cut trees would be needed to manage fuels and promote forest 

resiliency.

The No Action alternative generally precludes management of stands over 80 years old in reserves. In the 

Late-Successional Reserve and Riparian Reserve in the dry forest, none of the action alternatives and the 

Proposed RMP specifies an age limit for determining treatment eligibility. Alternative B and Subalternative B limit timber harvest in the Late-Successional Reserve in the moist forest to stands less than 

120 years old. None of the other action alternatives or the Proposed RMP would specify an age limit for 

silvicultural treatments in the reserve land use allocations in the moist forest. Instead, treatment eligibility 

for reserves would generally be based on habitat evaluations, rather than specific age limits. Regardless of 

the variation in age limits prescribed in the management direction, the BLM assumed that the majority of 

reserve treatments would occur in stands less than 80 years old in moist forests, and would not occur 

within older, more structurally-complex forests, as defined in the alternatives and the Proposed RMP in 

dry forests.

The non-ASQ volume would decline in future decades, as fewer moist forest stands would need 

silvicultural treatments to achieve Reserve land use allocation management objectives. This decline 

would be more pronounced in the coastal/north area than in the interior/south due to the higher proportion 

of dry forest reserves in the south. Under the action alternatives and the Proposed RMP, the BLM 

assumed that management in the Late-Successional Reserve in the dry forest would include stand density 

reduction, cultivation and release of large trees with old-growth characteristics, and introduction of 

heterogeneity into increasingly uniform stands. As described in more detail in the Fire and Fuels section 

in this chapter, the BLM assumed that mechanical treatments would be necessary to both restore dry 

forest stands and maintain them in a restored condition in order to increase stand resiliency to fire, 

disease, and the potential, yet unknown effects from climate change. This would involve selection harvest 

on a variable, but perpetual, re-entry cycle to keep stands from becoming overstocked. As a result, the 

non-ASQ volume associated with silvicultural treatments of the Late-Successional Reserve would not 

taper off to zero except in the No Action alternative and Alternative D (Table 3-59) in the dry forest.
355 | P a g e

Table 3-59. Annual non-ASQ timber harvest by decade: coastal/north vs. interior/south 

Alternative/

Proposed RMP Area 2023 (MMbf)

2033 

(MMbf)

2043 

(MMbf)

2053 

(MMbf)

2063 

(MMbf)

2113* 

(MMbf)

No Action Coastal/North 94 87 76 63 46 -

Interior/South 29 28 28 25 18 -

Alt. A Coastal/North 0.1 0.1 0.2 0.8 0.3 0.3

Interior/South 15 10 11 10 17 19

Alt. B Coastal/North 70 66 57 47 33 -

Interior/South 27 22 22 20 23 18

Sub. B Coastal/North 70 66 57 47 33 -

Interior/South 27 22 22 20 23 18

Alt. C Coastal/North 47 45 38 31 22 -

Interior/South 22 18 17 16 16 11

Sub. C Coastal/North 48 45 38 31 22 -

Interior/South 20 13 12 11 19 2

Alt. D Coastal/North 2.6 2.4 2.0 1.6 0.9 -

Interior/South 1.1 1.0 1.0 0.9 0.6 -

PRMP

Coastal/North 50 48 41 34 24 -

Interior/South 22 18 17 14 17 16

* This table has minor errors associated with rounding. 

In summary, all alternatives and the Proposed RMP would result in higher total harvest volumes in the 

first decade than the average annual timber sale volumes from the decision area since 1995, which 

averaged 167 MMbf per year. Although Sub-alternative B has the lowest ASQ volume, the total harvest 

volume would be 218 MMbf per year compared to 180 MMbf per year under Alternative D. Alternative C 

would have the highest total annual harvest in the first decade with 555 MMbf per year followed by the 

No Action alternative with 400 MMbf per year. The Proposed RMP would produce 278 MM bf per year 

of total timber harvest volume in the first decade. Non-ASQ timber harvest volumes would decline and 

eventually disappear in the moist forest Late-Successional Reserve, while non-ASQ timber harvest from 

dry Late-Successional Reserve would generally continue in future decades. 

Issue 4 

What log sizes would be harvested under each alternative? 

Summary of Analytical Methods 

The outputs from the Woodstock model grouped harvested timber volume into four generalized 

size/quality groups (Table 3-60). The BLM based these groupings on small end diameter inside bark 

from harvest tables, including taper assumptions by species group. Minimum merchantability standards 

were used in the vegetation modeling defining a minimum merchantable log as 8 feet long to a small end 

log diameter of 5 inches with 8 inches of trim, and a minimum tree DBH of 7 inches. 
356 | Page

Table 3-60. Log size groups by small end diameter inside bark diameter class 

Size Group Small End Log Diameter Class

(Inches)

1 > 20

2 12–20

3 8–11

4 5–8

Affected Environment and Environmental Consequences 

Because the vast majority of BLM timber harvesting in the past decade has come from thinning stands 

less than 80 years old, most of the timber volume has been coming from log size groups 2 through 4, with 

relatively little timber volume being produced in log size group 1 (logs greater than 20”). 

The percentage of timber harvested in log size groups 2, 3, and 4 would differ only slightly among the 

alternatives and the Proposed RMP. However, the alternatives and the Proposed RMP would differ more 

substantially in the percentage of timber harvested in log size group 1. Log size is generally smaller in 

younger stands, and taking older, more structurally-complex forests out of the Harvest Land Base would 

increase the reliance on timber harvest in younger stands. The percentage of timber in log size group 1 

would be lowest in Sub-alternative C, at 5 percent of total volume; because Sub-alternative C would 

reserve all stands currently older than 80 years old. The percentage of timber in log size group 1 would be 

highest in the No Action alternative, which does not specifically reserve older, more structurally-complex 

forest, and in Alternative C, which would reserve all stands currently older than 160 years old. Under the 

Proposed RMP, the BLM would produce 9 percent of total timber harvest volume in log size group 1 in 

the first 5 decades of implementation (Table 3-61).

Table 3-61. Percentage of total timber harvest volume in the decision area by log size group; first 5 

decades 

Log 

Size 

Group

No 

Action 

(Percent)

Alt. A

(Percent) 

Alt. B

(Percent) 

Sub. B 

(Percent) 

Alt. C

(Percent) 

Sub. C 

(Percent) 

Alt. D

(Percent) 

PRMP 

(Percent) 

1 14% 10% 10% 9% 14% 5% 11% 9%

2 50% 52% 50% 48% 51% 47% 47% 50%

3 22% 23% 23% 24% 21% 28% 24% 24%

4 15% 16% 16% 18% 14% 20% 18% 17%

Issue 5 

What harvest types and silvicultural practices would the BLM apply under each alternative? 

Summary of Analytical Methods

In the vegetation modeling, the BLM made assumptions for harvest types consistent with the management 

direction for each alternative (Appendix C). These harvest types fall into the following five categories: 

 Commercial thinning 

 Selection harvest 

 Variable-retention regeneration harvest 

 Clear-cut harvest 356 | Page

Table 3-60. Log size groups by small end diameter inside bark diameter class 

Size Group Small End Log Diameter Class

(Inches)

1 > 20

2 12–20

3 8–11

4 5–8

Affected Environment and Environmental Consequences 

Because the vast majority of BLM timber harvesting in the past decade has come from thinning stands 

less than 80 years old, most of the timber volume has been coming from log size groups 2 through 4, with 

relatively little timber volume being produced in log size group 1 (logs greater than 20”). 

The percentage of timber harvested in log size groups 2, 3, and 4 would differ only slightly among the 

alternatives and the Proposed RMP. However, the alternatives and the Proposed RMP would differ more 

substantially in the percentage of timber harvested in log size group 1. Log size is generally smaller in 

younger stands, and taking older, more structurally-complex forests out of the Harvest Land Base would 

increase the reliance on timber harvest in younger stands. The percentage of timber in log size group 1 

would be lowest in Sub-alternative C, at 5 percent of total volume; because Sub-alternative C would 

reserve all stands currently older than 80 years old. The percentage of timber in log size group 1 would be 

highest in the No Action alternative, which does not specifically reserve older, more structurally-complex 

forest, and in Alternative C, which would reserve all stands currently older than 160 years old. Under the 

Proposed RMP, the BLM would produce 9 percent of total timber harvest volume in log size group 1 in 

the first 5 decades of implementation (Table 3-61).

Table 3-61. Percentage of total timber harvest volume in the decision area by log size group; first 5 

decades 

Log 

Size

Group

No 

Action

(Percent)

Alt. A

(Percent)

Alt. B

(Percent)

Sub. B

(Percent)

Alt. C

(Percent)

Sub. C

(Percent)

Alt. D

(Percent)

PRMP

(Percent)

1 14% 10% 10% 9% 14% 5% 11% 9%

2 50% 52% 50% 48% 51% 47% 47% 50%

3 22% 23% 23% 24% 21% 28% 24% 24%

4 15% 16% 16% 18% 14% 20% 18% 17%

Issue 5 

What harvest types and silvicultural practices would the BLM apply under each alternative? 

Summary of Analytical Methods

In the vegetation modeling, the BLM made assumptions for harvest types consistent with the management 

direction for each alternative (Appendix C). These harvest types fall into the following five categories: 

 Commercial thinning 

 Selection harvest 

 Variable-retention regeneration harvest 

 Clear-cut harvest 

 Salvage 

Non-commercial thinning in the Late-Successional Reserve and Riparian Reserve in Alternative A and 

the middle zone of the Riparian Reserve – Moist of Class I subwatersheds in the Proposed RMP would 

generally not include timber harvest, as the BLM would fell the timber and leave it on site. Noncommercial thinning is not reported in the timber harvest categories, but it is included in the report on 

silvicultural treatments (Table 3-63). Timber harvest implemented in the Late-Successional Reserve in 

hdfiid lihihilid hPd RMPb
357 | Page

 Salvage 

Non-commercial thinning in the Late-Successional Reserve and Riparian Reserve in Alternative A and 

the middle zone of the Riparian Reserve – Moist of Class I subwatersheds in the Proposed RMP would 

generally not include timber harvest, as the BLM would fell the timber and leave it on site. Noncommercial thinning is not reported in the timber harvest categories, but it is included in the report on 

silvicultural treatments (Table 3-63). Timber harvest implemented in the Late-Successional Reserve in 

the dry forest is categorized as selection harvest in the action alternatives and the Proposed RMP, but as 

thinning in the No Action alternative, because of differences in management direction. Variable-retention 

regeneration harvesting would include all regeneration harvest practices in the Matrix and Adaptive 

Management Area in the No Action alternative, regeneration harvest in the Moderate Intensity Timber 

Area and Low Intensity Timber Area in Alternative B, Sub-alternative B, and the Proposed RMP, and 

regeneration harvest in the Moderate Intensity Timber Area in Alternative D. All timber harvesting in the 

Uneven-aged Timber Area in all action alternatives and the Proposed RMP, and in the Owl Habitat 

Timber Area in Alternative D, is in the selection harvest category, with the exception of salvage. 

The Woodstock model predicted the acreage of silvicultural treatments associated with timber harvest for 

each decade under each alternative and the Proposed RMP. These silvicultural treatments include fuels 

reduction, site preparation, planting, stand maintenance and protection, pruning, stand conversion, precommercial thinning, and fertilization. The extent of many silvicultural treatments is linked directly to the 

amount and type of regeneration harvest implemented. For example, following a regeneration harvest, the 

BLM would typically implement site preparation, tree planting, and stand maintenance. The BLM 

assumed that no aerial fertilization would be implemented under Alternatives B and D, Sub-alternative B, 

and the Proposed RMP because of their forest management practices. Modeling assumptions about postfire timber salvage are used to approximate the management direction for salvaging after natural 

disturbances included in Appendix B by land use allocation. For the Harvest Land Base in all alternatives 

and the Proposed RMP, except for the Owl Habitat Timber Area in Alternative D, the BLM assumed that 

timber salvage would occur after high- and moderate-severity fire events. In the Owl Habitat Timber Area 

in Alternative D, and the Late-Successional Reserve in Alternative C, the BLM assumed that timber 

salvage would occur only after high-severity fire events. The BLM only modeled timber salvage volume 

from reserves in Alternative C. With the exception of wildfire and associated salvage, the BLM did not 

simulate the occurrence of large-scale episodic natural disturbances in the vegetation modeling, including 

insect and disease outbreaks or wind-throw; however, the management direction in Appendix B provides 

salvage guidance for all natural disturbances. 

Affected Environment and Environmental Consequences 

The 1995 RMPs estimated levels of silvicultural treatments that would occur under implementation of the 

plan, but the BLM has generally not achieved these levels of treatments. The BLM plan evaluations 

concluded that implementation of the timber management program was departing substantially from the 

outcomes predicted in the 1995 RMPs (USDI BLM 2012). On average, implementation of regeneration 

harvests has been 26 percent of levels anticipated in the 1995 RMPs, varying from 9 percent to 36 percent 

among districts. Commercial thinning has averaged 137 percent of levels anticipated in the 1995 RMPs, 

varying from 95 percent to 569 percent among districts. With the exception of commercial thinning, the 

levels of silvicultural activities within the decision area (Table 3-62) have been substantially less than 

anticipated in the 1995 RMPs. Average decadal accomplishments in the decision area since 1995 include 

14,275 regeneration harvest acres sold and 122,245 acres of thinning sold. For this calculation, timber 

salvage is lumped into either the regeneration harvest category or the thinning category where it is the 

most similar. The levels of reforestation treatments have been directly affected by the timber harvest 

activities that the BLM has implemented. The lack of anticipated regeneration harvest levels and the shift 

357 | Page

 Salvage 

Non-commercial thinning in the Late-Successional Reserve and Riparian Reserve in Alternative A and 

the middle zone of the Riparian Reserve – Moist of Class I subwatersheds in the Proposed RMP would 

generally not include timber harvest, as the BLM would fell the timber and leave it on site. Noncommercial thinning is not reported in the timber harvest categories, but it is included in the report on 

silvicultural treatments (Table 3-63). Timber harvest implemented in the Late-Successional Reserve in 

the dry forest is categorized as selection harvest in the action alternatives and the Proposed RMP, but as 

thinning in the No Action alternative, because of differences in management direction. Variable-retention 

regeneration harvesting would include all regeneration harvest practices in the Matrix and Adaptive 

Management Area in the No Action alternative, regeneration harvest in the Moderate Intensity Timber 

Area and Low Intensity Timber Area in Alternative B, Sub-alternative B, and the Proposed RMP, and 

regeneration harvest in the Moderate Intensity Timber Area in Alternative D. All timber harvesting in the 

Uneven-aged Timber Area in all action alternatives and the Proposed RMP, and in the Owl Habitat 

Timber Area in Alternative D, is in the selection harvest category, with the exception of salvage. 

The Woodstock model predicted the acreage of silvicultural treatments associated with timber harvest for 

each decade under each alternative and the Proposed RMP. These silvicultural treatments include fuels 

reduction, site preparation, planting, stand maintenance and protection, pruning, stand conversion, precommercial thinning, and fertilization. The extent of many silvicultural treatments is linked directly to the 

amount and type of regeneration harvest implemented. For example, following a regeneration harvest, the 

BLM would typically implement site preparation, tree planting, and stand maintenance. The BLM 

assumed that no aerial fertilization would be implemented under Alternatives B and D, Sub-alternative B, 

and the Proposed RMP because of their forest management practices. Modeling assumptions about postfire timber salvage are used to approximate the management direction for salvaging after natural 

disturbances included in Appendix B by land use allocation. For the Harvest Land Base in all alternatives 

and the Proposed RMP, except for the Owl Habitat Timber Area in Alternative D, the BLM assumed that 

timber salvage would occur after high- and moderate-severity fire events. In the Owl Habitat Timber Area 

in Alternative D, and the Late-Successional Reserve in Alternative C, the BLM assumed that timber 

salvage would occur only after high-severity fire events. The BLM only modeled timber salvage volume 

from reserves in Alternative C. With the exception of wildfire and associated salvage, the BLM did not 

simulate the occurrence of large-scale episodic natural disturbances in the vegetation modeling, including 

insect and disease outbreaks or wind-throw; however, the management direction in Appendix B provides 

salvage guidance for all natural disturbances. 

Affected Environment and Environmental Consequences 

The 1995 RMPs estimated levels of silvicultural treatments that would occur under implementation of the 

plan, but the BLM has generally not achieved these levels of treatments. The BLM plan evaluations 

concluded that implementation of the timber management program was departing substantially from the 

outcomes predicted in the 1995 RMPs (USDI BLM 2012). On average, implementation of regeneration 

harvests has been 26 percent of levels anticipated in the 1995 RMPs, varying from 9 percent to 36 percent 

among districts. Commercial thinning has averaged 137 percent of levels anticipated in the 1995 RMPs, 

varying from 95 percent to 569 percent among districts. With the exception of commercial thinning, the 

levels of silvicultural activities within the decision area (Table 3-62) have been substantially less than 

anticipated in the 1995 RMPs. Average decadal accomplishments in the decision area since 1995 include 

14,275 regeneration harvest acres sold and 122,245 acres of thinning sold. For this calculation, timber 

salvage is lumped into either the regeneration harvest category or the thinning category where it is the 

most similar. The levels of reforestation treatments have been directly affected by the timber harvest 

activities that the BLM has implemented. The lack of anticipated regeneration harvest levels and the shift 
358 | P a g e

to commercial thinning has reduced the extent of reforestation and young stand management activities 

since 1995. 

Table 3-62. Average decadal silvicultural treatment accomplishment acres in the decision area, 1996–

2012 

Silvicultural 

Treatment

Coos Bay 

(Acres)

Eugene 

(Acres)

Klamath 

Falls 

(Acres)

Medford 

(Acres)

Roseburg 

(Acres)

Salem 

(Acres)

Totals 

(Acres)

Fertilization 14,213 1,511 - 1,389 3,440 2,903 23,456

Pre-commercial 

Thinning 18,135 21,374 10,352 26,423 36,428 27,082 139,793

Pruning 8,786 4,174 406 6,079 5,791 2,723 27,960

Slash Disposal and 

Site Preparation 2,928 2,759 30,727 129,829 4,573 6,522 177,338

Stand Conversion 489 - 92 - - 121 703

Stand Maintenance 

and Protection 25,552 13,032 2,053 17,860 12,958 22,330 93,784

Tree Planting 5,170 4,243 2,236 22,156 4,726 4,851 43,383

Alternative C would have the largest acreage of clear-cutting and the largest acreage of regeneration 

harvest overall in the first two decades (Figure 3-68). The No Action alternative would have the largest 

acreage of variable-retention regeneration harvest. Alternative D would have the largest acreage of 

selection harvest. Based on simulations of wildfire occurrence and subsequent salvage harvest, salvage 

harvest would occur on a small acreage under all alternatives and the Proposed RMP (359 acres per year 

or less). Alternative C would have the largest salvage harvest acreage, in part because Alternative C 

would direct the salvage in the Late-Successional Reserve after natural disturbances to recover economic 

value. The Proposed RMP would result in the second highest level of variable-retention regeneration 

harvesting, and the third highest level of selection harvesting. Since the BLM did not simulate the 

occurrence of other large-scale episodic natural disturbances besides wildfire in the vegetation modeling, 

these salvage figures are likely underestimated. 
359 | P a g e

Figure 3-68. Harvest acres per decade by harvest type based on an average of the first two decades

The acreage of timber harvest would not mirror the volume of timber harvest, as discussed above in the 

issue on the annual productive capacity. The dramatic difference in the timber volume per acre among the 

harvest types results in different patterns in acres that would be harvested and timber volume among the 

alternatives and the Proposed RMP (Figure 3-68 and Figure 3-69). For example, Alternative A would 

harvest the fewest total acres, but would harvest the sixth-highest timber volume. Alternative B would 

harvest the second-largest acreage, but would harvest the fourth-highest timber volume. Alternative D 

would harvest the fifth-highest acreage, but would harvest the least timber volume. These relationships 

are explained by the average timber volume per acre removed, which varies by harvest type, and is 

influenced by the log size class of timber eligible for harvest in each alternative and the Proposed RMP.

42,200

83,691

58,454

110,570

15,315

71,700

59,369

45,748

73,013

14,901

61,406

(CT)

26,757

68,580

42,147

45,403

34,063

103,059

58,641

43,932

30,711

17,379

19,957

31,115

2,539

884

2,642

1,498

3,587

2,308

1,640

2,258

0

50,000

100,000

150,000

200,000

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Harvest Per Decade (Acres)

Clearcut Commercial Thinning Selection VRH Salvage
360 | P a g e

Figure 3-69. Harvested timber volume per decade by harvest type based on an average of the first two 

decades

Average timber harvest volume per acre also varies between the coastal/north and interior/south areas.

Total annual timber harvest acreage is higher in the coastal/north area in the No Action alternative and 

Alternative C, and higher in the interior/south area in Alternative B and the Proposed RMP. Total annual 

harvest acreage in the other alternatives is relatively comparable between the coastal/north and the 

interior/south (Figure 3-70). However, total harvested timber volume per year is substantially higher in 

the coastal/north area than the interior/south in all alternatives and the Proposed RMP (Figure 3-71).

1,996

4,234

2,436

2,066

262

1,427

1,165

838

1,303

252

1,175

(CT)

189

642

338

398

162

745

428

1,846

1,170

615

773

1,107

44

15 (Salvage)

34

13

66

32 (Salvage)

30

31

0

1,000

2,000

3,000

4,000

5,000

6,000

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Timber Volume Per Decade (MMbf)

Clearcut Commercial Thinning Selection VRH Salvage
361 | P a g e

Figure 3-70. Total timber harvest acreage per year based on an average of the first two decades, broken 

out between coastal/north and interior/south areas

Figure 3-71. Total timber harvest volume per year based on an average of the first two decades, broken 

out between coastal/north and interior/south areas

The acreage of most silvicultural treatments, especially reforestation, site preparation, and stand 

maintenance activities that would occur under the alternatives and the Proposed RMP is correlated with 

the acreage of regeneration harvest (i.e., clear-cutting and variable-regeneration retention harvest). 

Uneven-aged management regimes would also require reforestation, site preparation, and stand 

9,332

3,941

8,035

6,300

9,230 9,295

6,836 6,827

6,372

4,575

9,329

5,739

8,613

7,489

7,120

8,736

0

2,000

4,000

6,000

8,000

10,000

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Timber Harvest Acres/Year

Coastal/North Interior/South

230

179

218

155

391

300

123

180

165

67

109

58

163

93

57

97

0

100

200

300

400

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Timber Harvest Volume (MMbf/Year)

Coastal/North Interior/South
362 | P a g e

maintenance activities, but these activities would only be undertaken on a portion of the treatment acres in 

a given decade. Alternative C would have the most acres of total silvicultural treatments and Alternative 

D would have the least acres of treatments (Table 3-63).

Table 3-63. Silvicultural treatment acreages per decade based on an average of the first two decades

Treatment 

Type

No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Sub. B 

(Acres)

Alt. C 

(Acres)

Sub. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Noncommercial 

Thinning

- 12,957 - - - - - 2,215

Under Burn 8,907 16,760 16,571 9,871 33,152 23,792 10,410 15,832

Hand Pile and 

Burn 24,734 23,309 35,349 21,950 45,751 36,590 25,822 32,232

Landing Pile 

and Burn 5,402 3,089 6,313 3,926 6,479 7,158 4,955 5,468

Machine Pile 

and Burn 14,780 7,429 13,353 9,874 17,907 17,197 10,313 11,274

Slash and 

Scatter 20,201 14,231 30,092 18,390 27,437 22,248 22,280 28,109

Mastication 3,010 4,669 3,902 2,129 10,664 7,488 2,352 4,056

Planting 55,999 57,223 44,750 27,154 117,004 82,669 38,064 52,833

Stand 

Maintenance 

and Protection

82,573 89,061 77,213 45,432 181,801 130,114 60,578 82,696

Precommercial 

Thinning

54,366 49,570 43,778 25,429 97,420 69,758 26,148 41,108

Fertilization 10,989 15,606 - - 19,139 36,222 - 0

Pruning 3,498 4,362 3,878 2,119 9,474 6,516 2,740 3,910

Stand 

Conversion 114 295 216 164 555 436 139 106

Totals 284,573 298,561 275,415 166,438 566,783 440,188 203,801 279,839

In summary, Alternative C would have the most acres of clear-cutting per decade, followed by Subalternative C and Alternative A. The No Action alternative would have the most acres per decade of 

variable-retention regeneration harvesting, followed by the Proposed RMP. Alternative D would have the 

most acres of selection harvest followed by Alternative B. Timber harvest acreages by harvest type for the 

Proposed RMP are bracketed by the alternatives. Silvicultural treatments acres would be correlated most 

strongly to the number of acres of clear-cutting and variable-retention regeneration harvesting, although 

other harvest types would also require silvicultural treatments to a lesser degree. Total annual timber 

harvest acreage is higher in the coastal/north area in the No Action alternative and Alternative C, and 

higher in the interior/south area in Alternative B and the Proposed RMP. However, total annual timber 

harvest is substantially higher in the coastal/north areas in all alternatives and the Proposed RMP.
363 | P a g e

Issue 6

How would each alternative affect the availability of special forest products?

Summary of Analytical Methods

In this analysis, the BLM divided special forest products into two broad categories:62

 Category I—Disturbance-associated special forest products – Christmas trees, wood products, 

manzanita, huckleberries, beargrass, pine cones, morels, etc.

 Category II—Disturbance-averse special forest products – ferns, wild ginger, mosses, hemlock 

cones, chanterelles and matsutakes, coniferous boughs, and burls, etc.

The BLM assumed for the analysis that disturbances such as timber harvest, prescribed fire, and wildland 

fire would produce the conditions that would support the availability of Category I special forest 

products; areas without these disturbances would support the availability of Category II special forest 

products. The BLM assumed that less intensive treatments such as pre-commercial thinning, fuels 

reduction, and fertilization would have no effect on conditions for the availability of either category of 

special forest products, although the BLM recognizes that there are site and species-specific exceptions to 

this assumption. The more acres that would be disturbed by timber harvest, prescribed fire, and wildland 

fire in the decision area, the more acres would be available for harvest of Category I species. The more 

acres that would be undisturbed in the decision area, the more acres would be available for harvest of 

Category II special forest products.

In this analysis, the BLM considered acres without timber harvest, prescribed fire, or wildland fire within 

the previous 20 years as undisturbed and therefore supporting Category II special forest products. The 

BLM used outputs from the Woodstock model to estimate future disturbed and undisturbed areas, in order 

to compare special forest product availability between the alternatives and the Proposed RMP.

This analysis only addresses broad characterizations of the availability of special forest products. The 

BLM lacks information on the extent to which availability would affect the collection of special forest 

products or other factors that would affect collection. The number of available acres suitable for the 

collection of these products does not forecast future demand or sustainable harvest levels for each of these 

products. The BLM also assumed that public access was available to all lands that would be available to 

special forest products harvesting, although the BLM recognizes reciprocal right-of-way agreements are 

distinctly different across the decision area, and may limit access for certain special forest products; legal 

access may also be limited on some portions of BLM-administered lands. Finally, each specific product 

has fine-scale associations by aspect, plant association, and other unique site-level factors beyond 

disturbance history. The BLM does not have sufficient product-specific, species-specific, or site-specific 

information at the scale of analysis to refine this analysis beyond the broad categories of special forest 

products and the broad characterizations of disturbance.

 

62 These categories are not a formal designation and are simply labeled here for the purpose of analysis. Some 

products fit in both categories, and some are conditionally included in one category or the other. For example, 

manzanita may benefit from open conditions created by disturbance, and be considered to be a Category 1 species, 

or depending on the type of disturbance, manzanita abundance could be reduced, making it fit better as Category II. 

Despite acknowledged limitations and site-specific nature of these generalized conceptual categories, the BLM 

believes that this analytical framework is useful in evaluating relative differences in special forest product 

availability across large and diverse range of landscapes and species, and long timescales considered in the analysis.
364 | P a g e

Background

‘Special forest products’ is a term used to describe some of the vegetative material found on public lands 

that can be harvested for recreational use, personal use, or as a source of income. They include, but are 

not limited to, grasses, seeds, roots, bark, burls, berries, mosses, greenery (e.g., fern fronds, salal, and 

huckleberry), edible mushrooms, boughs, tree seedlings, transplants, poles, posts, and firewood. Trees or 

logs that are sold as saw timber are not considered special forest products.

Management of special forest products is an important component of resource management in 

Oregon/Washington BLM. Special forest products are commonly referred to as ‘minor forest products’ 

and are restricted to vegetative material. The special forest products program benefits the 

Oregon/Washington BLM and the public in many ways. These include contributing to the economic 

stability in local communities, providing critical cultural and subsistence benefits, supporting a variety of 

cottage industries, forming partnerships with groups concerned with the harvest of management of these 

products, and providing educational opportunities regarding the value of natural, renewable resources.

Commercial, personal, free use, and free use with a permit are distinct categories for public users on 

BLM-administered lands, although the boundaries between personal and free use blend. Commercial use 

of special forest products requires a permit and harvesters generally search for and harvest high value 

products from patches in a systematic and thorough method for maximum resale value. Many individuals 

enjoy harvesting or collecting special forest products for their own personal use and tend to harvest 

smaller quantities, searching less systematically and less thoroughly and at smaller spatial scales. All 

personal use special forest products, with the exception of those meeting free use conditions, require 

permits. Free use includes collection and gathering of berries and mushrooms for immediate use and 

gathering firewood for campfires. Although most commercial harvesters in the Pacific Northwest do not 

rely on special forest products for their sole source of income, these products do provide important 

supplemental or seasonal sources of income that contribute to household economies (Charnley 2006).

Permits for commercial use and personal use for special forest products include restrictions to help meet 

ecological and renewable resource standards and to protect other sensitive resource values. Permits may 

restrict the type of species, harvest quantity, harvest or collection method, location, access, and season.

Field inventories of special forest products that include distribution and abundance, harvest areas, and 

actual harvest amounts on BLM-administered lands are lacking.

Affected Environment and Environmental Consequences

Currently, approximately 12 percent of the forested lands in the coastal/north area are available for the 

collection of Category I special forest products, while 17 percent of forested lands in the interior/south 

area are currently available for collection of these products. Conversely, approximately 88 percent of the 

coastal/north area and 83 percent of the interior/southern area are currently available for the collection of 

Category II special forest products. Based on this analysis, the availability of Category I special forest 

products are more limited than Category II special forest products in the decision area.

Under all alternatives and the Proposed RMP, the interior/south area would consistently have a higher 

proportion of the forested lands available for the harvesting of Category I special forest products than the 

coastal/north area (Figure 3-72 and Figure 3-73).
365 | P a g e

Figure 3-72. Percentage of forested acres available for the collection of Category I special forest products; coastal/north area

Figure 3-73. Percentage of forested acres available for the collection of Category I special forest products; interior/south area

0%

5%

10%

15%

20%

25%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Coastal/North Cat I SFPs 

(Percent)

2013 2023 2033 2043 2053 2063

0%

5%

10%

15%

20%

25%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Interior/South Cat I SFPs 

(Percent)

2013 2023 2033 2043 2053 2063
366 | P a g e

In the coastal/north, Alternatives C and Sub-alternative C would have the largest acreage available for 

harvest of Category I special forest products, followed by the No Action alternative and Alternative B. 

Alternative A would have the smallest acreage suitable for these disturbance-related products. In fact, the 

acreage available for harvesting Category I special forest products would decline in the coastal/north in 

the first two decades from current conditions under Alternative A (Figure 3-72).

In the interior/south, Alternative B would have the largest acreage available for the collection of Category 

I special forest products, followed by Alternative C and the Proposed RMP. As in the coastal/north, 

Alternative A would have the smallest acreage available for the harvesting of these products. The acreage 

available for harvesting Category I special forest products in the interior/south would decline in the first 

five decades from current conditions under Alternative A (Figure 3-73).

Conversely, the coastal/north would consistently have more acreage available for the collection of 

Category II special forest products. Regardless of alternative or the Proposed RMP, decade, or region, the 

proportion of the forested lands available for the collection of Category II special forest products would 

be above 75 percent of the forested acres in the decision area (Figure 3-74 and Figure 3-75).
367 | P a g e

Figure 3-74. Percentage of forested acres available for the collection of Category II special forest products; coastal/north area

Figure 3-75. Percentage of forested acres available for the collection of Category II special forest products; interior/south area

0%

20%

40%

60%

80%

100%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Coastal/North Cat II SFPs 

(Percent)

2013 2023 2033 2043 2053 2063

0%

20%

40%

60%

80%

100%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D PRMP

Interior/South Cat II SFPs 

(Percent)

2013 2023 2033 2043 2053 2063
368 | P a g e

In summary, the acreage of forests available for the harvesting of Category II (disturbance-averse) special 

forest products would remain abundant in all alternatives and the Proposed RMP, especially in the 

coastal/north areas. The acreage of forests available for the harvesting of Category I (disturbance 

associated) special forest products would be more limiting than Category II special forest products, and 

consistently higher in the interior/south than the coastal/north due to disturbed acres associated with 

timber harvest, prescribed fire, and wildland fire. Availability of these forest conditions in the 

coastal/north areas would be almost completely dependent on harvesting practices. Therefore, the 

alternatives that have the largest timber harvest acreage would also produce the largest number of acres 

available for the collection of Category I special forest products. In the coastal/north, Alternative C and 

Sub-alternative C would have the largest acreage available for harvest of Category I special forest 

products, followed by the No Action alternative and Alternative B. In the interior/south, Alternative B 

would have the largest acreage suitable for the collection of Category I special forest products, followed 

by Alternatives C and the Proposed RMP.

References

Birch, K. R., and K. N. Johnson. 1992. Stand-level wood-production costs of leaving live, mature trees at regeneration harvest in 

coastal Douglas-fir stands. West. J. Appl. For. 7(3): 65–68.

Charnley, S. (tech. coord.). 2006. Northwest Forest Plan-The First Ten Years (1994–2003): Socioeconomic monitoring results.

Vol. II (Timber and nontimber resources). General Technical Report PNW-GTR-649. USDA Forest Service, Pacific 

Northwest Research Station, Portland, OR. pp. 29–33. http://www.treesearch.fs.fed.us/pubs/22374.

Di Lucca, M. C., J. W. Goudie, and S. C. Stearns-Smith. 2004. Variable retention yield adjustment factors for TIPSY. Extension 

Note No. 69. British Columbia Ministry of Forests, Forest Science Program. Victoria, B.C.

Franklin, J. F., and K. N. Johnson 2012. A restoration framework for Federal forests in the Pacific Northwest. Journal of Forestry 

110(8): 429–439. http://www.blm.gov/or/districts/medford/plans/trail/files/forest-restoration.pdf.

Gustafsson, L., S. C. Baker, J. Bauhus, W. J. Beese, A. Brodie, J. Kouki, D. B. Lindenmayer, A. Lõhmus, G. M. Pastur, C. 

Messier, B. Palik, A. Sverdrup-Thygeson, W. J. A. Volney, A. Wayne, and J. F. Franklin. 2012. Retention forestry to 

maintain multifunctional forests: a world perspective. BioScience 62(7): 633–645.

http://dx.doi.org/10.1525/bio.2012.62.7.6.

Long, J. N., and S .D. Roberts. 1992. Technical commentary: Growth and yield implications of a “New Forestry” silvicultural 

system. Western Journal of Applied Forestry 7(1): 6–9.

Miller, R. E., R. E. Bigley, and S. Webster. 1993. Early development of matched planted and naturally regenerated Douglas-fir 

stands after slash burning in the Cascade Range. Western Journal of Applied Forestry 8(1): 5–10.

http://www.fs.fed.us/pnw/pubs/journals/pnw_1993_miller001.pdf.

Sensenig, T., J. Bailey, and J. C. Tappeiner. 2013. Stand development, fire and growth of old-growth and young forests in 

southwestern Oregon, USA. Forest Ecology and Management 291: 96–109.

http://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/38559/BaileyJohnDForestEngineeringResourcesManagementS

tandDevelopmentFire.pdf?sequence=1.

Temesgen, H., P. J. Martin, D. A. Maguire, J. C. Tappeiner. 2006. Quantifying effects of different levels of dispersed canopy tree 

retention on stocking and yield of the regeneration cohort. Forest Ecology and Management 235(1–3): 44–53.

http://dx.doi.org/10.1016/j.foreco.2006.07.025.

Tuchmann, E. T., and C. T. Davis. 2013. O&C Lands Report; Prepared for Oregon Governor John Kitzhaber. February 6, 2013. 

http://library.state.or.us/repository/2013/201302111127191/. Accessed 02/19/2015.

Urgenson, L. S., C. B. Halpern, and P. D. Anderson. 2013. Twelve year responses of planted and naturally regenerating conifers 

to variable-retention harvest in the Pacific Northwest, USA. Canadian Journal of Forest Research 43: 46–55.

http://www.fs.fed.us/pnw/pubs/journals/pnw_2012_urgenson001.pdf.

USDA FS and USDI BLM. 2000. Final Supplemental Environmental Impact Statement for Amendment to the Survey and 

Manage, Protection Buffer, and Other Mitigation Measures Standards and Guidelines. Vol. 1, Chapters 1–4, pp. 428–438. 

USDA FS and USDI BLM, Portland, OR. http://www.blm.gov/or/plans/surveyandmanage/files/rd-fseis_v1_ch1-4-2000-

11.pdf.

USDI BLM. 2008. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western 

Oregon Bureau of Land Management Districts. Portland, OR. Vol. I–IV. http://www.blm.gov/or/plans/wopr/index.php.

---. 2012. Resource Management Plan Evaluation Report, Western Oregon Districts. Bureau of Land Management. Portland, OR. 

http://www.blm.gov/or/plans/files/RMPEvaluation.pdf.

---. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, Oregon/Washington 

State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.

USDI FWS. 2011. Revised Recovery Plan for the Northern Spotted Owl (Strix occidentalis caurina). USFWS Region 1, 

Portland, OR. 258 pp. http://www.fws.gov/wafwo/pdf/NSO%20Revised%20Recovery%20Plan%202011.pdf.
369 | P a g e

Hydrology

Key Points

 The BLM analyzed stream shading using two methods. By Method A, all alternatives and the 

Proposed RMP would avoid any measurable increases in stream temperature. Method B

identified a small percentage of streams where forest management in the outer Riparian Reserve 

under Alternatives B and C would potentially affect stream temperature.

 Less than 1 percent of the decision area would be susceptible to peak flow increases under each

alternative and the Proposed RMP. The No Action alternative, Alternatives A and D, and the 

Proposed RMP would result in slight decreases and Alternatives B and C would result in slight 

increases in the number of subwatersheds susceptible to peak flow increases.

 Less than 1 percent of the Harvest Land Base would be susceptible to landslides with the 

potential to deliver sediment to streams under each alternative and the Proposed RMP. 

Alternative C would have the highest acreage of regeneration harvest in areas susceptible to 

landslides, and Alternative D would have the lowest acreage.

 Under all alternatives and the Proposed RMP, potential sediment delivery to streams from new 

road construction would result in less than a 1 percent increase above current levels.

Summary of Notable Changes from the Draft RMP/EIS

In the analysis of landslide risk, the BLM adjusted the threshold for steep slopes from 70 percent to 75 

percent based on information from the Oregon Department of Forestry. The analysis of how road 

construction would affect disturbance and sources of fine sediment that may be delivered to stream 

channels corrects an error in the calculation of the sediment delivery from existing roads. Specifically, the 

Draft RMP/EIS analysis overlooked the sediment contribution of existing paved roads. The updated 

analysis also uses new data for the estimates of new road construction for commercial thinning under each 

alternative and the Proposed RMP (see the Trails and Travel Management section of this chapter).

Issue 1

To what extent would each alternative maintain effective shade along streams?

Summary of Analytical Methods

This analysis addresses stream shading along each side of perennial and fish-bearing streams on BLMadministered lands. This analysis evaluates existing and projected forest vegetation that provides shade 

and maintains cool stream temperatures. Primary components of shade (forest tree height, canopy density, 

and the Riparian Reserve width) form the basis of the analysis, rather than measuring stream temperature 

variation along watercourses directly. The physics of stream temperature gain or loss within forest 

streams is highly correlated to the extent and quality of shading vegetation (discussed further under

Background of this section).

All action alternatives and the Proposed RMP define overall Riparian Reserve widths, which are divided 

into an inner zone and an outer zone. Management direction addresses a variety of actions for both zones, 

which varies by action alternative and the Proposed RMP. This analysis assumed that there would not be 

any harvest in the inner zone and that the outer zones would be maintained with thinning, under the action

alternatives and the Proposed RMP. In light of the differences in management direction for the outer zone, 
370 | P a g e

the analysis assumed that riparian thinning would occur over a greater percentage of stands suitable for 

thinning and the BLM would thin stands to a lower density in Alternatives B and C than in Alternatives A 

and D, and the Proposed RMP.

The No Action alternative defined interim Riparian Reserve widths that could be modified after 

watershed analysis. For this analysis, the BLM assumed that the Riparian Reserve under the No Action

alternative would remain at the interim widths: two site-potential tree heights for fish-bearing streams and 

one site-potential tree height for perennial, non-fish-bearing streams. Under the No Action alternative, 

thinning and other silvicultural treatments are allowed anywhere in the Riparian Reserve with no specific 

retention requirements. However, activities must meet the Aquatic Conservation Strategy objectives, 

which are often difficult to interpret at the site scale. Since 1995, the BLM has implemented thinning and 

other silvicultural treatments within the Riparian Reserve (see the Fisheries section of this chapter). 

Although not explicitly stated in the 1995 RMPs, under the No Action alternative this analysis assumed 

that a 60-foot-wide, inner zone along each side of a stream would not be thinned due to any combination 

of stream temperature concerns and maintenance of streamside shade; large and small wood recruitment 

needs over time; sediment filtering; and channel stability where steep and unstable inner gorges must be 

protected to prevent landsliding. Although implementation of Riparian Reserve thinning has been highly 

variable since 1995, this analytical assumption that no thinning would occur within 60 feet of streams 

under the No Action alternative represents an approximate average of past and current implementation 

practices. The BLM makes this assumption solely for the purposes of this analysis. In the outer portion of 

the Riparian Reserve, the BLM assumes that thinning would continue on young, overstocked stands under 

the No Action alternative to meet a variety of Aquatic Conservation Strategy objectives.

In this analysis, the BLM used two different methodologies to evaluate stream shade. Method A 

determines the width of Riparian Reserve by empirical relationships necessary to provide 80 percent 

effective shade and relies upon previous work in the 2008 FEIS (USDI BLM 2008, Appendix I – Water, 

pp. 250–253). Effective shade is the percentage of sunlight blocked by topography, forest trees, and 

vegetation during a solar day. Effective shade reaches an upper limit in the 80–90 percent range for 

normally stocked Young to Mature stands (USDA FS and USDI BLM 2012). During daylight hours in 

the summer months, when stream heating is a concern, the sun’s altitude (vertical zenith angle) and 

horizontal position (azimuth) change constantly, directing solar radiation down to the earth’s surface. 

Solar radiation intensity at the water surface varies with the sun’s altitude, azimuth, and cloud cover, and 

is diminished with blocking by topography and reflected or adsorbed by forest tree crowns (Brazier and 

Brown 1972, Boyd 1996). The sun’s path length through vegetation decreases transmissivity, particularly 

where leaf area is high (DeWalle 2010). Where the solar angle exceeds the forest shade angle from the 

tallest trees, solar radiation will reach the waterbody (Boyd 1996). When varying angular canopy density 

is summed for the primary daytime hours and weighted for the proportion of incoming solar radiation 

blocked for each time period, an estimate of effective shade is obtained. Angular canopy density is the 

sun-blocking vegetation in the path of the sun from 10 a.m. to 2 p.m. (Brazier and Brown 1972). For 

normally stocked Young to Mature stands, forest shade tends to reach a maximum (near 80 percent 

effective shade), where increasing the width of the Riparian Reserve would only marginally improve 

effective shade. Gaps in forest vegetation as well as the quality of shade from needles, leaves, treebranches and boles, even in Mature stands, prevent much higher measures of effective shade. There is 

always some solar radiation transmissivity to the water surface through needles and leaves and over the 

tallest trees, especially near solar noon.

Method A compares the Riparian Reserve allocations in the alternatives and the Proposed RMP to a 60-

foot-wide inner zone with no harvest and an outer zone with a 50 percent canopy closure that extends out 

to 1 site-potential tree height width63 along each side of perennial and fish-bearing streams. Analytical 

 

63 Site-potential tree height generally varies from 140–240 feet width in the planning area.
371 | P a g e

conclusions determine the miles of perennial and fish-bearing streams that are not substantially similar by 

HUC 12 watershed.

64 Streamside stands reach a shade limit in the range of 60- to 100-feet of width from 

the waterbody. A wider Riparian Reserve would provide no further shade benefit, because the solar path 

lengths through forest vegetation are sufficiently long and direct solar radiation has already been 

extinguished (DeWalle 2010). A disadvantage of Method A is that it considers a uniform management 

prescription in the outer zone. The empirical relationships in Method A do not consider angular canopy 

density that blocks sunlight outside the 10 a.m. to 2 p.m. daily period. However, this design has a 

negligible effect on decreasing effective shade, because incoming solar radiation intensity is substantially

lower during early morning and late afternoon hours, mountainous topography provides shade at these 

hours, and longer solar path lengths through the sides of forest trees are extinguishing available solar 

radiation (Boyd 1996, DeWalle 2010). Method A does not crosswalk with water quality studies or models 

to determine if temperature changes are occurring from management activities. Rather, Method A uses an 

approach that establishes effective shade that is near potential natural shade, based on empirical 

relationships by Brazier and Brown (1972) and Steinblums et al. (1984).

Method B, proposed by the Environmental Protection Agency (EPA), presents a mechanistic modeling 

approach that uses the Oregon Department of Environmental Quality (ODEQ) shade model to develop 

shade loss tables for each alternative and the Proposed RMP Riparian Reserve designs. The rationale uses 

a before‐after‐control‐impact design, where observed changes in stream temperature are due to the 

difference between pre- and post-harvest (Groom et al. 2011). The EPA methodology considers whether 

various widths and canopy cover densities in inner and outer zones of the Riparian Reserve would result 

in shade loss associated with management that would increase stream temperature. Although Groom et al. 

(2011) determined that less than 6 percent shade loss per stream reach, pre-harvest to post-harvest (0.4-

mile mean treatment reach length), would have no statistical effect on raising stream temperatures, the 

EPA has specifically proposed an analytical threshold of no greater than 3 percent shade loss, to provide

“a margin of safety” (EPA 2013, p. 3). Therefore, in the analysis in this Proposed RMP/Final EIS, the 

BLM considers shade loss exceeding 3 percent (calculated for 0.25-mile perennial and fish-bearing 

stream reaches in the decision area and summed by mile) as representing a risk of stream temperature 

increases. This analytical threshold does not represent a specific requirement for management, but an 

analytical tool for interpreting the results of this analysis.

The BLM cross-walked canopy cover from the ODEQ shade model with canopy cover from the 

Woodstock model to provide a common attribute, in addition to Riparian Reserve widths, for evaluating

the alternatives and the Proposed RMP using the EPA shade loss tables. The change is necessary because 

Woodstock-modeled canopy cover measures have removed tree-to-tree overlap that influences canopy 

density and shade. Results from Woodstock-modeled canopy cover underestimate field-measured canopy 

cover. Fiala et al. (2006) found that modeled canopy cover is consistently lower when compared to field 

measurements of canopy cover and suggest that a regression equation is best to compare measurements of 

canopy cover. McIntosh et al. (2012) compared modeled canopy cover results with a ground-based 

estimate and reported that equations underestimated canopy cover by 17 percent on average at high cover 

levels (greater than 70 percent) in wet conifer and wet hardwood stands. Using this approach, the BLM 

used field-measured canopy cover along selected streams from western Oregon districts to form a 

regression equation (Figure 3-76) between pre-harvest vegetation density (shown in the EPA shade loss 

tables) as canopy cover and the Woodstock-modeled canopy cover. The EPA reviewed this regression 

equation, and provided field-measured studies that support the interpretations. This is a modification of 

the analytical methodology described in the Planning Criteria (USDI BLM 2014, pp. 68–72).

 

64 Hydrologic Unit Codes (HUCs) are a U.S. Geological Survey classification based on a hierarchy of nested 

watersheds.
372 | P a g e

Figure 3-76. Canopy cover and angular canopy density in forest stands

In this analysis, the BLM (using EPA’s methodology) calculated shade lost from the combination of the 

existing canopy cover of the inner zone and the outer zone with the management direction of each 

alternative and the Proposed RMP to retain a specific threshold of canopy cover (Table 3-64). The BLM

divided perennial and fish-bearing streams into 0.25-mile segments and then merged those segments with 

the Woodstock-modeled canopy cover by decade until 2063 for the Riparian Reserve designs under each 

alternative and the Proposed RMP. This methodology ignores the small amount of canopy cover overlap 

at stream segment nodes and at stream junctions. To apply these shade loss tables spatially, the BLM 

tracked the changing inner zone canopy cover, along each side of perennial and fish-bearing streams for 

each decade until 2063, and then applied the outer zone canopy cover for purposes of reading the EPA 

shade loss tables. In this way, the BLM calculated the miles of perennial and fish-bearing streams that 

would exceed 3 percent shade loss until 2063 for each alternative and the Proposed RMP. This is a 

modification of the analytical methodology described in the Planning Criteria (USDI BLM 2014, pp. 73–

75).

y = 17.495x0.3868

R2 = 0.7529

40

50

60

70

80

90

100

20 30 40 50 60 70 80 90 100

Angular Canopy Density (Percent)

Canopy Cover (Percent) (ORGANON)

Includes effective shade calculated from Solar Pathfinder and Hemiview 

photography. Data from Coos Bay, Roseburg and Medford Districts. n=12.
373 | P a g e

Table 3-64. Modeled shade loss* for a 150-foot-wide Riparian Reserve, with a 60-foot inner no harvest 

zone, at various thinning intensities and initial canopy conditions 

Scenario (Two Sided Treatments)

Stream Aspect

North 

South NW/SE East West Average

Pre-harvest Condition - 80% Canopy Cover

1.3 1.1 0.9 1.1

2.6 1.9 1.3 1.9

4.4 3.0 1.6 3.0

Pre-harvest Condition - 60% Canopy Cover

5.7 4.9 5.6 5.4

9.7 7.7 6.9 8.1

Pre-harvest Condition - 40% Canopy Cover

13.8 12.7 16.2 14.2

* Yellow highlighted boxes are greater than or equal to the 3 percent shade loss analytical threshold. 

Source: EPA 2014 

Modeling design and constraints over such a large planning area prevent the varying of certain factors 

known to influence shade. With either method, assumptions about tree heights cannot vary spatially. The 

BLM calibrated Method A with tree heights for Mature to Structurally-complex stands. The BLM and 

EPA calibrated Method B with tree heights for Mature stands (50 to 70 years old). Neither method 

considers terrain slope and the positive effect of topographic shade during early morning and late 

afternoon hours. Method A ignores solar radiation outside of 10 a.m. to 2 p.m. In contrast, Method B may 

overestimate shade loss by not considering topographic shade. Method B tracks stream orientation in 

shade loss outputs, while Method A does not. However, Method A provides a design that averages all 

stream orientations where solar radiation can vary in the path of the sun. Both methods do not consider 

tree setback distance from the stream that may increase solar radiation or the shading effects of understory 

brush or stream incision. Method A uses a uniform Riparian Reserve design, emphasizing greater than 80 

percent effective shade where there is at least a 60-foot inner zone, without any particular harvest 
374 | P a g e

prescription constraints in the outer zone. Method B accounts for variable management actions and 

variable canopy cover density in the inner and outer zone. Method B does not identify an actual reduction 

in stream shading, but a susceptibility to a reduction in stream shading if the BLM were to thin the outer 

zone along certain streams. 

Both Methods A and B assume for analytical purposes that regeneration harvest has removed canopy 

cover outside of the Riparian Reserve. This assumption is unrealistic, because the majority of the decision 

area would be in reserves and planned regeneration harvest within the Harvest Land Base would be 

spread out temporally and spatially across the Harvest Land Base under all alternatives and the Proposed 

RMP. However, this assumption is unlikely to affect the analytical conclusions under Methods A or B; 

studies and modeling suggest that direct solar radiation from outside Riparian Reserve widths allocated in 

the alternatives and the Proposed RMP does not increase shade loss at the stream, because solar radiation 

has already been reflected, adsorbed, or otherwise extinguished by forest vegetation inside the Riparian 

Reserve. 

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 65–75). 

Background 

Most of the streams on BLM-administered lands are intermittent streams, as evidenced by the distribution 

of lands in mountainous headwaters, and the correspondingly high ratio (2:1) of intermittent to perennial 

streams as viewed in Table 3-65. The proportion of intermittent to perennial streams on other lands in the 

planning area is likely similar to the 2:1 ratio on BLM-administered lands. However, the data shown here 

yields a ratio of 1.5:1 for the planning area; the difference is likely due to variances in the mapping 

methods of other landowners. 

Table 3-65. Miles of streams with BLM ownership within the planning area 

Stream Periodicity Planning Area Streams

(Miles)

BLM Streams

(Miles)

BLM Stream Miles

(Percent)

Perennial* 57,893 6,711 12%

Intermittent†86,990 13,311 15%

Totals 144,884 20,023 14%

* Perennial streams have varying but continuous discharge year round. Their base level is at, or below, the water table.

† Intermittent streams are a nonpermanent drainage feature with a dry period, normally for three months or more. Flowing water 

forms a channel feature with well-defined bed and banks, and bed-forms showing annual scour or deposition, within a continuous 

channel network.

Stream temperature variation depends upon a number of natural and management factors, including 

topography, forest vegetation, channel characteristics, streamflow, and climate (Caissie 2006, Leinenbach 

et al. 2013). Water volume and stream width are important as mechanisms by which stream temperatures 

can fluctuate (Kibler 2007). As stream discharge increases, a fixed amount of solar energy is diluted and 

the resultant temperature change is decreased. As streams widen, the wetted surface area increases, which 

results in a higher absorption per unit volume of stream with a corresponding temperature rise. 

The interactions controlling stream temperature in mountainous, forested landscapes are complex, 

because simultaneous daily fluxes are occurring over a varying topography with steadily declining 

streamflow into summer. The temporal area of interest for this analysis is July and August, when clear 

sky days and solar radiation approach maximum levels. Direct solar radiation is the most important source 
375 | P a g e

of the energy budget affecting stream temperature gain at the water surface (Brown 1969, Beschta 1997, 

Moore and Wondzell 2005, Caissie 2006, Leinenbach et al. 2013). During July and August, the sun’s 

altitude is high, and only the portion of forest canopy to the south of the waterbody, in line with the suns

daily path, is involved. Stream banks or hill slopes in the path of the sun, as well as understory brush and 

trees with varying canopy layers and densities, produce shade for most daylight hours. There may be a 

few gaps where sunlight can reach the stream during the morning or afternoon hours, depending on

specific stand characteristics. However, at mid-day when the sun is near its zenith, solar radiation may 

reach the stream through overhead canopy gaps in the forest or overtop the highest trees’ shade angle, 

depending on tree height, setback distance, angular canopy density, and stream width. Small streams are 

generally well shaded because canopies spread over the channel. As watershed area increases and streams 

widen to rivers with floodplains, linear gaps appear over the stream channel.

There are important interactions simultaneously occurring, including stream direction (azimuth), 

topography, tree height, and stand density in blocking solar radiation. The natural environment poses an 

array of possibilities in assessing the transmission of solar radiation to a stream. The duration of shade 

depends upon shade-producing vegetation in the path of the sun at any given time during the day as the 

sun’s path and altitude changes. The quality of shade depends upon solar radiation transmission through 

forest canopies, where solar radiation decreases as leaf area index and forest density increases.

The 2008 FEIS provides additional detailed background information on the effects of Riparian Reserve on 

stream shading and is incorporated here by reference (USDI BLM 2008, pp. 336–34; Appendix I – Water, 

pp. 250–252).

Affected Environment

Proportions of Riparian Reserve in the decision area by stand structural stage within 100-feet of perennial 

and fish-bearing streams are shown in Figure 3-77.
376 | P a g e

Figure 3-77. Structural stage proportions of the Riparian Reserve within 100 feet of perennial and fishbearing streams in the decision area

Source: USDI BLM 2008, p. 341

More than half of the Riparian Reserve is currently in the Mature or Structurally-complex structural 

stages. There has been very limited regeneration harvest within 100 feet of perennial and fish-bearing 

streams in the last 30 years, leading to a decline in the Early Successional and Stand Establishment 

structural stages to 4 percent. Some portion of the Early Successional and Stand Establishment stands

within the Riparian Reserve has resulted from natural disturbances, such as wildfire, flood, or disease. 

Under the 1995 RMPs, the BLM has thinned in the Riparian Reserve in Young stands along perennial and 

fish-bearing streams, but has typically left a 50- to 60-foot no-harvest zone along each side of the stream 

channel.

Figure 3-78 shows the current proportions of the entire Riparian Reserve (i.e., No Action alternative) by 

structural stage. The forest structural stage patterns are similar to the 100-foot inner stream zone, except 

there is more area in Early Successional and Stand Establishment stands further than 100 feet from the 

edge of streams.65

 

65 This comparison assumes that the 8 percent with no data does not skew the current structural stage proportions.

Early 

Successional and 

Stand 

Establishment

4%

Young

41%

Mature

28%

Structurallycomplex

27%
377 | P a g e

Figure 3-78. Structural stage proportions of the current Riparian Reserve (i.e., No Action alternative) 

along perennial and fish-bearing streams in the decision area 

Monitoring results have documented a decrease in average maximum stream temperatures in the last 20 

years for some streams within the decision area. Varying atmospheric conditions and antecedent 

precipitation result in substantial year-to-year variation in stream temperatures. However, as shown in 

Figure 3-79, average maximum summertime stream temperatures are clearly declining by as much as 

4 °F in one coastal Oregon stream. Similar patterns are observed on other districts; Roseburg is shown in 

Figure 3-80. 

Early 

Successional

1% Stand 

Establishment

17%

Young

27%

Mature

22%

Structurallycomplex

25%

No Data

8%
378 | P a g e

Vincent Creek

Figure 3-79. Seven-day average maximum stream temperatures (°F) Vincent Creek Gaging Station, Coos 

Bay District, for years 1990–2013 

7-Day Average Maximum Stream 

Temperature (° Fahrenheit)

64.0

65.0

66.0

67.0

68.0

69.0

70.0

71.0

72.0

73.0

74.0

1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

Year

Deadman Creek

East Fork Stouts Creek 

South Fork Middle Creek

60.0

63.0

66.0

69.0

72.0

75.0

1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012

7-Day Average Maximum Water Temperature 

(° Fahrenheit)

Year

Deadman Creek above Middle Fork

East Fork Stouts Creek above Stouts Creek

South Fork Middle Creek above Middle Creek

Figure 3-80. Seven-day average maximum stream temperatures (°F) at Deadman Creek, East Fork Stouts 

Creek and South Fork Middle Creek, Roseburg District, for years 1992–2012 
379 | P a g e

Preliminary results of a density management study being carried out by the U.S. Forest Service and BLM 

show that the Riparian Reserve on BLM-administered lands is maintaining high measures of shade, even 

where thinning is conducted. This density management study took hemispherical photography in the field 

at stream centers along perennial steams with Mature mixed conifer/hardwood riparian stands, for five 

stream reaches in four BLM districts. The U.S. Forest Service’s Pacific Northwest Research Station staff 

analyzed the data with HemiviewTM solar physics software. Preliminary results shows percent visible sky 

(openness) at stream center average from 3.0–5.9 percent, indicating relatively closed forest canopies. 

Shade values ranged from 91–95 percent.66 Data from these sites further suggest maximum shading 

occurs at low solar angles and there is increased variability towards noon when radiation loads are higher 

(P. D. Anderson, U.S. Forest Service, Forestry Sciences Laboratory, personal communication, 2014). 

Environmental Consequences 

Figure 3-81 displays the total Riparian Reserve acres compared to Riparian Reserve acres bordering 

perennial and fish-bearing streams by alternative and the Proposed RMP. 

938,467

836,942

562,440

423,421

836,958 811,485

436,114

278,752 278,752

244,097

278,752 278,752

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Riparian Reserve (Acres)

Riparian Reserve Riparian Reserve–Fish-bearing and Perennial

Figure 3-81. Total acres of the current Riparian Reserve compared to acres of the Riparian Reserve along 

perennial and fish-bearing streams* 

* These acreage estimates have been corrected from the Draft RMP/EIS based on improved data using merged raster 

representations of stream vector datasets. 

There are 6,970 miles of perennial and fish-bearing streams, where forest management in the outer zone 

of the Riparian Reserve would potentially affect stream temperature. The total Riparian Reserve acres 

vary among alternatives and the Proposed RMP based on management objectives and direction. 

Alternatives A, B, and D, and the Proposed RMP include one site-potential tree height along each side of 

the stream channel of all perennial and fish-bearing streams, and Alternative C includes 150 feet along 

 

66 From HemiviewTM software, using 1-Global Solar Fraction (below canopy radiation/above canopy radiation) as a 

measure of shade 
380 | P a g e

each side of the stream channel of all perennial and fish-bearing streams. In contrast, the No Action 

alternative includes two site-potential tree heights along each side of the stream channel of fish-bearing 

streams and one site-potential tree height along each side of the stream channel of perennial, non-fishbearing streams. On perennial and fish-bearing streams, the outer management zone width varies from 2 

site-potential tree heights under the No Action alternative (i.e., the entire Riparian Reserve), between 120 

feet and 1 site-potential tree height under Alternatives A and D, and the Proposed RMP, between 60 feet 

and 1 site-potential tree height under Alternative B, and between 60 feet and 150 feet under Alternative C. 

Method A 

Implementation of Alternatives A and D, and the Proposed RMP would result in similar shading effects; 

therefore, they are grouped together for discussion. In the same manner, the effects of Alternatives B and 

C on shading are similar and are discussed together. 

Under Alternatives A and D, and the Proposed RMP, the BLM would not thin within a 120-foot-wide 

inner zone along each side of the stream channel of all perennial and fish-bearing streams. This 120-foot 

inner zone width would overlay the primary shade zone and the secondary shade zone.67 The inner zone 

alone would be sufficient to avoid reduction in stream shading under Method A. Nevertheless, 

Alternatives A and D and the Proposed RMP also include an outer zone of one site-potential tree height in 

which any thinning action would maintain at least 30 percent canopy cover and 60 trees per acre. The 

outer zone would provide protection to the inner zone, thwarting blowdown at the edge. 

Under Alternatives B and C, the BLM would not thin within a 60-foot width inner zone, which would 

match the primary shade zone. Sixty feet is the minimum width found necessary to maintain high levels 

of shade quality if managed with an outer (secondary) zone of 100 feet with 50 percent canopy cover. The 

BLM would maintain at least 50 percent canopy cover and 80 trees per acre in the outer zone, to a 

distance of one site-potential tree height for Alternative B and 150 feet for Alternative C. These outer 

zone widths exceed the secondary shade zone width of 100 feet (where the combination of primary and 

secondary shade zones maintains 80 percent effective shade) under Method A by 50 feet for Alternative C 

and an average of 80 feet for Alternative B (i.e., widths are based on varying site-potential tree heights). 

Therefore, implementation of Alternatives B or C would maintain stream shading sufficient to avoid 

increases in stream temperature under Method A. 

The No Action alternative would meet Method A criteria for stream shading, based on the Riparian 

Reserve width and assumptions about management actions described in analytical methods. However, 

there is an element of uncertainty related to stream shading under the No Action alternative compared to 

the action alternatives and the Proposed RMP. As explained in analytical methods above, thinning under 

the No Action alternative would be allowed anywhere in the Riparian Reserve with no specific retention 

requirements. However, activities must meet the Aquatic Conservation Strategy objectives, which are 

often difficult to interpret at the site scale. The 1995 RMPs do not define a ‘no-thinning’ zone, which 

makes the effects on stream shading less certain than under the action alternatives and the Proposed RMP. 

In summary, all alternatives and the Proposed RMP would exceed Method A criteria for stream shading 

and would be substantially similar in their ability to provide high quality shade and avoid any measurable 

increases in stream temperature at this scale of analysis. 

 

67 Method A uses the same methodology used in the 2008 FEIS analysis (USDI BLM 2008, Appendix I – Water, pp. 

250–253. The primary zone is defined as the area from the stream out to 60 feet. The secondary zone is defined as 

the area from the outer edge of the primary zone out to 100 feet. 
381 | P a g e

Method B

As in Method A, implementation of Alternatives A and D, and the Proposed RMP would result in similar 

shading effects and are grouped together for discussion. In the same manner, the effects of Alternatives B 

and C on shading are similar and are discussed together (Figure 3-82 and Figure 3-83). Under the No 

Action alternative, Alternatives A and D, and the Proposed RMP, there would be 30–34 miles of 

perennial and fish-bearing streams that would currently be susceptible to shade reductions that could 

affect stream temperature if the BLM were to apply thinning treatments in the outer zone of the Riparian 

Reserve. This is less than 0.5 percent of the total perennial and fish-bearing stream miles. This limited 

stream mileage reflects areas with currently low canopy cover in the inner zone, which are the stands that 

would be least likely to be thinned. This result does not reflect an actual reduction in stream shading, but 

a susceptibility to such a reduction in stream shading if the BLM thins the outer zone along these streams. 

If the BLM does not thin the stand in the outer zone on these particular 30–34 miles of perennial and fishbearing streams, no reduction in stream shading would occur. Additionally, this result likely 

overestimates the risk of shade reductions resulting in water temperature increases: if treatments were to 

occur in the outer zone adjacent to inner zone stands with low canopy cover, not all of the susceptible 

reaches would be treated in a given year, and, as some reaches were treated, other reaches would recover, 

reducing the overall effect of canopy removal. This limited stream mileage susceptible to shade 

reductions would decline over time as the stands in the inner zone increase in canopy cover. 

Implementation of the No Action alternative on stream shading would have very similar effects to 

Alternatives A and D, and the Proposed RMP, with the exception of a slight difference in the 2033 period.

The stream mileage susceptible to shade reductions would decline to almost zero in 20 years under 

Alternatives A and D, and the Proposed RMP, and in 30 years under the No Action alternative.
382 | P a g e

Figure 3-82. Perennial and fish-bearing stream miles exceeding 3 percent shade loss 

30 30 33

4 4 3

34

38

7 7 6 7

372

361

285

293

275

299

370

360

284

293

275

300

34

38

7 7 6 7

34

38

7 7 6 7

0

50

100

150

200

250

300

350

400

2013 2023 2033 2043 2053 2063

Fish-bearing and Perennial Stream Miles Exceeding 3% Shade Loss

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP
383 | P a g e

Figure 3-83. Perennial and fish-bearing stream miles*in the decision area compared to perennial and fish-bearing stream miles exceeding 3 

percent shade loss 

* The vertical axis is logarithmic to view the range of data. 

6,970

30 30 33

4 4

3

34 38

7 7

6

7

372 361

285 293 275 299

370 360

284 293 275 300

34 38

7 7

6

7

34 38

7 7

6

7

1

10

100

1,000

10,000

2013 2023 2033 2043 2053 2063

Fish-bearing and Perennial Stream Miles Exceeding 3% Shade Loss

Year

Fish-bearing and Perennial No Action Alt. A Alt. B Alt. C Alt. D PRMP
384 | P a g e

Under Alternatives B and C, there would be 275–372 miles of perennial and fish-bearing streams 

susceptible to shade reductions that could affect stream temperature if the BLM were to apply thinning 

treatments in the outer zone of the Riparian Reserve, amounting to approximately 5 percent of the total 

perennial and fish-bearing perennial stream miles. 

Using Method B, shade loss depends on the combination of the inner zone width and canopy cover, and 

the outer zone width and post-harvest canopy cover as shown in example Table 3-64. The shade loss 

thresholds, using Method B, would be exceeded most frequently where the canopy cover is less than 60 

percent in the 60-foot inner zone under Alternatives B and C, and where the canopy cover is less than 40 

percent in the 120-foot inner zone under Alternatives A and D, and the Proposed RMP. These results are 

consistent with Leinenbach et al. (2013), which concluded that the canopy cover of a no-cut buffer 

appeared to have an ameliorating effect on thinning activities outside of the buffer, with higher protection 

associated with greater canopy cover in the no-cut buffer. Maintaining an inner zone restricted from 

thinning, regardless of initial canopy cover, would reduce the miles of susceptible steams in future time 

periods, until a relatively constant canopy cover would be attained, commensurate with Mature or 

Structurally-complex Riparian Reserve stands. This is why stream mileage susceptible to shade 

reductions would decline within the first 20 years under Alternatives B and C (and a similar pattern under 

all alternatives and the Proposed RMP), and then would remain relatively constant in future decades. 

Method B does not model canopy cover increases that would occur in the outer zone between treatments, 

or the effect of those canopy cover increases in reducing potential shade loss. Under Alternatives B and 

C, if the BLM did not implement thinning treatments in the outer zone in stands with low canopy density 

and susceptible to shade loss, then all alternatives and the Proposed RMP would be substantially similar 

in their effect on stream shading. If treatments were to occur in the outer zone adjacent to inner zone 

stands with low canopy cover, not all of the susceptible reaches would be treated in a given year, and, as 

some reaches were treated, other reaches would recover, reducing the overall effect of canopy removal. 

The results of Method A and Method B analyses show that the effects of the alternatives and the Proposed 

RMP on stream shading are very similar, though they show an increased risk of shade loss under 

Alternatives B and C. While all alternatives and the Proposed RMP would maintain shade quality along 

perennial and fish-bearing streams, Alternatives A and D, and the Proposed RMP would provide slightly 

better stream shading, in part because of wider inner zones and management direction for forest 

management activities in the outer zone. While the No Action alternative would meet Method A and 

Method B criteria for stream shading as explained in the analytical methods, there is an element of 

uncertainty related to stream shading under the No Action alternative compared to the action alternatives 

and the Proposed RMP, because the No Action alternative does not define an inner, no-treatment zone. 

However, the difference among the alternatives and the Proposed RMP in areas that provide sufficient 

stream shading would be small when considered as a percentage of the total miles of perennial and fishbearing streams on BLM-administered lands. 

Issue 2 

How would timber harvest and road construction under the alternatives affect peak stream flows within 

the rain-on-snow dominated hydro-region? 

Summary of Analytical Methods 

Peak stream flows occur infrequently in the planning area, normally from November to February, but 

carry the majority of the sediment load with high stream energies that may erode and change channel 

form (Cooper 2005). Peak flows from storm events with a return interval of 1 year or greater have the 

capacity to mobilize sediment and bed-load transport (Andrews 1983 and 1984). Timber harvesting and 
385 | P a g e

associated activities alter the amount and timing of peak flows by changing site-level hydrologic 

processes, such as surface flow and sediment movement (Keppeler and Ziemer 1990, Wright et al. 1990, 

LaMarche and Lettenmaier 1998, Wemple and Jones 2003). Grant et al. (2008) concluded that field 

reviews did not provide evidence that timber harvest increases peak flows for storms with return intervals 

longer than 6 years, because the storm event is strong enough that forest management is not an 

influencing factor in peak flows. Therefore, peak flow storms with 1- to 6-year return intervals reflect the 

range for measuring the impacts on peak flows from timber harvest. 

Hydroregions are a classification of landscapes based on the precipitation type and longevity. These are 

shown in Figure 3-84 for the planning area. Hydroregions in western Oregon distinguish predominant 

precipitation types during the winter months that generally correspond to elevation and latitude. Within 

the planning area, there are three hydroregions: rain, rain-on-snow, and snow. The rain hydroregion is 

generally below 2,000 feet in elevation in the Coast Range. This hydroregion includes valleys up to 1,200 

feet in elevation in the north and up to 3,600 feet in elevation in the south along the western Cascades. 

The rain-on-snow hydroregion, where shallow snow accumulations come and go several times each 

winter, are 1,200–3,600 feet in elevation in the northern Oregon Cascades, gradually rising to 2,500–

5,000 feet in elevation in the southern Oregon Cascades. The snow hydroregion is generally above 3,600 

feet in elevation and is centered along the Cascades crest. 
386 | Page

Figure 3-84. Hydroregions within the planning area 

This issue presents an analysis of the cumulative effects on peak stream flows of past, present, and 

reasonably foreseeable future actions, including management actions on both BLM-administered lands 

and non-BLM-administered lands. 

In this analysis, the BLM addressed effects on peak flows in the rain-on-snow hydroregion only, because 

there is little evidence that timber harvest activities can elevate peak flows in the rain or snow 

hydroregions (Grant et al. 2008). The 2008 FEIS includes a more detailed discussion of the effects of 

timber harvest in the rain-dominated watersheds (USDI BLM 2008, pp. 352–354), which is incorporated 

here by reference. 

The BLM addressed effects on peak flows at the subwatershed level (HUC 12, previously termed a 6th

field watershed). Subwatersheds are generally 10,000–40,000 acres in size and have a single outlet. The 
387 | P a g e

BLM selected the subwatershed scale for this analysis, as it is more sensitive to vegetation and runoffrelated changes. In this analysis, the BLM addresses subwatersheds that meet the following three criteria: 

 BLM-administered lands are more than 1 percent of the subwatershed. 

 The subwatershed has more than 100 acres of BLM-administered lands in the rain-on-snow 

hydroregion. 

 More than 60 percent of the subwatershed is in the rain-on-snow hydroregion. 

In this analysis, the BLM calculated the total open area from timber harvest and roads for all lands in rainon-snow subwatersheds as a percent of the total subwatershed area by decade for the alternatives and the 

Proposed RMP. The BLM then refined open area percentage by factoring harvest unit opening 

percentages based on treatment type in the rain-on-snow hydroregion and compared these to the response 

curve (Grant et al. 2008). Total open area in this analysis was comprised of the following: 

 Early Successional structural stage from the Woodstock model for BLM-administered lands 

 Early Successional stands from the Landscape, Ecology, Modeling, Mapping, and Analysis 

(LEMMA) for non-BLM-administered lands 

 Road area for all lands 

The BLM has made three modifications from the analytical methodology described in the Planning 

Criteria. 

First, the BLM only addressed subwatersheds that are predominately rain-on-snow, with more than 60 

percent of the subwatershed in the rain-on-snow zone. This is a change from Step 1 of the analytical 

methods in the Planning Criteria, which included all subwatersheds with any amount of the rain-on-snow 

hydroregion. Only subwatersheds that are predominately rain-on-snow are appropriately compared to the 

Grant et al. (2008) response curve. 

Second, the BLM used change detection methods rather than the rule set described in Step 3 in the 

Planning Criteria to calculate the Early Successional forest on non-BLM-administered lands. Using the 

LEMMA satellite imagery and vegetation classification the BLM identified clearcut forest areas on nonBLM-administered lands for the base period with available imagery (1996–2006) for each identified rainon-snow subwatershed. The BLM projected this rate of clearcut harvest forward in 10-year increments for 

50 years. 

Third, the BLM added the acres of roads in rain-on-snow subwatersheds to the acres of Early 

Successional forest for BLM-administered lands and non-BLM-administered lands. The BLM calculated 

the area of roads from GIS spatial data for each subwatershed by assuming an average road cut of 15 feet, 

road width of 15 feet, and road fill of 15 feet, and multiplying that width by the total road length. 

Including the area of roads allows a direct comparison with the Grant et al. (2008) response curve of 

reported percentage change in peak flow with percent area harvested in the rain-on-snow hydroregion. 

This is an addition to Step 4 described in the Planning Criteria. 

The BLM compared the total open area for each rain-on-snow subwatershed by time period to the rainon-snow response curve from Grant et al. (2008) for each alternative and the Proposed RMP. Response 

curves for the rain-on-snow hydroregion developed by Grant et al. (2008) were constructed from data at 

the site scale (few to hundreds of acres); those response curves indicate that a mean of 19 percent of a 

watershed area with roads would need to be harvested to detect a change in peak flow response. 

Interpretation of measured peak flow increases at the site scale to larger scales, including the 

subwatershed scale, poses a scale problem. Changes in peak streamflow are influenced by timber harvest, 

but also by the age and pattern of forested stands within a larger watershed, the location and extent of 
388 | P a g e

roads, the width of Riparian Reserve, and the watershed condition. Very few studies, such as Jones and 

Grant (1996), and Bowling and Lettenmaier (2001), address peak flow response in larger watersheds, or 

the effects of a varying suite of forest management activities. These studies have shown that peak flow 

increase from timber harvest decreases with increasing watershed area. Proceeding downstream, flood 

peaks become flattened due to channel resistance, transmission losses, floodplain storage, and storm size 

variation over the watershed. Further, timing of tributary inputs typically desynchronizes peak flows,

causing reductions in unit stream flows of 50 percent or greater (Woltemade and Potter 1994). Jones and 

Grant (1996) describe that, in larger watersheds (15,000–150,000 acres), peak flow increases in adjoining 

watersheds with different forest stand structural stages were less than the year-to-year natural variability 

of stream flows. This suggests that stream channels are adjusted to a range of peak flows that is greater

than a land use variation.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 76–80).

Background

There is an ongoing and abundant supply of available moisture for rainfall over western Oregon in winter,

as greatly moderated maritime air masses move across the Pacific Ocean toward the Pacific Northwest. At 

times, continental air masses displace the warm fronts, producing snow in the higher elevations. Ongoing 

low intensity storms are common in the planning area, but occasional intense storms will produce a storm 

depth of more than 6” of precipitation in 24 hours (NOAA 1973). These storms generate peak flows that 

may overflow banks and cause channel changes, with a return frequency of 2–100 years.

Experimental subwatershed studies in hydrology demonstrate elevated peak flows during flood-producing 

storms when a high proportion of timber basal area has been removed by timber harvest (Figure 3-85), 

particularly within rain-on-snow watersheds (Grant et al. 2008). As the proportion of timber harvest 

increases within a watershed, evapotranspiration, direct interception, and potential for fog drip declines, 

while the potential for snow accumulation and melt increases. Snow accumulates faster in openings and is 

also susceptible to elevated snowmelt rates compared to forested lands (Harr 1981, Harr and Coffin 

1992). Storm flow causes runoff along road surfaces into drainage ditches or upon fills, while subsurface 

routes may be day-lighted in road cuts or flow paths cut off or modified under the road surface. This can 

result in quicker storm runoff into stream channels where ditch lines connect, compared to slower 

subsurface flow routes (Harr 1976, Harr et al. 1979, Megahan et al. 1992, Wemple et al. 1996). As storm 

intensity increases, runoff would more fully synchronize, contributing to peak flows (Megahan and Kidd 

1972, LaMarche and Lettenmaier 2001, Luce 2002, Wemple and Jones 2003).
389 | P a g e

Figure 3-85. Site conditions and treatments for risk of peak flow increase 

Source: Grant et al. 2008 PNW-GTR-760, p. 40 

There has been a long debate regarding the magnitude of peak flows resulting from timber harvesting and 

road construction. Much of the discussion has centered on the timing and scale at which peak flows are 

detected, as well as the type, size, and intensity of management activities that result in channel-changing 

peak flows. There is conflicting research on how much harvesting within a watershed would result in 

measurable changes to peak flows and at which watershed scales, and the role of road construction in 

changes in peak flows. Furthermore, there is insufficient information on the effect of partial harvesting on 

peak flows. The 2008 FEIS contained a review of the research and debate over peak flows (USDI BLM 

2008, pp. 357–359), which is incorporated here by reference. 

There are 1,203 subwatersheds within the planning area. When separated by hydroregion, 679 

subwatersheds are predominately rain-dominated, 96 subwatersheds are predominately rain-on-snowdominated (38 with BLM-administered lands), 163 subwatersheds are predominately snow-dominated 

and 265 subwatersheds have proportions of each hydroregion. Figure 3-86 shows the proportion of 

subwatersheds by hydroregions in the planning area. 

Figure 3-86. Proportions of hydroregions in the planning area 

679

96

163

265

0

100

200

300

400

500

600

700

800

Rain Dominated Rain-on-snow

Dominated

Snow Dominated Mixed

Subwatersheds (Number)

Hydroregions
390 | P a g e

Gravel bed channel types with a 1–2 percent gradient are most likely to be affected for any detectible 

peak flow increase from forest management and roads shown in Figure 3-87. Generally, these gravel bed 

stream types are a small proportion of total stream miles (less than 10 percent) in any subwatershed in the 

decision area. Most streams in the decision area are cascade or step-pool channel types. The 

predominance of cascade or step-pool channel types and the general absence of sand-bed channel types in 

the decision area reduces the likelihood that any peak flow increases would result in changes to channel 

structure in the decision area. 

Figure 3-87. Sediment transport by return period and stream type 

Source: Grant et al. 2008 PNW-GTR-760, p. 43 

Figure 3-87 shows the potential sediment transport and channel scour by channel gradient and stream 

type for 1- to 6-year recurrence interval peak flows from forest management and roads. Notice that 1–2 

percent gravel bed streams have the highest potential for effects. 

Affected Environment and Environmental Consequences 

Ninety-six subwatersheds (3 percent) in the decision area are rain-on-snow dominated (Figure 3-88). 

From this selected set of subwatersheds, 38 subwatersheds include BLM-administered lands, totaling 

197,709 BLM-administered acres. These intermediate elevations in rain-on-snow subwatersheds are 

analyzed with the methodologies presented in the Planning Criteria, and they range in area from 3,300 to 

27,400 acres, with a mean size of 15,500 acres and an area of 591,626 acres. Figure 3-89 displays the 

rain-on-snow subwatersheds with BLM-administered lands by decade across the range of alternatives and 
391 | Page

the Proposed RMP. Figure 3-88 also shows the 7 out of 38 subwatersheds with BLM-administered lands 

(8,780 acres) where more than 19 percent of the subwatershed is currently in an open condition with 

clearcut areas and roads. According to Grant et al. (2008), these 7 subwatersheds would be susceptible to 

detectable change in peak flow response. 

Figure 3-88. Rain-on-snow dominated subwatersheds and subwatersheds currently susceptible to a peak 

flow increase 

Under all alternatives and the Proposed RMP, the number of subwatersheds with BLM-administered 

lands that would have more than 19 percent of the subwatershed with clearcut harvest units and roads and 

be susceptible to a peak flow increase would vary from 6–10 subwatersheds in any period to 2063. In 

future decades, the No Action alternative, Alternatives A and D, and the Proposed RMP would result in 

slight decreases in the number of subwatersheds susceptible to peak flow increases after a slight increase 

in the 2023 period (in more than 19 percent open condition). In contrast, Alternatives B and C would 

result in slight increases in the number of subwatersheds susceptible to peak flow increases over the next 
392 | P a g e

50 years. In those subwatersheds susceptible to peak flow increases, the open area from clearcut harvest 

units and roads would vary from 19–29 percent of the subwatershed among all ownerships. The acreage 

of affected BLM-administered lands would increase through 2033, with the smallest increase under the 

Proposed RMP and the largest increase under Alternative C as shown in Figure 3-89. When all 

ownerships are analyzed together, Figure 3-90 shows a slightly different picture of peak flow 

susceptibility in the rain-on-snow subwatersheds that would have more than 19 percent of the 

subwatershed in clearcut harvest units and roads. This figure shows that the alternatives and the Proposed 

RMP would increase the open area with recently harvested areas and roads across all ownerships through 

2023 and decrease slowly until 2063, although an average of approximately 30,000 acres would continue 

to be susceptible to peak flow increases. Generally, Alternatives B and C would have the highest peak 

flow susceptibility and Alternative D the lowest peak flow susceptibility through 2063.
393 | P a g e

Figure 3-89. Subwatershed area (acres) on BLM-administered lands susceptible to peak flow increases by decade

Figure 3-90. Subwatershed area (acres) for all lands susceptible to peak flow increases

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

2013 2023 2033 2043 2053 2063

BLM-administered Lands Susceptible 

to Peak Flow Increases (Acres)

Year

No Action Alt. A Alt. B Alt. C Alt. D PRMP

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

2013 2023 2033 2043 2053 2063

All Lands Susceptible to

Peak Flow Increases (Acres)

Year

No Action At. A Alt. B Alt. C Alt. D PRMP
394 | P a g e

The affected harvest area on BLM-administered lands would vary from 621–10,173 acres in any time 

period, which is less than 0.4 percent of the BLM-administered lands within the decision area and less 

than 1 percent of the Harvest Land Base under any alternative and the Proposed RMP.

Issue 3

How would timber harvest affect the risk of landslides that would deliver sediment to stream channels 

under the alternatives?

Summary of Analytical Methods

Shallow, rapidly moving landslide68 initiation normally requires some combination of steep and 

convergent slopes, shallow soils overlying semi-impervious bedrock, and heavy or prolonged 

precipitation. Removing forest cover can elevate susceptibility to landsliding. Because of the multiple 

factors affecting landslide occurrence, including stochastic factors, it is not possible for the BLM to 

predict landslide occurrence. Instead, this analysis presents a depiction of risk of landslides and the effect 

of timber harvest under the alternatives and the Proposed RMP on that risk.

In this analysis, the BLM evaluated the risk of landslides by measuring relative landslide density using 

the GIS mass wasting hazard model within NetMap (Miller 2003, Miller and Benda 2005, and Miller and 

Burnett 2007a). The NetMap model produces a naturally occurring landslide susceptibility from geologic 

and landform factors, but independent of vegetation factors. The modeling is based on landslide 

inventories from the Coast Range, Western Cascades, and Klamath physiographic provinces. The model 

produces a spatially distributed estimate of landslide density by mathematically matching observed 

landslide locations with topographic attributes including slope, convergence (bowl-shaped landforms), 

and watershed area, using a digital elevation model. The BLM used the channelized mass wasting 

delivery model in NetMap to determine susceptible areas from the hill slope relative landslide density that 

could deliver to any stream channel.

The BLM calibrated this modeling for heavy precipitation represented by the 1996 storms (70- to 100-

year return period). Extreme storms are highly correlated with increased rates of landsliding on 

susceptible sites. For the 1996 storms, observed landslide size and density in the Coast Range were the 

highest for forest stands less than 10 years old, lower for stands between 10–100 years old, and lowest for 

forested areas over 100 years old (Robison et al. 1999, Miller and Burnett 2007a).

The BLM added forecasts of future timber harvest under each alternative and the Proposed RMP to the 

NetMap model outputs. In this analysis, the BLM assumed that clearcut harvest would increase the 

relative landslide density. After regeneration harvest, cut trees root strength rapidly declines, and shallow 

soils lose mechanical strength. Landslide susceptibility lowers substantially 10 years after clearcut harvest 

and becomes similar to mixed forests or hardwood stands (Ziemer 1981, Miller and Burnett 2007b). In 

this analysis, the BLM assumed that commercial thinning would not affect landslide risk. After thinning, 

residual live trees with intertwined roots promote slope stability. Live trees also transpire water, which 

helps to lower soil water, a causative factor in slope failures. In this analysis, the BLM grouped together 

the following harvest methods:69

 Regeneration in the High Intensity Timber Area in Alternatives A and C

 Variable retention harvests in—

 

68 A shallow, rapidly moving landslide is a mass of soil, rock, or debris that rapidly moves down a slope or stream 

channel at a velocity that is difficult for people to outrun or escape.

69 This grouping is necessary to compare harvested areas between the alternatives that are either clearcut or have a 

high degree of openness with low to variable retention.
395 | P a g e

o The Matrix, Connectivity/Diversity Blocks, and Adaptive Management Areas in No 

Action alternative;

o The Moderate Intensity Timber Area and Low Intensity Timber Area in Alternative B 

and the Proposed RMP; and

o The Moderate Intensity Timber Area in Alternative D.

It is possible that retention trees in variable retention harvests would reduce the effect of clearcut harvest 

on landslide risk. However, the BLM cannot distinguish this potential effect of retention trees on 

landslide risk at this scale of analysis. The BLM derived spatial locations of modeled regeneration harvest 

under each alternative and the Proposed RMP from the Woodstock model outputs (see the Vegetation 

Modeling section earlier in this chapter).

The BLM evaluated relative landslide density only within the Harvest Land Base under each alternative 

and the Proposed RMP, because the BLM would implement harvest only within the Harvest Land Base. 

This is a change from the methodology described in the Planning Criteria and streamlines the analytical

procedure by focusing on the areas where timber harvest may have a measureable effect on the naturally 

occurring landslide density. The BLM did not account for the continuing effect of clearcut harvests that 

the BLM has conducted within the past ten years. As described in the Forest Management section of this 

chapter, the BLM has conducted only a very small acreage of clearcut harvests in the past ten years.

Not all steep slopes are at high risk of landslides. Steep slopes in the Harvest Land Base can be up to 80

percent or more, such as those on smooth side slopes or competent rock, and have a low risk of 

landsliding. These areas are typically outside of headwalls or steep, dissected topography, which is 

usually found in the Riparian Reserve. An exception, based on slope steepness alone, is in the Tyee 

sandstone bedrock core area in the Coast Range and primarily on the Coos Bay District, where slopes 

> 75 percent slope are considered a landslide risk threshold (ODF 2003). Comparatively, similar landslide 

initiation risk inside Riparian Reserve in steep and convergent topography occurs on lower slopes (70

percent, except for the Tyee area, where 65 percent slopes are considered a threshold) (ODF 2003). Based 

on slope alone, the BLM used 75 percent slope as a threshold for landslide risk in the Harvest Land Base 

(instead of 80 percent) to account for the Tyee sandstone bedrock core area on Coos Bay District, even 

though it is only a small portion of the decision area.

This analysis within the Harvest Land Base does not account for areas that the BLM has identified or will 

identify through the Timber Production Capability Classification (TPCC) system as unsuitable for 

sustained yield timber production, such as low-productivity woodlands, unstable landforms, rock bands, 

talus slopes, meadows, and waterlogged soils (USDI BLM 1986). This inventory is ongoing, and the 

BLM reviews each proposed timber harvest area during interdisciplinary project planning. The BLM will 

periodically add additional areas to those areas reserved through updates to the TPCC system, when 

examinations indicate that an area meets the criteria for reservation, consistent with BLM Manual 5251 –

Timber Production Capability Classification (USDI BLM 1984). Because this modeling does not account 

for these areas, it overestimates the potential effect of timber harvest on relative landslide risk in these 

areas. However, these areas unsuitable for sustained-yield timber production would be identified and 

reserved similarly under all alternatives and the Proposed RMP, and the failure of the modeling to 

account for these areas does not change the relative outcomes under the alternatives or the Proposed 

RMP.

In regeneration harvest areas under each alternative and the Proposed RMP, the BLM multiplied the 

naturally occurring landslide density by factor of three, to represent the additive risk from regeneration 

harvest. The BLM derived this factor from the relationship of observed landslides in varying forest age 

classes on the Siuslaw National Forest during the 1996 storms; the landslide density in stands less than 10 

years old was approximately 3 times the average of stands over 10 years old (Miller and Burnett 2007a).
396 | P a g e

The BLM did not include potential increases to relative landslide risk from new road construction in this 

analysis. This is a change from the methodology described in the Planning Criteria (USDI BLM 2014, p. 

81). Roads do have the potential to increase landslide risk (Weaver and Hagans 1996, Miller and Burnett 

2007a). However, under all alternatives and the Proposed RMP, the BLM would construct few miles of 

new roads relative to the existing road system (see Trails and Travel Management in this chapter). 

Furthermore, most new roads under all alternatives and the Proposed RMP would be built on stable areas 

such as ridge top locations, and would mostly be short spurs to the existing collector roads.

The BLM evaluated the effects of timber harvest on relative landslide density over 50 years. This long 

period is appropriate, given the importance of stochastic events with long return-intervals (i.e., heavy 

precipitation) to the underlying landslide risk. Furthermore, this long period is necessary in the analysis to 

distinguish differences in timber harvest implementation and provide basis for meaningful comparison of 

the effects of the alternatives and the Proposed RMP.

The BLM used combined landslide density and delivery models in NetMap to calculate the relative 

susceptibility for direct debris-flow impacts to all stream channels. The BLM classified the traversal 

proportion grid in NetMap to determine the top 80 percent of debris flow risk areas that would transverse 

stream segments, based on the cumulative distribution of values. The BLM intersected the regeneration 

harvest projected in the Woodstock model by alternative and the Proposed RMP and by decade with the 

debris flow risk proportions data layer from NetMap. From this intersection, the BLM determined the 

potential area of debris flow susceptibility by alternative and the proposed RMP and decade that may be 

further elevated by regeneration harvest.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 80–82).

Background

Mountainous topography in western Oregon includes steep slopes, shallow soils, and underlying rock 

types that may trigger shallow, rapidly moving landslides under high rainfall conditions. Observed 

differences in the spatial density of landslides are explained in part by variations in geology, topography, 

and vegetation (Dragovich et al.1993). Forests on steep slopes provide partial stability by roots spreading 

providing mechanical strength and binding of the soil. The important distribution of roots is in the lateralhorizontal direction. Vertical distribution of roots is less important for shallow landslides, because few 

roots cross the shear plane of the landslides (Schwarz et al. 2012). The density of tree roots, especially 

coarse roots and branching, is important in maintaining slope stability. Tree-to-tree root grafting further 

improves slope stability for selective harvest types. Eis (1972) found that 45 percent of selectively cut 

Douglas-fir trees were root grafted, and approximately half of the stumps from cut trees were still alive 22 

years later.

Not all landslides result in effects on streams, as only 30–70 percent of landslides actually deliver 

sediment and other material to streams (Miller and Burnett 2007a). A rapidly moving landslide in a 

stream channel (also called debris torrent or sluice-out) is high velocity slurry of soil, rock, vegetation 

debris, and water that can travel long distances from an initiation site through steeply confined mountain 

channels. The travel distance of channelized debris torrents depends upon slope gradient, valley width, 

and high angle tributary junctions. As debris torrents move downhill, they entrain additional sediment and 

organic debris that can expand the original volume by 1,000 percent or more, being more destructive with 

distance traveled (Benda and Cundy 1990). Debris torrents lose energy and terminate at high angle stream 

tributary junctions and low gradient valley floors.
397 | P a g e

Affected Environment and Environmental Consequences

Figure 3-91 shows the proportion of slopes that are greater than 75 percent by alternative and the 

Proposed RMP in the Harvest Land Base. These steep slopes occur on 2–4 percent of the Harvest Land 

Base (8,000–27,000 acres) among the alternatives and the Proposed RMP.

Figure 3-91. Proportion of the Harvest Land Base with steep slopes > 75 percent

* The No Action alternative includes the Matrix and Adaptive Management Area acres, where regeneration harvest treatment 

would occur, to compare with the Harvest Land Base in the action alternatives and Proposed RMP.

The naturally occurring relative landslide density within the Harvest Land Base is similar among the 

alternatives and the Proposed RMP, although not identical (Figure 3-92). The differences are a result of 

the proportion of decision area that would be allocated to the Harvest Land Base under each alternative 

and the Proposed RMP. Among all alternatives and the Proposed RMP, almost half of the Harvest Land 

Base would have a relative landslide density of zero, meaning there would effectively be no risk of 

landslides. The BLM would include a slightly higher percentage of the Harvest Land Base under 

Alternative A with a relative landslide density of zero, compared to the other alternatives and the 

Proposed RMP. The alternatives and the Proposed RMP would all have a similar percentage of the 

Harvest Land Base, approximately 2 percent, with the highest relative landslide density (greater than 1 

per square mile). As noted in the 2008 FEIS, the Harvest Land Base under the No Action alternative (i.e., 

Matrix and Adaptive Management Areas) is the portion of the decision area with the lower naturally 

occurring landslide density. In contrast, the Riparian Reserve, Late-Successional Reserve, and nonforested lands have more than twice the area where modeled naturally occurring landslides exceed 1 per 

square mile (USDI BLM 2008, p. 349).

3.99

2.40

2.62

3.61 3.46

2.41

0

1

2

3

4

5

No Action* Alt. A Alt. B Alt. C Alt. D PRMP

Harvest Land Base with Steep Slopes > 75% 
398 | P a g e

Figure 3-92. Cumulative area of naturally occurring modeled landslide density within the Harvest Land 

Base, number/square mile

Over 50 years, the average landslide density in the Harvest Land Base would increase by varying amounts 

among the alternatives and the Proposed RMP. Alternative C would have the highest average landslide 

density, and the Proposed RMP and Alternative A would have the least (Figure 3-93). Alternatives A and 

C would have the most increase in average relative landslide density from the naturally occurring 

landslide density, and Alternative D would have the least. In descending order, Alternatives A, the No 

Action alternative, the Proposed RMP, and Alternative B would have less increase in average relative 

landslide density from the naturally occurring landslide density than Alternative C, but more than 

Alternative D.

46.4 52.2 47.8 45.0 45.5 49.3

37.8

34.9 37.6 38.0 37.9

36.8

14.1 11.5 13.0 14.8 14.7 12.6

1.8 1.4 1.6 2.1 1.9 1.4

0

20

40

60

80

100

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Naturally-occuring Modeled Landslide Density in 

Harvest Land Base (Percent)

0/sq. mi. 0.01 to 0.25/sq. mi. > 0.25 to < 1/sq. mi. 1 to 5/sq. mi.
399 | P a g e

Figure 3-93. Relative landslide density in the Harvest Land Base compared to intrinsic potential at 2013

The alternatives and the Proposed RMP would vary in the levels of regeneration harvest, and 

consequently in the potential effect on landslide density. Over 50 years, under Alternative A, the BLM

would implement regeneration harvest on the largest percentage of the Harvest Land Base at 10 percent, 

followed by Alternative C at 9 percent, the No Action alternative at 9 percent, the Proposed RMP at 7 

percent, Alternative B at 5 percent, and Alternative D at 3 percent.

The differences in relative landslide density among the alternatives and the Proposed RMP are a result of 

a combination of (1) the naturally occurring relative landslide density that is included in the Harvest Land 

Base and (2) the amount and specific locations of regeneration harvest. Within the Harvest Land Base, 

Alternatives C and D have approximately 30 percent more acres of steep slopes (Figure 3-91), compared 

to Alternatives A and B, and the Proposed RMP, and a corresponding higher natural relative landslide 

density. The No Action alternative, Alternatives B and D, and the Proposed RMP would retain live trees 

within the regeneration harvest units, in contrast to clearcut harvest under Alternatives A and C. This 

retention within regeneration harvest units may reduce the average relative landslide density towards what 

is naturally occurring, but the degree of improvement is not known. The highest risk of landslides is 

restricted to 2 percent of the Harvest Land Base upon steep slopes, where modeled naturally occurring 

landslides would exceed 1 per square mile. The average relative landslide density differences among the 

alternatives and the Proposed RMP in Figure 3-93 are slight and similar to what would naturally occur. 

Contrasted to regeneration harvest areas, a small percentage of Young, Mature, and Structurally-complex 

stands would naturally fail over time, regardless of forest management.

The size and placement of the Harvest Land Base is as important as the intensity of regeneration harvest. 

For example, as shown in Figure 3-93, Alternatives A and B, and the Proposed RMP would have lower 

average landslide density with regeneration harvest than the naturally occurring landslide density of the 

0.11

0.12

0.13

0.14

0.15

0.16

0.17

0.18

2013 2023 2033 2043 2053 2063

Relative Landslide Density (Number/Mile

2

)

Years

No Action Alt. A Alt. B Alt. C Alt. D PRMP

No Action

Alt. C

Alt. D

Alt. A PRMP

Alt. B
400 | P a g e

No Action alternative, indicating the importance of included or excluded lands in the Harvest Land Base 

and where suitable stands are available for regeneration harvest. During project planning, the BLM would 

evaluate project areas for slope stability and would reserve unstable areas under the TPCC system.

Under all alternatives and the Proposed RMP, portions of the Harvest Land Base would be susceptible to 

deliver sediment to a channel by shallow landsliding, whether managed or not. In the context of extreme 

storms, an average of 8 percent of the regeneration harvest areas under all alternatives and the Proposed 

RMP (ranging from 4 percent under Alternative D in 2023 to 13 percent in Alternative C in 2063) would 

have some measure of susceptibility to deliver to a channel over the next 50 years. The remaining 

regeneration harvest areas would have essentially no susceptibility at all. Figure 3-94 shows the acres of 

channelized debris flow susceptibility for Alternative C by decade would be approximately twice the 

acreage under the No Action alternative, while the acreage under Alternatives A and B, and the Proposed 

RMP would be approximately 50 percent of the acreage under the No Action alternative. The acres of 

channelized debris flow susceptibility by decade under Alternative D would be approximately 25 percent

of the acreage under the No Action alternative.

Figure 3-94. Regeneration harvest area with debris flow susceptibility, acres per decade

Shallow landsliding may contribute sediment, rocks, and forest debris to stream channels from susceptible 

portions of regeneration harvest areas during extreme storms, and from other unmanaged areas of the 

Harvest Land Base. There is increased risk for landsliding where the combination of steep slopes and 

geomorphic factors lower hill slope stability. Removal of vegetation by regeneration harvest would lower 

the strength of live roots binding the soil. If an extreme storm would occur during the Early Successional 

structural stage, the susceptibility of landsliding would be increased compared to forests where basal area 

would be maintained. Under all alternatives and the Proposed RMP over the next 50 years, the area of 

increased landsliding susceptibility with potential to deliver to streams would average no more than 8

percent of the regeneration harvest area and less than 1 percent (0.57 percent) of the Harvest Land Base.

0

2,000

4,000

6,000

8,000

10,000

2023 2033 2043 2053 2063

Regeneration Harvest Area with Debris Flow 

Susceptibility (Acres per Decade)

Years

No Action Alt. A Alt. B Alt.C Alt. D PRMP

Alt. C

No Action

Alt. D

Alt. A

PRMP Alt. B
401 | P a g e

Issue 4

How would new BLM road construction and road decommissioning under the alternatives affect 

disturbance and sources of fine sediment that may be delivered to stream channels?

Summary of Analytical Methods

This analysis compares surface erosion for existing roads and the projected new roads under each 

alternative and the Proposed RMP. Sediment delivery from roads can result from surface erosion, 

gullying, and mass wasting. However, due to limitations of model capability and geospatial processing 

across the planning area, this discussion is restricted to surface erosion from roads.

The empirical basis for this analysis is the Washington Road Surface Erosion Model (WARSEM; Dube et 

al. 2004). In this analysis, the BLM used the WARSEM methodology combined with BLM GIS data 

layers to derive estimates of annual long-term sediment production. Factors affecting surface erosion 

include geologic parent material, surface type, age of the road, road drainage, degree of vegetative cover 

on cut and fill slopes, and traffic factors such as winter haul. In this analysis, the BLM evaluated 

watersheds (approximately 60–300 miles2; U.S. Geological Survey hydrologic unit code 10, which had 

previously been termed 5

th field watersheds).

In this analysis, the BLM used projected timber volume and road ratios by harvest type as described in the 

Planning Criteria (USDI BLM 2014a, pp. 127–128, Tables 28–31) to determine miles of new temporary 

and permanent road construction for natural and aggregate surfaced road for forest treatment types other 

than commercial thinning under each alternative and the Proposed RMP (USDI BLM 2008, Appendix I –

Water, pp. 239–240). For new temporary and permanent road construction for commercial thinning, the 

analysis used actual new road construction ratios derived from six years (FY2007–FY2012) of harvest 

volume sold data and timber sale contract data, rather than the estimated new road construction ratios for 

commercial thinning from the 2008 FEIS (see the Trails and Travel Management section of this chapter). 

The BLM used these road estimates to calculate miles of existing and new, permanent BLM road 

construction by surface type within a 200-foot sediment delivery distance to streams using selected 

WARSEM parameters (formally DNR Reference Road model).

The modeled sediment delivery distance (200 feet) takes into account existing roads paralleling streams 

and existing roads with inside ditches that carry concentrated flow farther away from a stream due to lack 

of ditch relief culverts. This modeled distance is of little relevance to thinning activities and new road 

construction in the Riparian Reserve, because these roads are farther than the mean sediment travel 

distance to a stream and are separated by the no-harvest portions of the Riparian Reserve. 

This analysis calculated potential fine sediment delivery (tons/year) from new temporary and permanent 

roads by alternative and the Proposed RMP through 2023. Although the Planning Criteria displayed 

calculations over a longer period, this analysis is restricted to a ten-year time span because estimations of 

road construction beyond ten years become speculative. After ten years of implementation of any 

alternative or the Proposed RMP, the road system would be fully developed for the most part. That is, the 

BLM would have built most of the road network necessary to provide access to the actively managed 

forest stands, and road construction would decline over time. In addition, new road construction, logging 

technology, and changing harvest types would continue to reduce the road construction necessary to 

provide access to the actively managed forest stands. Therefore, potential fine sediment delivery from 

new roads in future decades would be lower than the sediment delivery calculated for the first decade.
402 | P a g e

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI 2014, pp. 

82–88).

Background

Soil erosion is a natural occurrence in a forested landscape, aided by water, climate, gravity, soil 

properties, and lack of vegetative cover. Forest roads are unnatural, compacted surfaces and offer 

opportunities for accelerated erosion and potential sediment delivery to stream channels from a variety of 

sources, including small slumps and slides into the roadway from the cut bank; water channeling from the 

road or ditches if not properly directed and controlled; and blocked culverts and road fill washouts during 

floods. Sediment sources from roads are described in more detail in the 2008 FEIS, which is incorporated 

here by reference (USDI BLM 2008, pp. 343–346).

Roads can deliver up to 90 percent of the total sediment production from forestry activities. This 

especially occurs on older roads where mid-hillslope construction and side casting of excess soil material 

was common (EPA 2005). Roads built in the last 30–40 years typically use ridge top locations or fullbench construction practices across steep slopes, removing excess soil material to offsite waste areas and 

managing drainage effectively. In general, modern road construction practices produce less sediment from 

forest roads than older road construction practices (Copstead 1998).

The distance that sediment travels along roadways depends upon a number of factors, including 

underlying geology, age of road since construction, road gradient, road drainage, and ground cover. The 

average sediment travel distance from seven studies in different geologies, including highly relevant 

studies in western Oregon, is 40 feet, with a range of 0–639 feet. Sediment travel distances from roads are 

described in more detail in the 2008 FEIS, which is incorporated here by reference (USDI BLM 2008, p. 

345).

There are 14,330 miles of inventoried BLM-controlled roads in the planning area, of which 1,390 miles 

have a paved surface (10 percent), 10,242 miles have a gravel surface (71 percent), and 2,698 miles have 

a natural surface (19 percent). There are a higher proportion of paved roads in the precipitation-dominated 

Coast Range province than in the drier Klamath province. When evaluating all BLM-controlled roads, the 

highest potential sediment yield is from natural surface roads, which average 9.61 tons/mi2/year. The 

lowest yield is from paved roads, which average 1.58 tons/mi2/year (USDI BLM 2008, p. 346).

Approximately 36 percent of all existing BLM-controlled roads on BLM-administered lands are within a 

200-foot delivery distance (5,096 miles of 14,330 total miles). The average potential fine sediment

delivery yield to streams from existing BLM-controlled roads within the 200-foot sediment delivery 

distance is 2.26 tons/mi2/year as shown in Table 3-66 (USDI BLM 2008, p. 347, Table 3-59).
403 | P a g e

Table 3-66. Potential fine sediment delivery from existing roads

Existing 

Roads*

Roads Within Fine 

Sediment Delivery 

Distance (Miles)†

Potential Fine Sediment 

Delivery

(Tons/Year)‡

Watershed Potential Fine 

Sediment Delivery 

(Tons/Mile2/Year)‡

BLM Other BLM Other BLM Other

Natural 1,738 15,874 23,050 233,054 0.86 8.75

Aggregate 2,590 22,938 28,938 30,765 1.09 1.15

Paved 767 2,436 8,277 33,807 0.31 1.27

Totals 5,096 21,249 60,265 297,626 2.26 11.17

* Includes BLM-controlled roads and private roads within the decision area from BLM GIS GTRN (roads) coverage

† Includes road segments within 200 feet of a stream channel, where ditch flow carrying fine sediment could enter streams

‡ Planning criteria estimate in which calculations are based on surface type for each HUC 10 watershed and summed for the 

planning area

Implementation of best management practices (BMPs;

70 Appendix J) is a primary reason that BLMcontrolled roads currently result in a minor portion of the total sediment delivery to streams from roads. 

The BLM has decommissioned about 900 miles (6 percent) of the road system (i.e., the BLM has closed 

the road to vehicles and left the road in an erosion-resistant condition). A small percentage of these 

decommissioned roads are within the 200-foot sediment delivery distance. The process of 

decommissioning includes the application of BMPs, including blocking the road, out-sloping and adding 

waterbars for drainage control, applying erosion control, and ensuring stream hydrologic conductivity, all 

features that reduce the potential sediment delivery from roads.

Forest management activities require adherence to management direction and the application of 

applicable BMPs in designing and constructing permanent and temporary roads under all alternatives and 

the Proposed RMP to maintain or improve water quality. The BMPs include methods that either avoid or 

minimize the delivery of sediment to streams. Specific BMPs have been developed for timber harvest, 

road construction, maintenance, and decommissioning, energy and mineral development, fuel reduction 

treatments, and other forest activities. Examples of the important BMPs that involve road construction 

and use are shown in Table 3-67.

 

70 Best management practices (BMPs) are methods, measures, or practices selected based on site-specific conditions 

to ensure that the BLM would maintain water quality at its highest practicable level to meet water quality standards 

and TMDL allocations as set by the State of Oregon, Department of Environmental Quality (Appendix J).
404 | P a g e

Table 3-67. Best management practices for road and landing construction*

Best Management Practice

Oregon Department of Forestry (ODF)/

Oregon Administrative Rules (OAR) Forest 

Roads - Division 625

Locate temporary and permanent roads and landings on 

stable locations (e.g., ridge tops, stable benches, or 

flats, and gentle-to-moderate side slopes). Minimize 

construction on steep slopes, slide areas, and high 

landslide hazard locations.

(OAR) 629-625-0200 (3) ODF, Road Location

Locate temporary and permanent road construction or 

improvement to minimize the number of stream 

crossings.

(OAR) 629-625-0200 (3-4) ODF, Road 

Location

Design roads to the minimum width needed for the 

intended use. (OAR) 629-625-0310 (3) ODF, Road Prism

Place sediment-trapping materials or structures such as 

straw bales, jute netting, or sediment basins at the base 

of newly constructed fill or side slopes where sediment 

could be transported to waters of the State.

(OAR) 629-625-0440 ODF, Stabilization

Retain ground cover in ditch lines, except where 

sediment deposition or obstructions require 

maintenance.

(OAR) 629-625-0600 ODF, Road Maintenance

Retain low-growing vegetation on cut- and fill-slopes. (OAR) 629-625-0600 ODF, Road Maintenance

* BLM BMPs are cross-walked to applicable Oregon Forest Practices and Oregon Administrative Rules

The BLM implements BMPs as a program of practices, rather than as individual practices. The BLM will 

select BMPs based upon site-specific conditions, technical feasibility, resource availability, and the water 

quality of those waterbodies potentially impacted. As such, it is not possible at this scale of analysis, to 

analyze the effectiveness of each individual BMP for each site and project. The BLM presents BMPs as a 

program of practices because the appropriateness, feasibility, and effectiveness of an individual BMP 

depends on the individual site and project. Nevertheless, the BLM has evaluated the effectiveness of 

BMPs through monitoring, plan evaluation, and consideration of research, and has concluded that the 

application of BMPs is effective as a program of practices. Implementation monitoring, documented in 

annual program summaries, has evaluated whether BMPs are properly designed and applied in projects, 

and has concluded that application of BMPs is appropriate, necessary, and effective (e.g., USDI BLM 

2012a, p. 12; USDI BLM 2013, p. 14; and USDI BLM 2014b, p. 52). The BLM considered the 

application of BMPs in the 2012 plan evaluation and concluded that plan maintenance would be 

appropriate to incorporate new BMPs, but that application of BMPs is adequate to meet resource needs 

and is meeting expected outcomes (USDI BLM 2012b, p. 4). A U.S. Forest Service review of BMP 

monitoring concluded that BMPs protect surface waters and are implemented correctly at least 86 percent

of the time and are effective in 85–99 percent of applications (USDA FS 2012, pp. 9–10).

The Proposed RMP includes management direction for several key preventative measures that the 

alternatives present as BMPs for road and landing construction and maintenance (see Appendix B). 

Examples of the Proposed RMP management direction are shown in Table 3-68 as well as how they meet 

applicable Oregon Administrative Rules.
405 | P a g e

Table 3-68. Proposed RMP key management direction for road and landing construction and 

maintenance*

Appendix B – Management Direction for the 

Proposed RMP

ODF/ Oregon Department of 

Environmental Quality (ODEQ) OARs*

Implement road improvement, storm proofing, 

maintenance, or decommissioning to reduce or 

eliminate chronic sediment inputs to stream channels 

and waterbodies. This could include maintaining 

vegetated ditch lines, improving road surfaces, and 

installing cross drains at appropriate spacing.

OAR 629-625-0600-ODF, Road Maintenance

ODEQ-Water Pollution:

Antidegradation OAR 340-041-0004(1)

Statewide Narrative OAR 340-041-0007(1), (7)

Turbidity OAR 340-041-0036

Suspend commercial road use where the road surface is 

deteriorating due to vehicular rutting or standing water, 

or where turbid runoff may reach stream channels.

OAR 629-625-0700-ODF, Wet Weather Road 

Use

ODEQ-Water Pollution:

Antidegradation OAR 340-041-0004(1)

Statewide Narrative OAR 340-041-0007(1), (7)

Turbidity OAR 340-041-0036

Decommission roads that are no longer needed for 

resource management and are at risk of failure or are 

contributing sediment to streams, consistent with valid 

existing rights.

OAR 629-625-0650-ODF, Vacating Forest 

Roads

ODEQ-Water Pollution:

Antidegradation OAR 340-041-0004(1)

Statewide Narrative OAR 340-041-0007(1), (7)

Turbidity OAR 340-041-0036

Design culverts, bridges, and other stream crossings for 

the 100-year flood event, including allowance for bed 

load and anticipated floatable debris. Culverts shall be 

of adequate width to preclude ponding of water higher 

than the top of the culvert. Design stream crossings 

with ESA-listed fish to meet design standards 

consistent with existing ESA consultation documents 

that address stream crossings in the decision area.

OAR 629-625-0600-ODF, Road Maintenance

OAR 629-625-0320-ODF, Stream Crossing 

Structures

ODEQ-Water Pollution:

Antidegradation OAR 340-041-0004(1)

Statewide Narrative OAR 340-041-0007(1), (7)

Biocriteria OAR 340-041-0011

Turbidity OAR 340-041-0036

* Management direction for the Proposed RMP is cross-walked to applicable Oregon Forest Practices, Oregon Department of 

Environmental Quality, and Oregon Administrative Rules.

Affected Environment and Environmental Effects

The 5,096 miles of existing BLM-controlled roads within the 200-foot sediment delivery distance 

produce 60,265 tons/year of fine sediment that could be delivered to streams.

The alternatives and the Proposed RMP would include new road construction that would increase the 

amount of potential fine sediment delivery through 2023. The incremental increase in potential fine 

sediment delivery from new road construction over the next 10 years would range from 93 tons/year 

under Alternative D to 369 tons/year under the No Action alternative, as shown in Figure 3-95. Under all 

alternatives and the Proposed RMP, this would constitute less than a 1 percent increase above current 

levels of fine sediment delivery from existing roads (note the logarithmic scale of Figure 3-95). Although 

the absolute values for increased potential fine sediment delivery through 2023 vary, these differences do 

not represent a substantial difference in effects, because the increases in sediment delivery and the 
406 | P a g e

differences among the alternatives and the Proposed RMP in future increases in sediment delivery are 

inconsequential in comparison to the existing sediment delivery. 

60,265

369

116

201 269

93

165

1

10

100

1,000

10,000

100,000

Existing

Roads

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Potential Fine Sediment Delivery

(Tons/Year)

Figure 3-95. Potential fine sediment delivery,*†to streams from new roads by 2023. 

* The vertical axis is logarithmic to view the range of data. 

† A numerical error was corrected for existing roads, to correspond to Table 3-66. Specifically, existing roads potential fine 

sediment delivery to streams was modeled at 60,265 tons/year rather than 51,988 shown in this figure in the Draft RMP/EIS. This 

correction includes the effects of paved roads within the sediment delivery buffer that were previously overlooked. 

This increase in potential fine sediment delivery would vary under the alternatives and the Proposed RMP 

with the amount of new road construction within the sediment delivery distance as shown in Figure 3-96. 

Under all alternatives and the Proposed RMP, fewer new roads would be located inside the 200-foot 

sediment delivery distance, because many transportation routes that parallel streams within a sediment 

delivery distance to streams are existing, permanent roads. Under Alternatives A and D, and the Proposed 

RMP, there would be an average of a 1 percent increase for new permanent and temporary roads within a 

sediment delivery distance to streams channels while the No Action alternative, and Alternatives B and C 

would average no more than 2 percent increase. Comparatively, upland areas outside a sediment delivery 

distance would average a 7 percent increase for new permanent and temporary roads under Alternatives 

A, B, and D, and the Proposed RMP, while Alternative C and the No Action alternative would average a 

14 percent increase, as shown in Figure 3-96.

71

 

71 The road ratios for harvest type and volume are proportioned inside the sediment delivery buffer at the same rate 

as upslope, which overestimates newly constructed permanent roads. 
407 | P a g e

Figure 3-96. Projected newly constructed roads within a sediment delivery distance compared to newly 

constructed roads outside a sediment delivery distance by 2023*

* Includes permanent and temporary roads

Under the action alternatives and the Proposed RMP, the BLM would not thin the inner zone of the 

Riparian Reserve, which would substantially reduce the need for road construction in the sediment

delivery distance and ensure that the Riparian Reserve would maintain an effective sediment filtration 

area along streams. This inner zone would vary in width by alternative and the Proposed RMP for stream 

periodicity and fish presence, from 50–120 feet along each side of a stream. New construction would 

intrude into the 200-foot sediment delivery distance only where there would be no other reasonable routes 

to access upslope forest stands. Except for roads very near the stream channel or stream crossings (with 

connected ditches to the first upslope cross-drain), this no-harvest, inner zone of the Riparian Reserve 

would result in effective sediment filtration, when compared to the mean sediment travel distance of 40 

feet (USDI BLM 2008, p. 345, Table 3-58). 

Under Alternative D and the Proposed RMP in Class I subwatersheds, the BLM would only thin stands in 

the outer zone of the Riparian Reserve to provide trees that would function as stable wood in the stream, 

which would require fewer roads than under the No Action alternative and Alternatives A, B and C.

Under the No Action alternative, Alternatives B, C, and D, and the Proposed RMP in Class II and Class 

III subwatersheds, the BLM would thin stands in the outer zone of the Riparian Reserve to promote the 

development of large, open grown trees, develop layered canopies, and multi-cohort stands, which would 

require comparatively more roads than Alternative D and the Proposed RMP in Class I subwatersheds. 

Additionally, under Alternative A, the BLM would not commercially thin stands in the outer zone of the 

Riparian Reserve in moist forests and only for the purpose of fuels reduction in the dry forests, further 

reducing the need for roads within the sediment delivery distance.

There is an element of uncertainty related to road construction within the sediment delivery boundary 

under the No Action alternative compared to the action alternatives and the Proposed RMP. As explained 

earlier in analytical methods, under the No Action alternative the BLM is allowed to thin anywhere in the 

Riparian Reserve with no specific retention requirements. This results in greater uncertainty when 

154

779

47

254

80

451

109

593

38

205

66

373

0

100

200

300

400

500

600

700

800

Inside Sediment

Delivery Boundary

Outside Sediment

Delivery Boundary

Constructed Roads (Miles)

No Action Alt. A Alt. B Alt. C Alt. D PRMP
408 | P a g e

estimating the effectiveness of Riparian Reserve in providing a sediment filtration area along streams for 

the No Action alternative.

Under all alternatives and the Proposed RMP, the BLM would decommission 372 miles of permanent 

road by 2023, bringing the total road mileage in long-term storage to 1,272 miles (8 percent of the entire 

road system). Decommissioning includes a variety of practices, ranging from simply blocking access to 

the road to full decommissioning, which may include re-establishing drainage by removing culverts, and 

re-contouring and planting the roadbed. The BLM estimates that approximately 0.25 percent of the roads 

decommissioned would be fully decommissioned, which would typically reduce potential fine sediment

delivery by 11–13 tons/mile/year, based on the data used to derive Table 3-66. For all decommissioned 

roads, potential fine sediment delivery would decline over time, but the amount of improvement would be 

difficult to estimate. The reduction in potential fine sediment delivery following decommissioning would 

depend on site-specific and road-specific factors, proximity to streams, and the level of decommissioning, 

which cannot be predicted and evaluated at this scale of analysis. The BLM may reopen these 

decommissioned roads in the future if needed to provide access for management, such as when timber 

stands in the Harvest Land Base reach harvestable age. Unneeded roads would remain decommissioned. 

Which roads would be decommissioned and whether they would remain decommissioned would depend 

on site-specific and road-specific conditions related to whether the road would be needed to provide 

access for future management actions.

Issues Considered but not Analyzed in Detail

How would timber harvest under the alternatives affect annual water yields?

The effect of timber harvest on annual water yield was not analyzed in detail, because none of the 

alternatives or the Proposed RMP would have a substantial effect on annual water yield. Timber harvest

can increase annual water yield and streamflows by reducing evapotranspiration; changes to annual yield 

are generally proportional to the amount of vegetation removed (Harr et al. 1982, Bosch and Hewlett 

1982, Satterlund and Adams 1992). Harvested areas do not permanently change annual water yield. As 

trees are replanted and grow, evapotranspiration would increase over time, thereby reducing annual water 

yield to pre-harvest levels. The majority of the decline in annual water yield occurs in the first 10 years 

after harvest (Jones and Grant 1996, Thomas and Megahan 1998, Jones 2000). A summary of past small 

basin studies undertaken in the Oregon Cascades show that an annual water yield increase of 26–43

percent is possible when small catchments are entirely clearcut, including the riparian area. However, 

clearcut harvesting of up to 25 percent of these small catchments, including the Riparian Reserve, showed 

no substantial change in annual water yield (Moore and Wondzell 2005). Stednick (1996) found that 

approximately 25 percent of a watershed in western Oregon rain-dominated hydroregions needed to be 

clearcut to detect a measurable increase in annual water yield. Because of the limited extent of the 

Harvest Land Base, none of the alternatives or the Proposed RMP would regenerate more than 25 percent 

of a watershed in a single decade. Furthermore, the no-harvest Riparian Reserve under all alternatives and 

the Proposed RMP would avoid or reduce any effect of timber harvest on annual water yield, intercepting 

any additional flow of water before it could reach the stream network. Timber harvest associated with the 

alternatives and the Proposed RMP would produce an inconsequential change in annual water yield.

How would timber harvest under the alternatives affect low water flows?

The effect of timber harvest on low water flows was not analyzed in detail, because none of the 

alternatives or the Proposed RMP would have a measurable effect on low water flows at the subwatershed 

or watershed scale. Many hydrologic studies summarized by Moore and Wondzell (2005) show that 
409 | P a g e

summer low water flows can be increased in magnitude where riparian vegetation has been harvested. 

The data are inconsistent between studies, and, where studies found increases in flow, the increases in

absolute volumes were small. Comparatively, an important difference between these studies and this 

analysis is that riparian vegetation would not be removed under any of the alternatives or the Proposed 

RMP. Even though the alternatives and the Proposed RMP would include thinning in some portions of the 

Riparian Reserve, none would remove stands located along streams. Given that no stands along streams 

would be completely removed and the limited extent of the Harvest Land Base under all alternatives and 

the Proposed RMP, there is no reasonably foreseeable measurable effect of harvesting outside of riparian 

areas on low water flows.

The Climate Change section of this chapter describes that changing climate conditions could result in 

decreasing summer stream flows over the next century. However, this forecast in decreasing low water 

flows is describing a trend in the resource condition, rather than an effect of BLM management.

How would timber harvest and road construction under the alternatives affect water flow duration and 

timing?

The effect of timber harvest and road construction on water flow duration and timing was not analyzed in 

detail, because none of the alternatives or the Proposed RMP would have a measurable effect on water 

flow duration and timing at the subwatershed or watershed scale. Streamflow duration and timing are

guided by the frequency, magnitude, and duration of maritime precipitation, interacting with varying 

watershed features (e.g., basin orientation, relief, drainage density, vegetative cover, soil depth, and soil

properties). Flow duration and timing of runoff at progressively higher to lower volumes closely follow 

the winter storm season and summer dry season. Research has found differences in timing of water flow 

on an experimental watershed basis, but only under extreme circumstances restricted to the site scale,

(e.g., areas with high proportion of regeneration harvest on highly compacted sites and high road density 

with many road stream connections (Moore and Wondzell 2005)). This section does analyze in detail how 

timber harvest and road construction under the alternatives or the Proposed RMP would affect peak 

stream flows within the rain-on-snow dominated hydro-region. Timber harvest and road construction 

under the alternatives and the Proposed RMP would not have measurable effects on other aspects of water 

flow duration and timing at the subwatershed or watershed scale because of the overwhelming influence 

of climate and intrinsic watershed characteristics.

How would timber harvest under the alternatives affect nutrient loading in streams?

The effect of timber harvest on nutrient loading in streams was not analyzed in detail because none of the 

alternatives or the Proposed RMP would have a significant effect on nutrient loading in streams. The 

nutrients of potential concern for streams are nitrogen and phosphorus. Nitrate, dissolved inorganic 

nitrogen, can enter aquatic ecosystems via point sources (e.g., farm and aquaculture wastewater, and 

municipal and industrial sewage) and nonpoint sources (e.g., cultivation of nitrogen-fixing crops, use of 

animal manure and inorganic nitrogen fertilizers, and logging and fuels management treatments that 

remove vegetation and increase leaching from forest soils). Streamside areas can remove dissolved 

nitrogen from subsurface water by denitrification, plant uptake, and microbial uptake (Sweeney and 

Newbold 2014 and references therein). Phosphorous as phosphate can be lost through soil erosion and, to 

a lesser extent, to water running over or through soil. Because phosphate is relatively immobile in soils, 

erosion control practices minimize phosphate loading to streams.

Under all alternatives and the Proposed RMP, allocation and management of Riparian Reserve would 

reduce or avoid nutrient loading of streams from upslope forest practices. Sweeney and Newbold (2014) 
410 | P a g e

compared the nitrate removal efficiency and buffer width from 30 studies worldwide, half with forest 

vegetation, and concluded that effective nitrogen removal at the watershed scale probably requires buffers 

at least 100 feet wide, and the likelihood of high removal efficiencies continues to increase in buffers 

wider than 100 feet. Nieber et al. 2011 suggest that average nitrogen and phosphorus retention is around 

80 percent for 100-foot buffers. The authors calculated the percentage removal of nitrogen and 

phosphorus into wetlands based on two literature reviews that covered 55 nationwide research papers. 

The Riparian Reserve under all alternatives and the Proposed RMP for perennial and fish-bearing streams 

would range from 150 feet to one site-potential tree height, which compare favorably with effective buffer 

widths in these references, indicating that the Riparian Reserve under all alternatives and the Proposed 

RMP would provide effective nutrient filters on these streams. 

Riparian Reserve widths of 50 feet on non-fish-bearing intermittent streams in Alternatives B and C and 

in Class III subwatersheds in the Proposed RMP may not, in and of themselves, be sufficient to prevent 

nutrient loading to streams on all sites. Several factors that control buffer effectiveness (e.g., vegetation 

characteristics, slope, soil compaction and texture, percent organic matter, and subsurface water flux) are 

dependent on site-specific conditions (Nieber et al. 2011, Sweeney and Newbold 2014) that cannot be 

fully assessed at the scale of this analysis. However, the potential for nutrient loading in these streams is 

highly limited. The majority of the acreage upslope of the Riparian Reserve would be allocated to other 

reserve land use allocations, limiting the extent and intensity of upslope timber harvest. Under the 

Proposed RMP, Class III subwatersheds would constitute a small percentage of the decision area (see 

Chapter 2). Timber harvest and manual application of fertilizer upslope of non-fish-bearing intermittent 

streams would be staggered in space and time, minimizing the potential for cumulative effects from 

nutrient loading within the analysis area. In addition, trees remaining in upland thinned stands and 

retention trees in regeneration and selection harvests would increase their growth rate and uptake of 

nutrients and water following harvest (Reiter and Beschta 1995, Chan et al. 2004, Ruzicka et al. 2014).

Maintenance of continuous forest cover and sources of large wood on all streams under all alternatives 

and the Proposed RMP, together with continued in-stream habitat restoration, would ensure effective 

nutrient processing in the decision area, which would further minimize any nutrient loading in streams. 

Peterson et al. (2001) studied nitrogen in headwater streams in North America and found that the most 

rapid uptake and transformation of inorganic nitrogen occurred in the smallest streams where large 

streambed to water volume ratios favor rapid nitrogen uptake and processing. Streams with greater 

complexity, including low-order streams with log and boulder steps and higher order streams enhanced 

with boulders and wood for fish habitat, are more effective at nitrogen uptake than those lacking 

obstructions and backwaters, because the complexity provides more opportunities for water to come into 

contact with stream organisms that process and remove nitrogen (Johnson 2009).

As a result of the Riparian Reserve providing an effective nutrient filter on most or all streams, the limited 

extent and intensity of timber harvest and fertilization upslope of the Riparian Reserve, and the effective

nutrient processing in riparian and aquatic systems, none of the alternatives or the Proposed RMP would 

have a substantive effect on nutrient loading in streams.

How would timber harvest and road construction under the alternatives affect source water watersheds?

The effect of timber harvest and road construction on source water watersheds was not analyzed in detail, 

because the relevant effects are analyzed in detail in other issues. The ODEQ’s mapped source water 

watersheds for Oregon are very general. Source water assessments for individual public water systems

show the area of interest is within an 8-hour travel time above a purveyor’s intake. The public water 
411 | P a g e

systems for BLM-administered lands have been previously identified (USDI BLM 2008, Appendix I –

Water).

72

The BLM’s primary water quality protection strategy is composed of the Riparian Reserve land use 

allocation, especially the inner zone along streams, management direction for the Riparian Reserve and 

hydrology, and the BMPs. These preventative measures have complementary goals with Oregon’s 

drinking water protection program. Table 3-69 shows a risk analysis linking potential contaminants with 

causal mechanisms, management activities, and control.

 

72 This summary includes public water system ID, name, source, population served, BLM-administered acres, and other acres.
412 | P a g e

Table 3-69. Source water protection

Contaminant Causal Mechanism Activity Control

Temperature

Decrease in stream 

shade affected by 

canopy removal

Thinning in Riparian 

Reserve outer zone, along 

each side of perennial and 

fish-bearing streams

Riparian Reserve no-treatment 

zones along streams and 

waterbodies*

Management Direction

Sediment

Sediment delivery 

from roads to 

streams

New road construction, 

maintenance of existing 

roads

Riparian Reserve unmanaged 

inner zones

Management Direction

BMPs

Landslides and 

debris torrents 

Regeneration harvest, new 

road construction

Avoid unstable areas withdrawn 

under TPCC

Riparian Reserve buffer to the 

extent of the unstable area

Management Direction

Surface erosion

New road construction, 

forest harvest, broadcast 

burning

Riparian Reserve unmanaged 

inner zones

Management Direction

BMPs

Concentrated 

livestock grazing in 

riparian areas leading 

to erosion or 

streambank collapse

Livestock grazing

Term permit conditions meeting 

Rangeland Health Standards

Management Direction

BMPs

Bacteria

Improper waste 

disposal, failing 

sewage systems

Recreation

Management Direction

BMPs

Livestock within 

riparian areas, onstream wateringLivestock grazing

Term permit conditions meeting 

Rangeland Health Standards

Management Direction

BMPs

Nutrients

Erosion, fertilizer 

entering 

watercourses

Road construction, forest 

fertilization, recent burns

Riparian Reserve inner zones

BMPs

Herbicides

Application to nontarget areas by drift 

or runoff

Forest herbicide 

application

BLM Vegetation Treatments 

Using Herbicides on BLM Lands 

in Oregon ROD (USDI BLM 

2010) 

Petroleum 

Products Spills

Refueling of equipment, 

transportation and fuel 

storage

Riparian Reserve inner zones

BMPs

* Under the No Alternative there would be no defined no-treatment zones along streams and waterbodies.
413 | P a g e

Potential effects of the alternatives and the Proposed RMP on source water watersheds are related to 

water temperature and sediment delivery to streams. The alternatives and the Proposed RMP would not 

have effects related to the other potential contaminants. Effects on temperature and sediment are analyzed 

in detail in this section, and the effects of the alternatives and the Proposed RMP in source water 

watersheds would be no different from the effects in other watersheds. Segregating these analyses for 

source water watersheds would not improve the quality of the analysis or reveal any additional 

differences in the effects of the alternatives or the Proposed RMP.

How would public motorized vehicle use under the alternatives affect water quality?

The effect of public motorized vehicle use on water quality was not analyzed in detail, because although 

public motorized vehicle use has the potential to affect water quality, there is no basis to evaluate any 

differences in effects among the alternatives or the Proposed RMP due to—

 The limited nature of the RMP decisions on public motorized vehicle travel;

 The lack of comprehensive site-specific information on public motorized vehicle trail conditions 

relevant to water quality effects; and

 The lack of comprehensive site-specific information on intensity of public motorized vehicle use.

The BLM would be better able to address the effects of public motorized vehicle use on water quality as 

the BLM prepares implementation-level transportation management plans subsequent to the adoption of 

the RMP.

Public motorized vehicle use on low-volume roads, partially decommissioned roads, and trails 

(collectively referred to as trails) can affect the water quality of streams and waterbodies by increased 

sediment delivery and contamination from vehicle fluids. Public motorized vehicle trail use is unlikely to 

have any effect on stream temperature, because overstory trees casting shade are generally not removed

because of public motorized vehicle activities.

Public motorized vehicle use can potentially cause sediment delivery to streams and waterbodies, but the 

effects are highly dependent upon site-specific trail conditions. Public motorized vehicle trails typically 

differ from roads in that they are narrow, conform to the topography (instead of excavating into the 

subgrade), and many lack drainage improvements. Compaction of the trail surface can limit water 

infiltration, which can lead to runoff and channeling. Where a trail approaches a stream, sediment can be 

delivered from an eroding trail surface if not diverted or filtered by vegetation. Sediment delivery to 

waterbodies from public motorized vehicle trails in the Riparian Reserve and at unimproved stream 

crossings (also called low water crossings or unvented fords)73 depend upon varying factors, including

geology, valley form, stream type, soils, vegetation, trail design and condition, season of use, allowed 

motorized vehicle class, and intensity of public motorized vehicle use. These factors affecting sediment 

delivery make it difficult to make broad generalizations. 

Marion et al. (2014) studied upstream/downstream effects of 15 high-traffic public motorized vehicle

stream crossing sites that have been active on the Ouachita National Forest for 20 years. Effects included 

increased bank erosion, channel widening, mud coatings on substrate, and in-channel fine-sediment

accumulations at the crossings and a short distance downstream. However, individual effects are small74

 

73 Fords are considered ‘unvented’ when the stream flows over the roadway and ‘vented’ when culverts

are placed in the ford and used to convey normal levels of streamflow under the roadway.

74 Sediment delivery from trails in Marion et al. (2014) (reported in pounds of sediment) was orders of magnitude 

smaller than the sediment delivery from roads in this analysis (reported in tons of sediment).
414 | P a g e

and strongly related to local, climate, channel, and valley geomorphology. Sensitive areas for sediment 

delivery to waterbodies include steep trails near streams, erosion-prone trail surfaces that are not resistant 

to motorized vehicle traffic, and unimproved stream crossings (Brown 1994, cited in Marion et al. 2014). 

Unimproved stream crossings have more effects on water quality than do culverts or bridges, with some 

reported sediment deposition downstream (Taylor 1999). Compared to an unimproved low water 

crossing, a hardened low water crossing (i.e., where the streambed has been excavated and replaced with 

compacted rock and gravel) showed much less sediment downstream (Sample et al. 1998). The BLM 

lacks comprehensive site-specific information on trail conditions relevant to evaluating sediment delivery 

from trails. Unlike existing roads, the BLM does not have a workable, comprehensive inventory showing 

trail locations, stream crossings, trail design, and trail condition.

The intensity of public motorized vehicle use on a trail also influences the potential for sediment delivery 

to streams and waterbodies. The amount of public motorized vehicle traffic and the type of use affect trail 

compaction and erosion.

Compared to highway vehicles, many off-highway vehicles (i.e., all-terrain vehicles, four-wheelers, 

quads, side-by-sides, and off-highway motorcycles) are much lighter with low ground pressure tires, 

distributing weight, and minimizing impact. The small erosion surface of trails and persistence of varying 

amounts of rock, vegetation, duff, and woody material in the roadway, contribute to decreased on-site soil 

loss. The BLM lacks comprehensive information on the amount of traffic and the type of public 

motorized vehicle use on trails in the decision area.

Public motorized vehicle use can potentially cause contamination of streams and waterbodies from 

vehicle fluids. Oil, grease, and other chemical pollutants can wash off motorized vehicles driving through 

streams, depending on streamflow and condition of the vehicle. Vehicle pollutants that have been 

identified on highways include lead, zinc, cadmium, and polychlorinated biphenyls from tire wear; 

asbestos, copper, chromium, and nickel from brake-lining wear; and oil and grease (Hyman and Vary 

1999). However, there is no information regarding whether or not these pollutants have been identified at 

fords accessible to public motorized vehicle use at detectable levels.

The alternatives and the Proposed RMP would designate all lands in the decision area as open, limited, or 

closed for public motorized access. Under all of the action alternatives and the Proposed RMP, the BLM 

would not designate any areas as open for public motorized access. The RMP would not make decisions 

about public motorized vehicle use beyond these area designations (see the Trails and Travel

Management section of this chapter). Given the site-specific nature of water quality effects from public 

motorized vehicle use, it is not possible to equate these area designations with any specific effects of 

public motorized vehicle use on water quality. In areas designated as limited, the BLM would make 

individual trail designations through implementation-level transportation management planning, 

subsequent to adoption of the RMP. In that implementation-level transportation management planning, 

the BLM would be able to evaluate whether individual trails are having effects on water quality and could 

consider restrictions of public motorized vehicle use on individual trails. Under all alternatives and the 

Proposed RMP, the BLM would apply BMPs for trail management as needed to maintain water quality, 

both on an interim basis until implementation-level travel management planning is completed and in 

individual route designations in travel management planning (see Appendix J).

Although the BLM has some site-specific and anecdotal information about illegal public motorized travel 

activities, the BLM does not have a basis for predicting the location or effects of any widespread or 

systematic, illegal public motorized travel activities. In addition, much of the decision area has physical 

limitations to potential, illegal public motorized travel activities, including dense vegetation, steep slopes, 

and locked gates. Terrain, vegetation, and a greater amount of open spaces in most of the interior/south 

can lead to degradation and erosion in a greater proportion than the coastal/north where vegetation is 
415 | P a g e

denser and terrain is steeper. However, the BLM lacks a basis for characterizing current, illegal public 

motorized travel activities or for forecasting potential, illegal public motorized travel activities in the 

future under any of the alternatives and the Proposed RMP at this scale of analysis. In this analysis, the 

BLM assumed that members of the public participating in motorized travel recreation would operate 

vehicles consistent with BLM decisions about public motorized travel opportunities.
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Invasive Species

Key Points

 The risk of introducing and spreading invasive plant species would be lowest under Alternative D 

and highest under Alternative C.

 The risk of introducing and spreading invasive aquatic species would be lowest under Alternative 

A and highest under Alternative C. 

 The No Action alternative, Alternatives C and D, and the Proposed RMP would result in the 

smallest increase in sudden oak death infestation, because the BLM would treat all detected 

infestations. Alternative A would result in the largest increase in sudden oak death infestation.

Summary of Notable Changes from the Draft RMP/EIS

The BLM replaced the discussion of long-term effects on introduction and spread of invasive plant

species and invasive aquatic species with a qualitative summary of the overall risks for each alternative 

and the Proposed RMP. As described in the Draft RMP/EIS, the uncertainties associated with the 

effectiveness of future prevention and treatment measures, as well as uncertainties related to future 

invasive species introductions, render discussion of long-term trends speculative. To the extent it is 

possible to forecast future introduction and spread of invasive plant species and invasive aquatic species, 

it is reasonably foreseeable that the alternatives and the Proposed RMP would have the same relative 

effects in the first decade as in future decades.

Issue 1

How would the alternatives affect the risk of invasive plant introduction and spread?

Summary of Analytical Methods

The BLM compared the relative risk of introducing and spreading invasive species resulting from the land 

use allocations and planned management activity levels under the alternatives and the Proposed RMP, 

taking into consideration the collective distribution of a representative set of invasive plant species. 

Invasive species are non-native species whose introduction does, or is likely to, cause economic or 

environmental harm or harm to human health. The species selected for this analysis characterize the 

general distribution and condition of invasive species occurrences on BLM-administered lands in western 

Oregon. They represent a variety of strategies for introduction, spread, and resistance to certain treatment 

methods. The alternatives’ and Proposed RMP’s differing approaches to land use allocations (including 

designations for public motorized access), timber harvest levels, harvest methods, Riparian Reserve 

widths and management direction, new road construction, and livestock grazing drives the variation in the 

effects on invasive species.

In this analysis, the BLM measured the effects of management actions on the introduction and spread of 

invasive plant species in terms of susceptibility and risk. Susceptibility is the extent to which an area is 

vulnerable to the introduction and spread of invasive species. Risk accounts for both susceptibility to 

introduction and the existing distribution and abundance of invasive species in a given area. The higher 

the susceptibility and the higher the distribution and abundance of invasive species in a particular area, 

the higher the risk is of introducing and spreading invasive species.
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The BLM measured the effects of timber harvest, road management activities, and public motorized 

access designations on the introduction and spread of invasive plant species at the scale of HUC 1075

watersheds (formerly known as 5th field watersheds). The BLM measured the effects of livestock grazing

on the introduction and spread of invasive plant species at the scale of the district or field office. In this 

analysis, the BLM reports effects using the watershed or the district/field office as the basic analytical unit 

in much the same way as a site-specific analysis may report effects in terms of acres, rather than the 

smaller increments representing the extent of the infestations. Even though BLM-administered lands 

constitute a small percentage of many watersheds, BLM management actions could still affect 

susceptibility and risk for the introduction and spread of invasive plant species. Therefore, the BLM 

included all watersheds within the decision area in this analysis.

The BLM used the following factors to assess the relative levels of risk for the inadvertent introduction of 

invasive plant species on the BLM-administered lands:

 Distribution and abundance of invasive plant species

 Types of timber harvest and logging methods

 Proximity of harvest activity to streams

 Intensity and distribution of management activities

 Designations for public motorized access

 Availability for livestock grazing

The analysis assumed that actions on other ownerships and BLM management actions other than timber 

harvest, road management activities, public motorized access designations, and livestock grazing on 

BLM-administered lands would continue to contribute to invasive plant species introduction and spread at 

current levels. These actions include BLM management of special forest products, rights-of-way 

agreements, road maintenance, and fuels reduction treatments. Any future changes in the contribution 

from these other activities to the risk of introduction and spread of invasive plant species would be

speculative and depend largely on site-specific factors that are inappropriate to analyze at this scale. There 

is no basis for speculating that such changes would vary among the alternatives and the Proposed RMP. 

Therefore, information on the contribution of these other management actions to the risk of introduction 

and spread of invasive plant species is not necessary for a reasoned choice among the alternatives and the 

Proposed RMP.

Illegal public motorized travel activities could potentially contribute to the introduction and spread of 

invasive plant species. Although the BLM has some site-specific and anecdotal information about illegal 

public motorized travel activities, the BLM does not have a basis for predicting the location or effects of 

any widespread or systematic illegal public motorized travel activities. In addition, much of the decision 

area has physical limitations to potential illegal public motorized travel activities, including dense 

vegetation, steep slopes, and locked gates. Terrain, vegetation, and a greater amount of open spaces in 

most of the interior/south can lead to degradation and erosion in a greater proportion than most of the 

coastal/north where vegetation is denser and terrain is steeper. However, the BLM lacks a basis for 

characterizing current illegal public motorized travel activities or forecasting such potential illegal public 

motorized travel activities in the future under any of the alternatives or the Proposed RMP at this scale of 

analysis. Therefore, in this analysis, the BLM assumed that members of the public participating in 

motorized travel recreation would operate vehicles consistent with BLM decisions about public motorized 

travel opportunities (see the Trails and Travel Management section of this chapter).

 

75 Hydrologic Unit Codes (HUCs) are a U.S. Geological Survey classification based on a hierarchy of nested 

watersheds.
421 | P a g e

The Planning Criteria provides detailed information on the invasive plant analysis and assumptions, 

including the representative invasive plant species selected for this analysis, which is incorporated here by 

reference (USDI BLM 2014, pp. 90–98). 

Determining Species Distribution Categories 

The BLM pooled representative invasive plant species occurrence data from BLM corporate datasets and 

iMapInvasives (ORBIC 2013). Figure 3-97 displays reported infestations of representative invasive plant 

species within the planning area. The BLM evaluated the collective pool of reported sites to determine 

representative invasive plant presence for each square mile in a grid applied to the planning area. Invasive 

plant species distribution categories of Abundant, Limited, and Low are based on the known 

representative species’ distribution in watersheds:

 Abundant – the representative invasive species reported from more than 25 percent of the 

square miles within the watershed 

 Limited – the representative invasive species reported from more than 1 percent and less than 

25 percent of the square miles within the watershed 

 Low – the representative invasive species reported in no more than 1 percent of the square 

miles within the watershed 

Watersheds in the Abundant species distribution category are more likely to have invasive species 

introduction and spread associated with management and human activities than those in the Limited and 

Low species distribution categories, because there are already relatively more infestations within them. 
422 | Page

Figure 3-97. Reported infestations of representative invasive plant species within the planning area 

Assessing Risk of Introduction and Spread of Invasive Plant Species 

Associated with Timber Harvest 

The risk of introducing invasive plant species over the next 10 years as a result of timber harvest activities 

would vary by alternative and the Proposed RMP. The BLM used the invasive plant distribution 

categories, the acres of the different timber harvest types (thinning, regeneration harvest, and uneven-aged 

management), and the methods of logging to determine the relative risk of introducing invasive plant 

species in each alternative and the Proposed RMP. For the purposes of this analysis, the BLM assumed: 

 Regeneration harvests would create higher light levels than commercial thinning and unevenaged management. Lower or no retention levels in regeneration harvests would create higher 

light levels after harvest than regeneration harvests with higher retention levels. 

 Ground-based logging methods would disturb more soil, cable skyline systems would disturb less 

soil, and aerial logging systems would disturb the least amount of soil. Although the BLM does not 

generally prescribe specific logging methods in the alternatives or the Proposed RMP, the BLM 
423 | P a g e

has made analytical assumptions about reasonably foreseeable logging methods under each 

alternative and the Proposed RMP based on assumptions developed for the 2008 FEIS.

The BLM determined the susceptibility of watersheds to invasive species introduction associated with 

timber harvest by analyzing estimates of timber harvest volumes under the alternatives and the Proposed 

RMP from the Woodstock vegetation model and the timber harvest type and harvest method coefficients 

developed for the 10-year scenarios in the 2008 FEIS (Appendix C). The geographic arrangement of 

timber harvests is a modeling product used solely for the purpose of this analysis and is not a product of 

actual site-specific project planning or decision-making.

For each alternative and the Proposed RMP, the BLM estimated the acres of timber harvest activities for 

watersheds in the planning area for the next 10 years using the generated harvest volumes. Each timber 

harvest type received a relative weight of 1 or 5, based on its respective post-harvest light levels (5 

having a higher light level than 1). Each logging method received a relative weight of 1, 3, or 5, based 

on its respective levels of soil disturbance. The BLM assumed the non-commercial thinnings in the 

moist forest reserves would neither increase the light levels nor disturb the soil enough to create 

susceptibility for invasive species introduction and spread. Multiplying the weighted values by the 

watersheds’ estimated acres for the timber harvest types and methods over the next 10 years allowed the 

BLM to generate a combined timber harvest activity weighted value for each watershed.

Dividing these combined timber harvest values into three groups (Low, Moderate, and High) allowed 

the BLM to assign each watershed to one of these three susceptibility categories for introduction of 

invasive plant species from timber harvest activities.

The BLM determined the risk for invasive species introduction associated with timber harvest by 

considering both the susceptibility category and the presence of invasive plant species. Watersheds 

with a low distribution of invasive plant species and that are in the Low susceptibility category would 

have the lowest risk of invasion. The greatest risk of invasion would be in watersheds that are both in 

the High susceptibility category and where invasive plant species are abundant. Watersheds with no 

reported sites for the representative sample set of invasive plant species in the analysis, no BLMadministered lands, or no timber harvest activity susceptibility in the first 10 years do not have an 

assigned risk category.

Assessing Risk of Introduction and Spread of Invasive Plant Species in 

Riparian Habitats Associated with Timber Harvest 

The BLM assessed the susceptibility of invasive plant species introduction into riparian habitats 

associated with each alternative and the Proposed RMP by considering the relative impact of the widths 

of the Riparian Reserve, management direction within the Riparian Reserve, and levels of timber harvest 

activity within the Riparian Reserve. These factors affect the light levels in riparian habitats; the higher 

the light levels, the higher the risk for the introduction of invasive plant species. As described in the 

Planning Criteria, the BLM assumed for the purpose of invasive plant species analysis that the light levels 

of areas within 100 feet of timber harvest would increase and that the light levels 100 feet or more from 

timber harvest would remain unaffected.

The BLM analyzed the effects of thinning within the Riparian Reserve over the next 10 years using 

spatial analysis to determine susceptibility of invasive plant species introduction into riparian habitats. In 

this analysis, the BLM used the modeled thinning acres in the Riparian Reserve from the Woodstock

vegetation model to compare the susceptibility of introducing invasive plant species into riparian habitats 

through such thinning across the alternatives and the Proposed RMP over the next 10 years for each 

office. As noted above, the geographic arrangement of thinning is a modeling product used solely for the 
424 | P a g e

purpose of this analysis and is not a product of actual site-specific project planning or decision-making. 

For the purposes of this analysis, the risk of introducing invasive plants into riparian habitats from 

thinning activities matches the level of susceptibility.

The BLM also analyzed the effects of timber harvest activity adjacent to the Riparian Reserve over the 

next 10 years using spatial analysis to determine susceptibility of invasive plant species introduction into 

riparian habitats. The BLM considered the effects of timber harvest activities occurring outside of and 

adjacent to the Riparian Reserve with widths less than 100 feet on either side of streams. Multiplying 

Riparian Reserve acres susceptible to effects from the alternatives’ timber harvest activities by weights 

accounting for the relative differences in the combination of factors below provides a range of watershed 

riparian susceptibility values and subsequent susceptibility categories of Low, Moderate, and High:

 Light generated by timber harvest types

 Soil disturbance from different timber harvest methods

 Shade reduction in stands adjacent to timber harvest activities

The BLM used riparian susceptibility and species distribution categories to determine the risk by 

alternative and the Proposed RMP of introducing invasive plant species into riparian habitats over the 

next 10 years.

As described in the Fisheries section of this chapter, there is an element of uncertainty related to riparian 

thinning under the No Action alternative compared to the action alternatives and the Proposed RMP. 

Riparian thinning under the No Action alternative is allowed anywhere in the Riparian Reserve with no 

specific retention requirements. However, activities must meet the Aquatic Conservation Strategy

objectives, which are often difficult to interpret at the site scale. Nevertheless, the 1995 RMPs do not 

define an inner zone with management direction prohibiting thinning, which makes the specific location 

and implementation of riparian thinning less certain than under the action alternatives or the Proposed 

RMP.

Assessing Risk of Introduction and Spread of Invasive Plant Species 

Associated with New Road Construction

Road construction and associated road management activities involving disturbance to soil and increased 

light levels contribute to the introduction of new infestations and the spread of existing invasive plant

infestations. Road construction equipment can inadvertently transport invasive plant species seed or 

vegetation, creating new infestations. Soil disturbance and increased light created by road construction 

activities provide opportunities for invasive plants already present in a project area to thrive. Light and 

disturbed soils provide favorable conditions for invasive plant seed germination and plant establishment.

The BLM determined the susceptibility of watersheds to invasive species introduction associated with 

new road construction (temporary or permanent) by prorating each watershed with the road construction 

estimates for each alternative and the Proposed RMP produced in the Trails and Travel Management 

section in this chapter. Susceptibility values fall into relative susceptibility categories, allowing the BLM 

to compare the susceptibility of the watersheds to invasive plant species introduction and spread. As 

noted above, the geographic arrangement of timber harvest is a modeling product used solely for the 

purpose of this analysis, as is the modeled location of associated new road construction, and is not a 

product of actual site-specific project planning or decision-making.

The BLM used the susceptibility categories and species distribution categories for the watersheds to 

determine each alternative and the Proposed RMP’s relative risk of invasive plant introduction 

associated with road construction.
425 | P a g e

Assessing Risk of Introduction and Spread of Invasive Plant Species 

Associated with Public Motorized Vehicle Use

Motorized vehicles can inadvertently transport invasive plant species seed or vegetation, creating new 

infestations. Infestations associated with public motorized vehicle travel tend to spread along road and 

trail corridors. Public motorized vehicle travel along roads and trails disturb soil, especially along new 

trails. The combination of disturbed soil conditions from public motorized vehicle travel and vehicles 

inadvertently transporting invasive plant parts create susceptibility.

The BLM assessed the susceptibility of BLM-administered lands in the planning area to invasive species 

introduction associated with public motorized travel activities by comparing each alternative and the 

Proposed RMP’s acres of open, closed, and limited for public motorized access designations. The BLM 

assumed that areas designated as open would be more susceptible to having new introductions of invasive 

plant species and infestation spread than areas designated as limited or closed. The BLM assumed that 

areas designated as closed would not be susceptible to new introductions and spread of invasive plant 

species associated with public motorized travel activities. As noted above, the BLM assumed that 

members of the public participating in motorized travel recreation would operate vehicles consistent with 

BLM decisions about public motorized travel opportunities.

The BLM assigned public motorized access designation weights to each part of the watershed having a 

different public motorized access designation under each alternative or the Proposed RMP. Public 

motorized access designation susceptibility weights are the following:

 Closed = 0

 Limited = 3

 Open = 5

For each alternative and the Proposed RMP, the BLM multiplied the susceptibility weights by total acres 

per watershed for each of the three designations to generate a set of susceptibility values for the 

watersheds and then divided them into three categories: Low, Medium, and High.

The BLM used the susceptibility weights and species distribution categories for the watersheds to 

determine each alternative and the Proposed RMP’s relative risk of invasive plant introduction associated 

with public motorized access designations.

Assessing Risk of Introduction and Spread of Invasive Plant Species 

Associated with Livestock Grazing

The BLM assessed the risk of invasive species introduction associated with livestock grazing by 

comparing the relative amount of land available for livestock grazing under each alternative and the 

Proposed RMP. Livestock grazing creates ground disturbance, which creates susceptibility for the 

introduction and spread of invasive plants. The BLM assumed invasive plants would occur in the areas 

available for livestock grazing. Livestock movement and associated activities, such as the transport of 

contaminated hay, can introduce invasive plants into new locations. Therefore, areas that the BLM 

determined would be susceptible for introduction and spread of invasive plants associated with livestock 

grazing would be at risk. Only the Coos Bay District, Klamath Falls Field Office, and Medford District 

administer livestock grazing in the decision area. Comparing the acreage available for livestock grazing in 

the Coos Bay District, Klamath Falls Field Office, and Medford District provides a relative assessment for 

the introduction and spread of invasive plants across the alternatives and the Proposed RMP.
426 | P a g e

Affected Environment 

The Final Environmental Impact Statement for the Revision of the Resource Management Plans of the 

Western Oregon Bureau of Land Management Districts describes the Invasive Plant management 

program in detail, which the BLM incorporates here by reference (USDI BLM 2008, pp. 274–282). This 

reference includes definitions, magnitude of invasive species diversity in the planning area, and 

information about how land management activities contribute to invasive plant introduction and spread 

within the planning area. 

While the affected environment section from the 2008 planning effort is still pertinent, data sharing 

among land managers has led to a more robust understanding of the distribution of invasive plant species 

than was available in 2008. The distribution of invasive plant species is available at iMapInvasives 

(www.imapinvasives.org). While this data is more robust then that available in 2008, the data is still 

limited because there is no requirement for county, private, or corporate landowners to report invasive 

plant information. 

Figure 3-97, Figure 3-98, and Table 3-70 show the relative density of the reported infestations, which 

demonstrate that the representative invasive plant species are common throughout the planning area. 

Although reported infestations of the representative invasive plant species are less than the total amount 

of all invasive plant species infestations, these reported infestations provide a sense of how invasive 

species are distributed within the planning area. Almost all of the watersheds currently fit the Limited or 

Abundant species distribution categories. Only one watershed fits the Low species distribution category, 

and only one watershed has no reported sites. Neither of these watersheds contains BLM-administered 

lands. 
427 | Page

Figure 3-98. Distribution categories of invasive plant species for the watersheds within the planning area 

Table 3-70. Number of watersheds per district in each species distribution category 

District/

Field Office

Species Distribution Categories

Low Limited Abundant

Coos Bay - 14 13

Eugene - 11 22

Klamath Falls 1 19 12

Medford - 6 35

Roseburg - 11 16

Salem - 63 36

Total Watersheds 1 124 134
428 | Page

Environmental Consequences 

This analysis examines timber harvest, road management activities, and public motorized access 

designations for the potential to introduce and spread invasive plant species that would result from the 

alternatives. 

Risk of Introduction and Spread of Invasive Plant Species Associated with 

Timber Harvest 

Susceptibility to the introduction and spread of invasive plant species due to timber harvest would be 

greatest under Alternative B, which would have 157 watersheds that have some level of susceptibility 

associated with timber harvest activities over the next 10 years. Alternative A would have the least 

watersheds with some level of susceptibility from timber harvest activities, with 136 susceptible 

watersheds. The No Action alternative, Alternatives C and D, and the Proposed RMP would be 

intermediate in susceptibility, with 143, 144, 146, and 155 susceptible watersheds, respectively. 

The watersheds in the high susceptibility category occur evenly throughout the planning area under all 

alternatives and the Proposed RMP, with Alternative C having the most watersheds in this category and 

Alternative D having the fewest, at 67 and 35 watersheds, respectively. The No Action alternative, 

Alternatives A and B, and the Proposed RMP would have an intermediate number of High susceptibility 

category watersheds at 44, 40, 39, and 45 respectively. Watersheds with the potential for the most area 

with timber harvest activities that would generate soil disturbance and reduced shade over the next 10 

years fall into the highest susceptibility categories. 

Categories for the distribution of invasive plant species and the categories for the susceptibility of 

introduction from timber harvest activities determine the relative risk categories for the introduction of 

invasive plant species. For example, watersheds with both a high density of representative invasive 

species and a high level of susceptibility would be in the Highest risk category. 

Table 3-71 contains the relative risk for the introduction and spread of invasive plant species that are 

associated with timber harvest activities over the next 10 years. 

Table 3-71. Risk of introduction and spread of invasive plant species associated with timber harvest over 

the next 10 years 

No Action Alt. A Alt. B Alt. C Alt. D PRMP 

Risk Category (Number of 

Watersheds)

(Number of 

Watersheds)

(Number of 

Watersheds)

(Number of 

Watersheds)

(Number of 

Watersheds)

(Number of 

Watersheds)

Highest 42 30 30 52 26 32

High 33 43 56 46 57 53

Moderately High 11 12 16 11 11 10

Moderate 24 32 28 16 26 31

Moderately Low 33 19 27 19 26 29

Low - - - - - -

Total at Risk 143 136 157 144 146 155

Total Not at Risk 124 131 110 123 121 112

Total Watersheds 267 267 267 267 267 267

Over the next 10 years, Alternative B would have the most watersheds at some level of risk (157), and 
429 | Page

428 | Page

Total at Risk 143 136 157 144 146 155

Total Not at Risk 124 131 110 123 121 112

Total Watersheds 267 267 267 267 267 267

Over the next 10 years, Alternative B would have the most watersheds at some level of risk (157), and 

Alternative A would have the least watersheds at some level of risk (136). Under all alternatives and 

the Proposed RMP, slightly more than half of the watersheds in the planning area would experience 

some level of risk of introduction of invasive plant species associated with timber harvest activities 

over the next 10 years. The highest degree of risk would occur under Alternative C, and the lowest 

would occur under Alternative A, with 98 and 73 watersheds in the High and Highest risk categories, 

respectively. Moderate levels of risk intensity associated with timber harvest in the watersheds over 

the next 10 years would occur under the No Action alternative, Alternatives B and D, and the 

Proposed RMP as shown in Table 3-71. Under all alternatives and the Proposed RMP, less than onequarter of the watersheds would experience Moderate to Moderately Low risk of invasive plant 

species introduction associated with timber harvest activities over the next 10 years. 

Risk of Introduction and Spread of Invasive Plant Species into Riparian 

Habitats Associated with Timber Harvest Adjacent to the Riparian Reserve 

The Riparian Reserve would be wide enough (i.e., at least 100 feet) to avoid effects on light levels in 

riparian habitats from adjacent timber harvest activities (including regeneration harvest where the 

Riparian Reserve is adjacent to Harvest Land Base, and thinning where the Riparian Reserve is adjacent 

to Late-Successional Reserve) under the following alternatives and the Proposed RMP and stream types: 

 No Action alternative, Alternatives A and D, and the Proposed RMP Class I and Class II 

subwatersheds – all streams 

 Alternative B – fish-bearing and perennial streams and intermittent, debris-flow-prone, nonfish-bearing streams 

 Alternative C and the Proposed RMP Class III subwatersheds – fish-bearing and perennial 

streams 

However, riparian habitats would be susceptible to increases in light levels associated with adjacent 

timber harvests, because the Riparian Reserve would be less than 100 feet in width on either side of 

streams under the following alternatives and the Proposed RMP and stream types: 

 Alternative B – intermittent, non-debris-flow-prone, non-fish-bearing streams 

 Alternative C and the Proposed RMP Class III subwatersheds – intermittent, non-fish-bearing 

streams 

Figure 3-99 shows the susceptibility to the introduction and spread of invasive plant species into 

riparian habitats associated with timber harvest adjacent to the Riparian Reserve over the next 10 

years. 
430 | P a g e

Figure 3-99. Susceptibility to the introduction and spread of invasive plant species into riparian 

habitats associated with timber harvest adjacent to the Riparian Reserve over the next 10 years

Under the No Action alternative and Alternatives A and D, there would be no susceptibility for 

invasive plant introductions into riparian habitats associated with timber harvest activities adjacent to 

the Riparian Reserve. Under Alternative B, 150 watersheds would have a Low susceptibility, and no 

watersheds would have Moderate to High susceptibility. Under Alternative C, 136 of the 267 

watersheds in the planning area would be susceptible to invasive plant introduction into riparian 

habitats associated with timber harvest activities adjacent to the Riparian Reserve over the next 10 

years. Eight watersheds would have Moderate to High susceptibility. Under the Proposed RMP, 22

watersheds would be susceptible to invasive plant introduction into riparian habitats associated with 

timber harvest activities adjacent to the Riparian Reserve over the next 10 years, and 10 of those 

watersheds would have Moderate susceptibility. 

Under the No Action alternative and Alternatives A and D, no watersheds would be at risk of the 

introduction of invasive plant species into riparian habitats associated with timber harvest activities 

adjacent to the Riparian Reserve over the next 10 years. The highest overall risk would occur under 

Alternatives B and C. More of the watersheds (56 and 51 percent, respectively) would be at risk under 

Alternatives B and C, compared to the eight percent of the watersheds at risk under the Proposed RMP. 

Table 3-72 displays the risk of introduction and spread of invasive plant species into riparian habitats 

associated with timber harvest adjacent to the Riparian Reserve over the next 10 years.

267 267

117 122

267

152

150 136

105

3

10

6

0

50

100

150

200

250

300

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Watersheds (Number)

High Susceptibility Moderate Susceptibility Low Susceptibility None
431 | P a g e

Table 3-72. Risk of introduction and spread of invasive plant species into riparian habitats associated 

with timber harvest adjacent to the Riparian Reserve over the next 10 years

Risk Category

No Action

(Number of 

Watersheds)

Alt. A

(Number of 

Watersheds)

Alt. B

(Number of 

Watersheds)

Alt. C

(Number of 

Watersheds)

Alt. D

(Number of 

Watersheds)

PRMP

(Number of 

Watersheds)

Highest - - - 3 - -

High - - - 5 - 8

Moderately High - - - - - 2

Moderate - - 102 88 - 8

Moderately Low - - 48 40 - 4

Total at Risk - - 150 136 - 22

Total Not at Risk 267 267 117 131 267 245

Total Watersheds 267 267 267 267 267 267

Risk of Introduction and Spread of Invasive Plant Species in Riparian 

Habitats Associated with Thinning within the Riparian Reserve

Under all alternatives and the Proposed RMP, thinning activities would occur within the Riparian 

Reserve at varying levels in the next 10 years. Thinning would be limited to outside of the inner zone 

of the Riparian Reserve under all action alternatives and the Proposed RMP and could occur anywhere 

in the Riparian Reserve under the No Action alternative.

Under the No Action alternative, there is no defined area excluding thinning activities within the 

Riparian Reserve, which leaves all riparian habitats susceptible to invasive plant introductions 

associated with thinning activities. Under the No Action alternative, 31,407 acres of thinning in the 

Riparian Reserve would occur over the next 10 years, and a proportion of those acres could be within 

100 feet of streams (see the Fisheries section of this chapter). Therefore, the No Action alternative 

would have the highest risk of introducing and spreading invasive plants into riparian habitats from 

thinning within the Riparian Reserve of all alternatives and the Proposed RMP.

Under Alternative A, the inner zone of the Riparian Reserve would be wider than 100 feet from fishbearing streams and perennial streams and are therefore wide enough to prevent thinning activities in 

the outer zone from reducing shade levels in riparian habitats. On intermittent, non-fish-bearing 

streams, thinning could occur within 100 feet of streams. In moist forests, thinning would be limited to 

snag and down woody debris creation (i.e., no commercial thinning). These activities would not 

change shade levels enough to increase the susceptibility of the treatment areas to the introduction and 

spread of invasive plant infestations. In dry forests, thinning to reduce fire hazards would reduce shade 

levels and disturb the soil within 50 feet of streams, making the riparian habitats more susceptible to 

the introduction and spread of invasive plants. Under Alternative A, 7,219 acres of thinning in 

Riparian Reserve would occur over the next 10 years, but the fuel treatments in the dry forest of the 

Riparian Reserve would be the only thinning within the Riparian Reserve under Alternative A that 

would result in susceptibility for invasive plant introductions and spread into riparian habitats. As a 

result, Alternative A would have the second lowest level of susceptibility for introducing invasive 

plants into riparian habitats. 

Under Alternative B, the inner zone of the Riparian Reserve would be less than 100 feet on either side of 

fish-bearing streams and perennial streams. The inner zone would also be less than 100 feet on either side 

of intermittent, debris-flow-prone, non-fish-bearing streams. Riparian Reserve thinning outside of the 
432 | P a g e

inner zone would create susceptibility for the introduction of invasive plant species into riparian habitats 

over the next 10 years. No thinning would occur within Riparian Reserve along intermittent, non-debrisflow-prone, non-fish-bearing streams. Under Alternative B, 15,958 acres of thinning in the Riparian 

Reserve would occur over the next 10 years. Alternative B would have the second highest level of risk for 

introducing invasive plants into riparian habitats associated with thinning within the Riparian Reserve.

Under Alternative C, the width of the inner zone of the Riparian Reserve would be less than 100 feet on 

either side of fish-bearing streams and perennial streams, similar to Alternative B. No thinning would 

occur within Riparian Reserve along intermittent, non-fish-bearing streams under Alternative C. The 

Riparian Reserve thinning activities along fish-bearing streams and perennial streams would create 

susceptibility for the introduction of invasive plant species into riparian habitats over the next 10 years. 

Under Alternative C, 7,146 acres of thinning in the Riparian Reserve would occur over the next 10 years. 

Alternative C would have a Moderate level of risk for introducing invasive plants into riparian habitats 

associated with thinning within the Riparian Reserve.

Under Alternative D, there would be no susceptibility for invasive plant introductions and spread into 

riparian habitats associated with thinning within the Riparian Reserve. Under Alternative D, the inner 

zone of the Riparian Reserve would be wider than 100 feet from all streams and are therefore wide 

enough to prevent thinning activities in the outer zone from reducing shade levels in riparian habitats. 

Therefore, there would be no risk of introducing and spreading invasive plants into riparian habitats 

from thinning within the Riparian Reserve under Alternative D.

Under the Proposed RMP, the effects of thinning along fish-bearing streams and perennial streams in 

all subwatersheds would the same as Alternatives A and D; there would be no risk of introducing and 

spreading invasive plants into riparian habitats from thinning within the Riparian Reserve because the 

inner zone would be wider than 100 feet from streams. In Class I subwatersheds, thinning along 

intermittent, non-fish-bearing streams would be the same as Alternative A; there would be no risk in 

moist forests, but some limited risk associated with fuels treatments in dry forests. In Class II 

subwatersheds, the width of the inner zone of the Riparian Reserve would be less than 100 feet on 

either side intermittent, non-fish-bearing streams, which would create susceptibility for the 

introduction of invasive plant species into riparian habitats over the next 10 years. In Class III 

subwatersheds, no thinning would occur within Riparian Reserve along intermittent, non-fish-bearing 

streams. In total, 10,561 acres of Riparian Reserve thinning would occur under the Proposed RMP 

over the next 10 years. The Proposed RMP would have a Moderately Low level of risk of introducing 

and spreading invasive plants into riparian habitats from thinning within the Riparian Reserve.

Risk of Introduction and Spread of Invasive Plant Species Associated with 

New Road Construction

The BLM determined the susceptibility of watersheds to invasive species introduction associated with 

new road construction (temporary or permanent) by prorating each watershed with the road construction 

estimates for each alternative and the Proposed RMP produced in the Trails and Travel Management 

section in this chapter. Susceptibility values fall into relative susceptibility categories, allowing the BLM 

to compare the susceptibility of the watersheds to invasive plant species introduction and spread. As 

noted above, the geographic arrangement of timber harvest is a modeling product used solely for the 

purpose of this analysis, as is the modeled location of associated new road construction, and is not a 

product of actual site-specific project planning or decision-making.

The BLM used the susceptibility categories and species distribution categories for the watersheds to 

determine each alternative and the Proposed RMP’s relative risk of invasive plant introduction associated 

with road construction. See Table 3-73 for the risk comparison for the introduction and spread of invasive 
433 | P a g e

plant species resulting from new road construction activities among the alternatives and the Proposed 

RMP.

Table 3-73. Risk of introduction and spread of invasive plant species associated with new road 

construction over the next 10 years

Risk Category

No Action

(Number of 

Watersheds)

Alt. A

(Number of 

Watersheds)

Alt. B

(Number of 

Watersheds)

Alt. C

(Number of 

Watersheds)

Alt. D

(Number of 

Watersheds)

PRMP

(Number of 

Watersheds)

Highest 36 14 34 55 12 26

High 41 45 42 47 44 46

Moderately High 16 13 16 8 12 15

Moderate 22 44 30 17 45 33

Moderately Low 28 29 35 18 33 35

Low - - - - - -

Total at Risk 143 145 157 145 146 155

Total Not at Risk 132 130 118 130 129 120

Total Watersheds 275 275 275 275 275 275

Under Alternative B and the Proposed RMP, 157 and 155 watersheds, respectively, would be at risk of 

introduction of invasive plant species associated with new road construction in the next 10 years. The 

other alternatives would have between 143 and 146 watersheds at risk of introduction of invasive plant 

species associated with new road construction in the next 10 years. Alternative C would have 102 

watersheds in the High to Highest relative risk rankings, more than any other alternative or the Proposed 

RMP. The No Action alternative, Alternative B, and the Proposed RMP would have an intermediate 

number of watersheds in the High to Highest risk categories, 77, 76, and 72 watersheds, respectively.

Alternatives A and D would have the fewest watersheds in the High to Highest risk categories, 59 and 56 

watersheds, respectively.

Overall, the greatest relative risk of invasive plant species introduction associated with new road 

construction would occur under Alternative C, because it would have the most watersheds in the High to 

Highest risk categories. The lowest risk would occur under the Alternatives A and D. However, all 

alternatives and the Proposed RMP have management objectives to prevent the introduction of invasive 

species and the spread of existing invasive species infestations and the BLM would implement measures 

to prevent, detect, and rapidly control new invasive species infestations based on management direction. 

Because of this management direction, all alternatives and the Proposed RMP would be expected to 

continue to apply mitigation against introduction and spread of invasive plant species equally across all 

risk-level HUC 10 watersheds within the planning area in response to new road construction.

Risk of Introduction and Spread of Invasive Plant Species Associated with 

Public Motorized Vehicle Use

The action alternatives and the Proposed RMP would have similar susceptibility to invasive plant

introduction and spread associated with public motorized access designations because none would 

designate any areas as open to public motorized vehicle use. The BLM would only designate open for 

public motorized access under the No Action alternative. Furthermore, all alternatives and the Proposed 

RMP would have similar susceptibility to invasive plant introduction and spread associated with public 

motorized access designations over the portions of the decision area where the topography and vegetation 

inhibit cross-country vehicle travel.
434 | P a g e

The designation of open areas in the No Action alternative, and the number and distribution of areas with 

public motorized vehicle use restrictions (e.g., ACECs and District-Designated Reserve – Lands Managed 

for their Wilderness Characteristics) would result in the slight differences among the alternatives and the 

Proposed RMP in the risk results. Table 3-74 shows a relative risk comparison for introduction and 

spread of invasive plant species associated with public motorized access designations between the 

alternatives and the Proposed RMP.

Table 3-74. Risk of introduction and spread of invasive plant species associated with public motorized 

access designations

Risk Category

No Action

(Number of 

Watersheds)

Alt. A

(Number of 

Watersheds)

Alt. B

(Number of 

Watersheds)

Alt. C

(Number of 

Watersheds)

Alt. D

(Number of 

Watersheds)

PRMP

(Number of 

Watersheds)

Highest 38 - - - - -

High 100 86 80 68 64 111

Moderately High 40 63 62 57 55 68

Moderate 5 30 35 47 52 5

Moderately Low 3 6 7 12 14 1

Low - - - - - -

Total at Risk 186 185 184 184 184 185

Total Not at Risk 81 82 83 83 83 82

Total Watersheds 267 267 267 267 267 267

Almost 70 percent of the watersheds would be at risk for invasive plant species introductions associated 

with public motorized travel under all of the alternatives and the Proposed RMP. The No Action 

alternative would have higher risk levels than the action alternatives and the Proposed RMP, because it is 

the only alternative with areas designated as open for public motorized access. The No Action alternative 

is the only alternative that would have any watersheds in the Highest risk category for invasive plant 

species introduction and spread associated with public motorized travel. The No Action alternative would 

have more watersheds in the High to Highest risk categories than any action alternative or the Proposed 

RMP. Although the Proposed RMP would have no watersheds in the Highest risk category, it would have 

the most watersheds in the High risk category, 111 watersheds. Alternatives A and B would have an 

intermediate number of watersheds in the High risk category, 86 and 80 watersheds, respectively. 

Alternatives C and D would have the fewest watersheds in the High risk category, 68 and 64 watersheds, 

respectively.

Risk of Introduction and Spread of Invasive Plant Species Associated with 

Livestock Grazing

The BLM assessed the risk of invasive species introduction associated with livestock grazing by 

comparing the relative amount of land available for livestock grazing under each alternative and the 

Proposed RMP. Livestock grazing creates ground disturbance, which creates susceptibility for the 

introduction and spread of invasive plants. The BLM assumed invasive plants would occur in the areas 

available for livestock grazing. Livestock movement and associated activities, such as the transport of 

contaminated hay, can introduce invasive plants into new locations. Therefore, areas that the BLM 

determined would be susceptible for introduction and spread of invasive plants associated with livestock 

grazing would be at risk. The Livestock Grazing section of this chapter lists the acres of BLMadministered lands in the Coos Bay District, Klamath Falls Field Office, and Medford District available 
435 | P a g e

for livestock grazing by alternative and the Proposed RMP. 

In the Coos Bay District, the No Action alternative would have 544 acres available for livestock grazing, 

resulting in the greatest risk of invasive plant introduction and spread. Under all action alternatives and 

the Proposed RMP, no lands would be available for livestock grazing in the Coos Bay District, and there 

would therefore be no risk of invasive plant introduction and spread associated with livestock grazing.

In the Klamath Falls Field Office, the No Action alternative would result in the greatest risk of 

introduction and spread, with 203,582 acres available for livestock grazing. Alternatives A, B, and C and 

the Proposed RMP would have 203,377 acres available for livestock grazing, resulting in slightly less risk 

of introduction and spread than the No Action alternative. Alternative D would have no acres available for 

livestock grazing and would therefore result in no risk of invasive plant introduction and spread 

associated with livestock grazing.

In the Medford District, the No Action alternative would result in the greatest risk of introduction and 

spread, with 285,920 acres available for livestock grazing. Alternatives A, B, and C would have 162,854 

acres available for livestock grazing, resulting in less risk of introduction and spread than the No Action 

alternative. The Proposed RMP would have 156,926 acres available for livestock grazing, resulting in less 

risk of introduction and spread than the No Action alternative and Alternative A, B, and C. Alternative D 

would have no acres available for livestock grazing and would therefore result in no risk of invasive plant

introduction and spread associated with livestock grazing.

Summary

The risk of introduction and spread of invasive plant species would vary by the various management 

activities, as described above. It is not possible to combine the risks associated with various management 

activities quantitatively to provide a total cumulative risk from all management activities for each 

alternative or the Proposed RMP because of the different metrics used for measuring the risk associated 

with different management activities and the differing geographic scope of management activities (see 

‘Determining Species Distribution Categories’ in the Summary of Analytical Methods above). 

Additionally, the risk of introduction and spread of different invasive plant species and different 

management activities are not quantitatively comparable. For example, timber harvest adjacent to the 

Riparian Reserve would have indirect effects on the introduction and spread of invasive plant species in 

riparian habitats by increasing light levels in riparian habitats, whereas road construction would have 

more direct effects on the introduction and spread of invasive plant species by transporting invasive plant 

seeds or vegetation. 

It is possible to summarize qualitatively the relative cumulative risk of introduction and spread of 

invasive plant species for each alternative and the Proposed RMP. Table 3-75 ranks the alternatives and 

Proposed RMP in terms of the relative risk of introduction and spread of invasive plant species by 

analysis factor and overall.

The No Action alternative would result in a moderate overall risk of introduction and spread of invasive 

plant species. Under the No Action alternative, the risk associated with timber harvest and new road 

construction would be moderately low and moderate, respectively. The No Action alternative would have 

no risk of introduction and spread of invasive plant species in riparian habitats from timber harvest outside 

of the Riparian Reserve, but the highest risk associated with thinning within the Riparian Reserve. The No 

Action alternative would have the highest risk associated with public motorized vehicle use and livestock 

grazing, but the effect of these management activities on introduction and spread of invasive plant species 

would be geographically limited within the decision area.
436 | P a g e

Alternative A would result in a low overall risk of introduction and spread of invasive plant species. 

Under Alternative A, timber harvest activities and new road construction would result in a Low risk of 

introduction and spread of invasive plant species relative to the other alternatives and the Proposed RMP. 

Alternative A would result in a Moderate risk associated with public motorized vehicle use and livestock 

grazing, but the effect of these management activities on introduction and spread of invasive plant species 

would be geographically limited within the decision area.

Alternative B would result in a Moderately High overall risk of introduction and spread of invasive plant

species, the second highest of all alternatives and the Proposed RMP. Under Alternative B, timber harvest 

activities and new road construction would result in a Moderate risk of introduction and spread of invasive 

plant species relative to the other alternatives and the Proposed RMP. Alternative B would result in a High 

risk of introduction and spread of invasive plant species in riparian habitats, both from timber harvest 

outside of the Riparian Reserve and thinning within the Riparian Reserve. Alternative B would result in a 

Moderate risk associated with public motorized vehicle use and livestock grazing, but the effect of these 

management activities on introduction and spread of invasive plant species would be geographically 

limited within the decision area.

Alternative C would result in the highest overall risk of introduction and spread of invasive plant species 

of all alternatives and the Proposed RMP. Under Alternative C, timber harvest activities and new road 

construction would result in the Highest risk of introduction and spread of invasive plant species. 

Alternative C would result in a Low risk associated with public motorized vehicle use and a Moderate risk 

associated with livestock grazing, but the effect of these management activities on introduction and spread 

of invasive plant species would be geographically limited within the decision area. 

Alternative D would result in the lowest overall risk of introduction and spread of invasive plant species 

of all alternatives and the Proposed RMP. Under Alternative D, timber harvest activities would result in a 

Moderate risk and new road construction would result in the Lowest risk of introduction and spread of 

invasive plant species. Alternative D would have no risk of introduction and spread of invasive plant 

species in riparian habitats from either timber harvest outside of the Riparian Reserve or thinning within 

the Riparian Reserve. Alternative D would result in the Lowest risk associated with public motorized 

vehicle use. Alternative D would have no risk of introduction and spread of invasive plant species 

associated with livestock grazing. 

The Proposed RMP would result in a moderate overall risk of introduction and spread of invasive plant

species. Under the Proposed RMP, the risk associated with timber harvest and new road construction 

would be moderate relative to the alternatives. The Proposed RMP would result in a Low risk of 

introduction and spread of invasive plant species in riparian habitats from timber harvest outside of the 

Riparian Reserve, and a Moderately Low risk associated with thinning within the Riparian Reserve, but 

this risk would be limited to Class III subwatersheds. The Proposed RMP would result in a Moderately 

High risk associated with public motorized vehicle use and a Moderate risk associated with livestock 

grazing, but the effect of these management activities on introduction and spread of invasive plant species 

would be geographically limited within the decision area.

These qualitative rankings of risk are simply evaluations of susceptibility based on current conditions of 

invasive plant species populations, coupled with management actions proposed under the alternatives and 

the Proposed RMP. That is, an alternative’s overall rating describes the level of risk of introduction and 

spread of invasive plant species rather than an analysis of actual introduction and spread of invasive plant 

species in any specific watershed. Whether an alternative would result in actual introduction and spread of 

invasive plant species in any specific watershed would depend on a variety of project-specific, watershedspecific, and species-specific factors that cannot be analyzed at this scale of analysis. All alternatives and 

the Proposed RMP have management objectives to prevent the introduction of invasive species and the 
437 | P a g e

spread of existing invasive species infestations and the BLM would implement measures to prevent, 

detect, and rapidly control new invasive species infestations based on management direction. Because of 

this management direction, all alternatives and the Proposed RMP would be expected to continue to apply 

mitigation against introduction and spread of invasive plant species equally across all risk-level HUC 10 

watersheds within the planning area in response to management activities.
438 | P a g e

Table 3-75. Relative risk of introduction and spread of invasive plant species by analysis factor and overall

Management Activity No Action

(Risk)

Alt. A

(Risk)

Alt. B

(Risk)

Alt. C

(Risk)

Alt. D

(Risk)

PRMP

(Risk)

Timber harvest activities Moderately 

Low Lowest Moderate Highest Moderate Moderate

Timber harvest activities adjacent to 

Riparian Reserve (invasive plant species in 

riparian habitats)

None None High Highest None Low

Thinning activities within Riparian Reserve

(invasive plant species in riparian habitats) Highest Low High Moderate None Moderately Low

New road construction Moderate Low Moderate Highest Lowest Moderate

Public motorized vehicle use Highest Moderate Moderate Low Lowest Moderately

High

Livestock grazing Highest Moderate Moderate Moderate None Moderate

Overall Risk of Introduction and

Spread of Invasive Plant Species

Moderately 

High Low Moderately High Highest Lowest Moderate
439 | P a g e

Issue 2 

How would the alternatives affect the risk of invasive aquatic species introduction and spread? 

Summary of Analytical Methods 

The BLM compared the relative risk of introducing and spreading invasive aquatic species resulting from 

the land use allocations and planned management activity levels under the alternatives and the Proposed 

RMP, taking into consideration the collective distribution of a representative set of invasive aquatic 

species. Variation in the effects among the alternatives and the Proposed RMP would result from 

differences in Recreation Management Area designations, the area available to livestock grazing, and the 

mileage of new road construction over the next 10 years. The Planning Criteria provides detailed 

information on the invasive species analysis and assumptions, which is incorporated here by reference 

(USDI BLM 2014, pp. 90–98). 

In this analysis, the BLM measured effects associated with new road construction and RMA designations 

using subbasins (HUC 8) as the basic analytical unit, in much the same way as a site-specific analysis 

may report infestation effects in terms of acres, rather than in smaller increments representing the extent 

of the infestations. Even though BLM-administered lands constitutes a small percentage of many 

subbasins, BLM management actions could still affect susceptibility and risk for the introduction and 

spread of invasive plant species. Therefore, the BLM included all subbasins within the decision area in 

this analysis. The BLM measured the effects of livestock grazing on the introduction and spread of 

invasive aquatic species at the scale of the district or field office. 

Representative Species 

The BLM selected the following invasive aquatic species to characterize the general condition of invasive 

aquatic species in the decision area: 

 American bullfrog (Rana catesbeiana) 

 Asiatic clam (Corbicula fluminea) 

 New Zealand mudsnail (Potamopyrgus antipodarum) 

 Nutria (Myocastor coypus) 

 Yellow flag iris (Iris pseudacorus) 

Each of these species has a unique distribution and strategy for spreading and resisting different control 

methods. Although each species is unique, this sample of invasive aquatic species represents a range of 

life histories and methods of introduction and spread sufficient to describe the condition of invasive 

aquatic species in the decision area. The BLM considered these dispersal strategies when developing its 

assumptions around how management activities would affect invasive aquatic species introduction and 

spread. Figure 3-100 illustrates the reported presence of the representative invasive aquatic species in the 

planning area. 

A complete accounting of the distribution of invasive aquatic species is unavailable, because there is no 

requirement for county, private, or corporate landowners to report occurrences of invasive aquatic 

species. Despite the limited reporting, a sufficient picture of the distribution of invasive aquatic species is 

available on a species-by-species basis on the NAS – Nonindigenous Aquatic species database managed 

by the U.S. Geological Survey (http://nas.er.usgs.gov/) and iMapInvasives (www.imapinvasives.org). 

Baseline occurrence data in iMapInvasives and the NAS – Nonindigenous Aquatic species database allow 

for an analysis of invasive aquatic species among alternatives and the Proposed RMP using the subbasins 

as the basic analysis unit. 
440 | Page

Figure 3-100. Reported infestations of representative invasive aquatic species within the planning area 

Determining Species Distribution Categories 

The BLM pooled representative invasive aquatic species occurrence data from BLM corporate datasets 

and iMapInvasives (ORBIC 2013). The BLM evaluated the collective pool of reported sites to determine 

representative invasive plant presence for each square mile in a grid applied to the planning area. The 

BLM based the invasive aquatic species distribution categories of Abundant, Limited, and Low on the 

known representative species’ distribution in the subbasins:

 Abundant—the representative invasive species reported from more than 25 percent of the 

square miles within the subbasin 

 Limited—the representative invasive species reported from more than 1 percent and less 

than 25 percent of the square miles within the subbasin 
441 | P a g e

 Low—the representative invasive species reported in no more than 1 percent of the square 

miles within the subbasin

Subbasins fitting the Abundant species distribution category are more likely to have invasive species 

introduction and spread associated with management and human activities than those fitting the Limited 

and Low species distribution categories because there are already more infestations within them.

Risk of Introduction and Spread of Invasive Aquatic Species

The BLM considered the following factors in the analysis of the relative levels of risk of the introduction 

and spread of invasive aquatic species in the decision area:

 Distribution and abundance of invasive aquatic species

 Levels of new road construction over the next 10 years

 Designations for Recreation Management Areas

 Proximity of Recreation Management Area designations to streams and water bodies

 Area available to livestock grazing

The relative risk of introducing and spreading invasive aquatic species would vary by alternative and the 

Proposed RMP. This analysis compares the effects road construction, recreation use, and livestock grazing

would have on the introduction and spread of invasive aquatic species, in terms of susceptibility and risk 

(see Issue 1 above for the discussion of susceptibility and risk). 

As in Issue 1 above, the analysis assumed that actions on other ownerships and BLM management actions 

other than those listed above would continue to contribute to invasive aquatic species introduction and 

spread at current levels.

All alternatives and the Proposed RMP include management direction to “prevent, detect, and 

rapidly control new invasive aquatic species infestations” (Appendix B). This management direction 

is general, as is appropriate to the scope and scale of this action. Under the alternatives and the 

Proposed RMP, the BLM would mitigate some of the effects by incorporating prevention measures 

in the planning and design of implementation-level actions, to prevent the introduction of new 

infestations. These specific measures would include, but are not limited to, the following:

 Clean road construction, restoration, and livestock grazing management equipment that would 

operate off roads. In infested areas, where the transport of invasive species seeds, propagules, 

or individuals on equipment is likely, clean the equipment before leaving the project site

 Use sterile road construction materials and weed-free straw and mulch

 Use native plant species to promote competitive exclusion of invasive plant species

 Retain native plant communities in and around riparian and aquatic habitats and minimize soil 

disturbance, consistent with project objectives

Although implementation of these measures under all alternatives and the Proposed RMP would mitigate 

the effects of management activities on the introduction and spread of invasive aquatic species, it is not 

possible to forecast the effectiveness of prevention or treatment measures in avoiding or reducing the 

introduction and spread of specific invasive aquatic species. Thus, it is not possible to incorporate a 

quantitative analysis of the effect of such prevention and treatment measures into this analysis.

Assessing Risk of Invasive Aquatic Species Introduction Associated with 

New Road Construction

Road construction activities contribute to the introduction of new infestations and the spread of existing 

invasive aquatic species infestations. Road construction equipment can inadvertently transport invasive 
442 | P a g e

aquatic species from one contaminated aquatic system to another. In addition, the disturbance and 

modification of riparian and aquatic habitats by road construction can create better habitat conditions for 

some invasive aquatic species. 

This analysis used levels of new road construction over the next 10 years to compare the relative risk 

of invasive aquatic species introduction associated with road construction across the alternatives and 

the Proposed RMP.

The BLM determined the susceptibility of subbasins to invasive species introduction associated with 

new road construction by analyzing the alternatives and the Proposed RMPs estimates of road 

construction from the Woodstock vegetation model and the coefficients developed for the 10-year 

scenarios in the 2008 FEIS (Appendix C). See Issue 1 above for discussion of the analytical 

assumptions regarding new road construction.

The BLM prorated the road construction estimates for the subbasins in the planning area for each 

alternative and the Proposed RMP. The BLM used levels of new road construction under each 

alternative and the Proposed RMP over the next 10 years to generate susceptibility values for each 

subbasin. The BLM used these susceptibility values to compare the susceptibility of the subbasins to 

invasive aquatic species introduction and spread.

This analysis considers both the susceptibility of a subbasin to invasion due to new road construction 

and the presence of invasive aquatic species to determine the risk of invasion and spread of invasive 

aquatic species. Subbasins with a low distribution of invasive aquatic species and low susceptibility 

for the introduction of invasive aquatic species would have the lowest risk of invasion. The greatest 

risk of invasion would be in subbasins where both invasive aquatic species are more abundant and 

susceptibility would be higher. Subbasins without a risk category either have no reported sites for the 

representative sample set of invasive aquatic species or have no BLM-administered lands in the 

subbasin.

Assessing Risk of Introduction and Spread of Invasive Aquatic Species 

Associated with Recreation Management Area Designations

Visitors to recreation areas could introduce invasive aquatic species to new locations in a number of 

different ways. Recreational vehicles and equipment can inadvertently transport invasive aquatic species 

into new habitats, resulting in new introductions. In addition, visitors sometimes deliberately release 

aquatic pets they no longer want in areas with easy access to water. 

The levels of human activity in the different Recreation Management Area (RMA) designations would 

create varying levels of opportunity for introducing and spreading invasive aquatic species. Visitor use 

and concentration would be highest in Special Recreation Management Areas (SRMAs), intermediate in 

Extensive Recreation Management Areas (ERMAs), and lowest in areas outside of designated RMAs. In 

this analysis, the BLM assumed that, with increased visitor use and activity, there would be a 

corresponding increase in the susceptibility of introduction and spread of invasive aquatic species. That is, 

this analysis assumed that SRMAs would be most susceptible, ERMAs would be moderately susceptible, 

and areas with no RMA designation would be least susceptible to introduction and spread of invasive 

aquatic species.

New guidance on applying RMA allocations on BLM-administered lands creates a marked difference in 

how RMA designations are defined under the No Action alternative, compared to all action alternatives 

and the Proposed RMP. Under the No Action alternative, all lands in the decision area would be 

designated to either SRMAs or ERMAs, but these designations have different meaning than under the 
443 | P a g e

action alternatives or the Proposed RMP (see the Recreation section of this chapter). Because the RMA 

designation definitions differ for the No Action alternative, the relative ranking analysis can only compare 

the action alternatives and the Proposed RMP.

The BLM assessed susceptibility to invasive aquatic species introduction and spread by using subbasins 

as the basic unit of analysis. SRMAs received the highest weight (i.e., the highest susceptibility) and areas 

with no RMA designation received the lowest weight (i.e., the lowest susceptibility). Susceptibility values 

for each subbasin result from multiplying the acres of each type of RMA by the relative weight for each 

alternative and the Proposed RMP. The BLM organized the susceptibility categories into relative 

susceptibility categories of High, Medium, and Low.

This analysis considers both the susceptibility of a subbasin to invasion due to RMA designations and 

the presence of invasive aquatic species to determine the risk of invasion and spread of invasive 

aquatic species. Subbasins with a low distribution of invasive aquatic species and low susceptibility 

for the introduction of invasive aquatic species would have the lowest risk of invasion. The greatest 

risk of invasion would be in subbasins where both invasive aquatic species are more abundant and 

susceptibility would be higher. Subbasins without a risk category either have no reported sites for the 

representative sample set of invasive aquatic species or have no BLM-administered lands in the 

subbasin.

Assessing Risk of Introduction and Spread of Invasive Aquatic Species 

Associated with Livestock Grazing

The BLM assessed the risk of invasive aquatic species introduction and spread associated with livestock 

grazing by comparing the amount of land available for livestock grazing in each alternative and the 

Proposed RMP by BLM district. Livestock grazing creates opportunities for livestock and equipment to 

move through streams and other aquatic environments, which creates susceptibility for the introduction 

and spread of invasive aquatic species. Therefore, areas that the BLM determined would be susceptible 

for introduction and spread of invasive aquatic species associated with livestock grazing would be at risk. 

Only the Coos Bay District, Klamath Falls Field Office, and Medford District administer livestock 

grazing in the decision area. Comparing the acreage available for livestock grazing in the Coos Bay 

District, Klamath Falls Field Office, and Medford District provides a relative assessment for the 

introduction and spread of invasive aquatic species across the alternatives and the Proposed RMP.

Background

Invasive aquatic species include non-native species in all taxa groups whose introduction causes 

economic or environmental harm, or harm to human health. Numerous invasive species identified in the 

Oregon Conservation Strategy (ODFW 2006) occur in the planning area. Some of these invasive species 

include New Zealand mudsnails, ringed crayfish, bullfrogs, and bluegill. Other priority invasive aquatic 

species with documented sightings in western Oregon that have the potential to be introduced and 

documented in the planning area include quagga mussels, Eastern snapping turtle, and Louisiana swamp 

crawfish. In this analysis, the BLM is specifically considering the following representative species, all of 

which occur within the planning area.

American Bullfrog

American bullfrogs (Rana catesbeiana) inhabit river and stream segments with slow moving waters, 

ponds, lakes, and boggy areas and prefer simplified, modified aquatic habitats (Fuller et al. 2011). 

Tadpoles require moisture year round to mature. American bullfrogs move to new sites by a variety of 

mechanisms including: aquaculture and garden water feature escapes, translocation into private wetlands 
444 | P a g e

from pet store purchases, and release of bullfrog pets into the wild (Crayon et al. 2009). Bullfrogs 

disperse from ponds into natural water bodies up to two miles away during periods of seasonally high 

water (Adams et al. 2003).

Habitat modifications that make better conditions for American bullfrog establishment include simplifying 

the plant community and altering seasonally wet habitats to those with permanent water. Simplification of 

the plant community allows for easier hunting and increased water temperatures (Crayon et al. 2009). 

Warmer water temperatures generally provide better habitat conditions for American bullfrog in the 

planning area.

American bullfrogs occur on BLM-administered lands in the Roseburg District (USDI BLM 2013) and in 

numerous widespread locations across western Oregon.

Asiatic Clam

The Asiatic clam (Corbicula fluminea) is a filter feeder inhabiting the surface and top layer of sediment in 

rivers and reservoirs. This species can reproduce rapidly under warm conditions and can persist in cool 

temperatures. Simply one Asiatic clam introduced into a new location can multiply into a new population 

because the species is capable of self-fertilization and cloning. Asiatic clam are successful invasive 

species because they have multiple reproductive strategies, reproduce rapidly, easily relocate in aquatic 

systems, and tolerate a wide range of environmental conditions. The species’ life history requirements 

limit its ability to spread in high temperature, low pH, and low calcium environments (Kramer-Wilt 

2008).

People introduce Asiatic clam to new locations by way of contaminated sand and gravel for construction 

projects, bait buckets, and imported aquaculture purchases (Weidemer and Chan 2008). They also move 

to new areas in water currents, on contaminated sporting and construction equipment, and through the 

transfer of infested water (Foster et al. 2014).

Asiatic clam occur within the administrative boundaries of the Coos Bay, Eugene, Roseburg, and Salem 

Districts.

New Zealand Mudsnail

The New Zealand mudsnail (Potamopyrgus antipodarum) is a clonal mollusk species that thrives in 

disturbed fresh and brackish waters. This habitat generalist spreads very easily, likes to burrow in 

sediment, and grows large populations under high nutrient flows. New Zealand mudsnails live equally 

well on organic matter or silt in lakes and in slow-moving streams, or burrowed in sediment in fastmoving streams.

New Zealand mudsnails are spread into new locations by passage through fish digestive tracts, 

contaminated fishing, sporting, and construction equipment, and contaminated water from game fish 

relocations (Oregon Sea Grant 2010). Once introduced into an aquatic system, New Zealand mudsnails 

spread within aquatic environments as hitchhikers on fish and aquatic plants. This species has the 

potential to interfere with the operations of facilities drawing infested waters. New Zealand mudsnail 

populations can become very dense and outcompete native snails for habitat and food (Benson et al. 

2014).

New Zealand mudsnail are reported across the planning area, on BLM-administered lands in the Coos 

Bay District, and within the administrative boundaries of the Eugene, Medford, Roseburg, and Salem 

Districts.
445 | P a g e

Nutria 

Humans intentionally introduced nutria (Myocastor coypus), a large rodent, to Oregon and Washington in 

the 1930s for two purposes: fur trade and undesirable aquatic plant control. Within a decade, nutria 

escaped captivity and became feral (Washington Department of Fish and Wildlife 2006). Nutria is now 

well established throughout the planning area. Nutria travel long distances over land to find new habitat 

as their populations expand (Washington State Lake Protection Association 2011). They inhabit burrows 

in riparian areas near still or slow-moving water bodies, including marshes, wetlands, ponds, and rivers. 

Dense populations of nutria modify riparian ecosystems by overgrazing riparian vegetation and building 

numerous burrows. The burrows also weaken fabricated structures, such as roadbeds and dikes. 

Intolerance to freezing temperatures is the primary factor limiting the spread of nutria in Oregon (ODFW 

2014). 

Nutria is reported in all parts of the planning area. 

Yellow Flag Iris 

Yellow flag iris (Iris pseudacorus) is a tall and showy invasive perennial wetland plant species introduced 

to North America for multiple purposes, including gardening, erosion control, and bioremediation 

(specifically, to remove metals from wastewater in sewage treatment plants). Yellow flag iris reproduces 

sexually by seed and vegetatively by rhizomes. The species tolerates a broad array of habitat conditions, 

including high soil acidity, high salinity, low soil oxygen, and periods of drought. However, yellow flag 

iris does not tolerate long periods of freezing temperatures (Ramey 2001). 

Similar to other invasive aquatic plants, yellow flag iris can be introduced to new locations when it is 

inadvertently transported on construction equipment and vehicles. Once introduced, yellow flag iris 

spreads to form thickets in mud and shallow water. Seeds can float long distances and start new colonies 

downstream. Any disturbance to yellow flag iris infestations provides an opportunity for the species to 

spread via rhizome fragments. Yellow flag iris thickets crowd out most other vegetation, including native 

aquatic plants such as cattails (Ramey 2001). 

Yellow flag iris has limited to widespread distribution in western Oregon and occupies BLMadministered lands in the Coos Bay, Eugene, and Medford Districts. 

Affected Environment 

The representative invasive aquatic species generally have the following distribution in the planning area: 

 American bullfrog occurs in numerous widespread locations across western Oregon. 

 Asiatic clam occurs within the administrative boundaries of the Coos Bay, Eugene, Roseburg, 

and Salem Districts. 

 New Zealand mudsnail infestations are reported across the planning area. 

 Nutria are well established throughout the planning area. 

 Yellow flag iris has limited to widespread distribution in western Oregon and occupies BLMadministered lands in the Coos Bay, Eugene, and Medford Districts. 

Figure 3-101 shows the distribution of representative invasive aquatic species throughout the planning 

area by subbasin. 
446 | Page

Figure 3-101. Distribution categories of invasive aquatic species by subbasins within the planning area 

Of the 41 subbasins completely or mostly within the planning area, none have enough reported 

infestations of the representative invasive aquatic species to fall into the Abundant species distribution 

category. Thirteen subbasins are in the Limited distribution category, and 21 subbasins are in the Low 

distribution category for invasive aquatic species. In total, 83 percent of the subbasins have some reported 

representative invasive aquatic species infestations. Seven subbasins (17 percent) fall in the Null 

distribution category (i.e., they currently have no reported representative invasive aquatic species 

infestations). 
447 | P a g e

Environmental Consequences

Risk of Introduction and Spread of Invasive Aquatic Species Associated 

with New Road Construction

The No Action alternative and Alternative C would have the greatest susceptibility because they have the 

most subbasins in the highest susceptibility ranking. Alternatives B and C, and the Proposed RMP would 

each have 36 subbasins with some level of susceptibility that is associated with new road construction 

over the next 10 years. Alternative D would have the least susceptibility to the introduction and spread of 

invasive aquatic species, with all of the susceptible subbasins with Moderate to Low relative categories. 

Alternative B would be the second highest in susceptibility; Alternative A would be intermediate, and the 

Proposed RMP second to the least susceptible.

See Table 3-76 for the risk of the introduction and spread of invasive aquatic species resulting from new 

road construction activities among the alternatives and the Proposed RMP.

Under all alternatives and the Proposed RMP, no subbasins would have a High risk of introduction and 

spread of invasive aquatic species resulting from new road construction over the next 10 years. 

Alternative A would have the most number of subbasins with some level of risk of introduction and 

spread of invasive aquatic species resulting from new road construction, and Alternative D would have 

the fewest. However, the No Action alternative and Alternative C would have the highest relative risk of 

introduction and spread of invasive aquatic species resulting from new road construction, because they 

would have the most subbasins in the Moderately High risk category. Alternative B and the Proposed 

RMP would have an intermediate number of subbasins in the Moderately High risk category. Alternatives

D and A would have the lowest relative risk of introduction and spread of invasive aquatic species 

resulting from new road construction, because they would have the least number of subbasins in the 

Moderately High risk category.

Table 3-76. Risk of introduction and spread of invasive aquatic species associated with new road 

construction by subbasins over the next 10 years.

Risk Category

No Action

(Number of 

Subbasins)

Alt. A

(Number of 

Subbasins)

Alt. B

(Number of 

Subbasins)

Alt. C

(Number of 

Subbasins)

Alt. D

(Number of 

Subbasins)

PRMP

(Number of 

Subbasins)

High - - - - - -

Moderately High 8 3 7 8 4 6

Moderate 1 - 4 5 - 3

Moderately Low 15 14 14 12 16 16

Low 6 15 6 6 9 6

Total at Risk 30 37 31 31 29 31

Risk of Introduction and Spread of Invasive Aquatic Species Associated 

with Recreation Management Area Designations

See Table 3-77 for the risk of introduction and spread of invasive aquatic species associated with the 

RMA designations.

All of the alternatives and the Proposed RMP would have 32 total subbasins with some level of risk of 

introduction and spread of invasive aquatic species associated with RMA designations and 9 subbasins 

with no risk of introduction and spread of invasive aquatic species associated with RMA designations. 
448 | P a g e

The Proposed RMP would have 7 subbasins in the Moderately High to High risk categories, and would 

therefore result in the most risk of introduction and spread of invasive aquatic species associated with

RMA designations, Alternative C and D would have 6 subbasins in the Moderately High to High risk 

categories, and Alternative B and A would have 4 and 3 subbasins, respectively, in the Moderately High 

to High risk categories, and would therefore have the least risk of introduction and spread of invasive 

aquatic species associated with RMA designations.

Table 3-77. Risk of introduction and spread of invasive aquatic species associated with RMA 

designations

Risk Ranking

Alt. A

(Number of 

Subbasins)

Alt. B

(Number of 

Subbasins)

Alt. C

(Number of 

Subbasins)

Alt. D

(Number of 

Subbasins)

PRMP

(Number of 

Subbasins)

High - - 1 2 2

Moderately High 3 4 5 4 5

Moderate - 1 4 6 5

Moderately Low 14 23 20 20 17

Low 15 4 2 - 3

Total at Risk 32 32 32 32 32

Total Watersheds 41 41 41 41 41

Risk of Introduction and Spread of Invasive Aquatic Species Associated 

with Livestock Grazing

The Livestock Grazing section in this chapter lists acres of the BLM-administered lands available for 

livestock grazing by alternative and the Proposed RMP. 

In the Coos Bay District, the No Action alternative would have 544 acres available for livestock grazing, 

resulting in the greatest risk of invasive aquatic species introduction and spread. Under all action 

alternatives and the Proposed RMP, no lands would be available for livestock grazing in the Coos Bay 

District, and there would therefore be no risk of invasive aquatic species introduction and spread 

associated with livestock grazing.

In the Klamath Falls Field Office, the No Action alternative would result in the greatest risk of 

introduction and spread, with 203,582 acres available for livestock grazing. Alternatives A, B, and C and 

the Proposed RMP would have 203,377 acres available for livestock grazing, resulting in slightly less risk 

of introduction and spread of invasive aquatic species than the No Action alternative. Alternative D would 

have no acres available for livestock grazing and would therefore result in no risk of invasive aquatic 

species introduction and spread associated with livestock grazing.

In the Medford District, the No Action alternative would result in the greatest risk of introduction and 

spread of invasive aquatic species, with 285,920 acres available for livestock grazing. Alternatives A, B, 

and C would have 162,854 acres available for livestock grazing, resulting in less risk of introduction and 

spread than the No Action alternative. The Proposed RMP would have 156,926 acres available for 

livestock grazing, resulting in less risk of introduction and spread than the No Action alternative and 

Alternative A, B, and C. Alternative D would have no acres available for livestock grazing and would 

therefore result in no risk of invasive aquatic species introduction and spread associated with livestock 

grazing.
449 | P a g e

Summary

The risk of introduction and spread of invasive aquatic species would vary by the various management 

activities, as described above. As with the discussion of invasive plant species in Issue 1 above, it is not 

possible to combine the risks associated with various management activities quantitatively to provide a 

total cumulative risk from all management activities for each alternative or the Proposed RMP because of 

the different metrics used for measuring the risk associated with different management activities and the 

differing geographic scope of management activities. Additionally, the risk of introduction and spread of 

different invasive aquatic species and different management activities are not quantitatively comparable. 

Table 3-78 shows the relative risk of the alternatives and the Proposed RMP, by analysis factor and 

overall, of introduction and spread of invasive aquatic species.

Table 3-78. Relative risk of introduction and spread of invasive aquatic species by analysis factor and 

overall

Management Activity No Action

(Risk)

Alt. A

(Risk)

Alt. B 

(Risk)

Alt. C 

(Risk)

Alt. D 

(Risk)

PRMP 

(Risk)

New road construction High Lowest Moderately 

High Highest Low Moderate

RMA designations -- Lowest Low High High Highest

Livestock grazing Highest Moderate Moderate Moderate None Moderate

Overall relative risk for 

the introduction and 

spread of invasive 

aquatic species

High Lowest Moderate Highest Low Moderately 

High

The No Action alternative would result in a high overall risk of introduction and spread of invasive 

aquatic species. Under the No Action alternative, the risk associated with new road construction would be 

high. As noted above, the RMA designations under the No Action alternative cannot be directly compared 

to the RMA designations under the action alternatives and the Proposed RMP. However, the overall 

recreation management approach under Alternative B best reflects the recreation management approach of 

the No Action alternative, updated with RMA designations consistent with current BLM policy. Thus, the 

effect of recreation management on risk of introduction and spread of invasive aquatic species under the 

No Action alternative can best be approximated as Low relative to the other alternatives and the Proposed 

RMP, similar to Alternative B. The No Action alternative would have the Highest risk associated with 

livestock grazing, but the effect of livestock grazing on introduction and spread of invasive aquatic 

species would be geographically limited within the decision area.

Alternative A would result in the lowest overall risk of introduction and spread of invasive aquatic 

species. Under Alternative A, new road construction and RMA designations would result in the Lowest 

risk of introduction and spread of invasive aquatic species relative to the other alternatives and the 

Proposed RMP. Alternative A would result in a Moderate risk associated with livestock grazing, but the 

effect of livestock grazing on introduction and spread of invasive aquatic species would be geographically 

limited within the decision area.

Alternative B would result in a moderate overall risk of introduction and spread of invasive aquatic 

species. Under Alternative B, new road construction would result in a Moderately High risk of 

introduction and spread of invasive aquatic species relative to the other alternatives and the Proposed 

RMP. RMA designations would result in a Low risk relative to the other alternatives and the Proposed 

RMP. Alternative B would result in a Moderate risk associated with livestock grazing, but the effect of 

livestock grazing on introduction and spread of invasive aquatic species would be geographically limited 
450 | P a g e

within the decision area.

Alternative C would result in the highest overall risk of introduction and spread of invasive aquatic 

species. Under Alternative C, new road construction would result in the Highest risk of introduction and 

spread of invasive aquatic species relative to the other alternatives and the Proposed RMP. RMA 

designations would result in a High risk relative to the other alternatives and the Proposed RMP. 

Alternative C would result in a Moderate risk associated with livestock grazing, but the effect of livestock 

grazing on introduction and spread of invasive aquatic species would be geographically limited within the 

decision area.

Alternative D would result in a low overall risk of introduction and spread of invasive aquatic species. 

Under Alternative D, new road construction would result in a Low risk of introduction and spread of 

invasive aquatic species relative to the other alternatives and the Proposed RMP. RMA designations 

would result in a High risk relative to the other alternatives and the Proposed RMP Alternative D would 

have no risk of introduction and spread of invasive aquatic species associated with livestock grazing.

The Proposed RMP would result in a moderately high overall risk of introduction and spread of invasive 

aquatic species. Under the Proposed RMP, new road construction would result in a Moderate risk of 

introduction and spread of invasive aquatic species relative to the alternatives. RMA designations would 

result in the Highest risk relative to the alternatives. The Proposed RMP would result in a Moderate risk 

associated with livestock grazing, but the effect of livestock grazing on introduction and spread of 

invasive aquatic species would be geographically limited within the decision area.

Issue 3

How would the alternatives affect the risk of sudden oak death introduction and spread?

Summary of Analytical Methods

The BLM designed the analysis to project the rate of sudden oak death (Phytophthora ramorum) 

infestation expansion for the periods of 2013–2023 and 2023–2033. The analysis shows the relative 

differences in the expected rate of sudden oak death infestation expansion resulting from different sudden 

oak death treatments strategies under the alternatives and the Proposed RMP. The Planning Criteria 

provides detailed information on the sudden oak death analysis and assumptions, which is incorporated 

here by reference (USDI BLM 2014, pp. 101–104).

The BLM measured the effects of where sudden oak death treatments would occur in the decision area in 

terms of the location and amount of area projected to become infested in the sudden oak death expansion 

zones over the next 10–20 years. Zone 1 covers infestation area for the period between 2001 and 2013; 

Zone 2 shows the expected extent of the infested area by 2023, and Zone 3 by 2033.

The BLM considered the following factors in the analysis relative to the projected sudden oak death

infestation levels and spread over the next 10–20 years:

 Sudden oak death treatment strategy by alternative and the Proposed RMP: 

o Treat all infestations under the No Action alternative, Alternatives C and D, and the 

Proposed RMP 

o No treatments under Alternative A 

o Treat all infestations outside of the Riparian Reserve under Alternative B

 Sudden oak death projected infestation zones for the next 10–20 years
451 | P a g e

The rate of the sudden oak death expansion realized from the date of first detection in 2001 through 2013 

defines the boundaries of the infestation zones for the next 10–20 years. Under the status quo, technical 

experts anticipate the infestation area would expand by approximately 1 mile to the south, 5 miles to the 

east and 17 miles to the north every 10 years for the next 20 years, as it has done in the previous 10 years 

(Frankel and Palmieri 2014).

A team of technical experts including Ellen Goheen (U.S. Forest Service), Alan Kanaskie (Oregon 

Department of Forestry), and Everett M. Hansen (Department of Botany and Plant Pathology, Oregon 

State University) worked with the BLM to project the rate of disease expansion and infestation zones for 

the next 10–20 years under the alternatives and the Proposed RMP. The experts used their professional 

opinions, the proportion of infestation acres on BLM-administered lands in the Riparian Reserve (as 

described under Alternative B) compared to total infestation area on BLM-administered lands, and the 

principles within a sudden oak death distribution model to arrive at the projected rates of expansion and 

infestation levels on BLM-administered lands. 

The technical experts added assumptions to facilitate the analysis after the Planning Criteria was 

developed. These assumptions include:

 The acres treated on BLM-administered lands in the period 2001–2013 represent the infested area 

for the same period.

 The area treated would expand at the same rate on BLM-administered lands in the second and 

third decades as it did between 2001 and 2013.

 Disease management practices on nearby non-Federal land will influence amount of disease on 

BLM-administered lands; sudden oak death will spread and intensify when left untreated 

resulting in disease intensification and spread from infected trees for several years and 

accelerated mortality in untreated areas.

 All infestations on other ownerships would be treated.

The analysis does not account for the following:

 Regrowth of vegetation on sites that were treated and replanted or naturally re-vegetated

 Variation in abundance of tanoak across the landscape

 Treatments that remove tanoak but leave overstory conifer and non-host hardwoods intact 

Background

Non-native forest pathogens, whose introduction causes economic or environmental harm, or harm to 

human health, are invasive species. Sudden oak death, caused by the invasive pathogen Phytophthora 

ramorum, threatens Oregon’s forest and nursery industries.

Phytophthora ramorum, a water mold (oomycete), caused high levels of tanoak and live oak mortality in 

California for several years before its presence in Curry County, Oregon became evident in 2001. 

Phytophthora ramorum also infects nursery stock of a wide range of host species in Europe, California, 

Oregon, and Washington. The European and North American mating types are not the same, which 

indicates that the source population for the North American infestations is not from Europe. In 2001, 

Oregon had several infection centers in close proximity to one another on private residential, industrial 

forestland, and BLM-administered lands. The original quarantine area covered 9 square miles (Goheen et 

al. 2006). By 2013, the quarantine area expanded to 264 square miles, despite aggressive coordinated 

education, prevention, and early detection and treatment efforts.

Phytophthora ramorum travels long distances via nursery stock and in the infected wood of some host 

species. For that reason, the pathogen is subject to both State (ORS 603-052-1230) and Federal (7 CFR 
452 | P a g e

301.92) quarantine regulations that restrict the movement of host material from infested areas into 

disease-free areas. Phytophthora ramorum infects more than 46 host species and more than 90 associated 

species (USDA APHIS 2013). Regulated material includes host nursery stock and wood, logs, and lumber 

of identified host species. Many host species are native trees and shrubs found in forests in the decision 

area, including tanoak and canyon live oak. Phytophthora ramorum causes mortality in susceptible oak, 

tanoak, rhododendron, viburnum, evergreen huckleberry, and other plant species. 

Phytophthora ramorum affects the stem, twigs and leaves of its host. The species spreads by both resting 

(chlamydospores) and swimming (zoospores) spores. Sporangia released from the canopies of infected 

trees travel to new host trees or the ground through the air assisted by wind and rain. Zoospores can move 

through water along the stems, twigs, and leaves of host plants, and some spores ultimately penetrate and 

infect new hosts. The spores travel in water, splash onto new susceptible host plants, and start new 

infections. Irrigation water from infested drainages or water sources also carries spores to new sites. 

Chlamydospores, which can survive periods of warmth and drought, move to new locations on infested 

soil, leaf, and twig litter (Goheen et al. 2006). 

Outside of nurseries, pathologists have not detected Phytophthora ramorum infections on conifer species 

in Oregon. Pathologists believe the aggressive treatments in Oregon’s forests have kept the spore levels 

down to a level where understory conifer species growing in infestation areas have escaped inoculation. 

However, in California, infestation levels are relatively high, and several species of conifers in the 

understory of infected oaks have become infected. The list of susceptible conifers in California includes 

Douglas-fir, several fir species, coast redwood, and Pacific yew. When left untreated, the disease 

intensifies as the infected hosts produce more spores for several years. In Oregon, where the disease has 

been aggressively treated since 2001, the spore loads have not reached high levels. 

Early in 2013, the State of Oregon revised the quarantine rule to establish a Generally Infested Area 

where landowners are no longer required to try to eradicate infestations. The BLM and other Federal 

agencies have continued aggressive treatments within the Generally Infested Area (Frankel and Palmieri 

2014). Pathologists do not know if higher spore levels in untreated areas in Oregon will lead to infections 

on understory conifers, such as in California, but pathologists do know the spore loads will increase. With 

higher spore loads come more opportunities for the spores to infect more hosts and to move off site to 

new locations. 

The Coos Bay District has been coordinating treatment activities with adjoining landowners, the Oregon 

Department of Forestry, and the U.S. Forest Service to control sudden oak death infection sites in the 

state-designated quarantine area since 2001. After pathologists found new infestations north of the 

established quarantine area in 2013, the Animal and Plant Health Inspection Service (APHIS) and the 

State of Oregon expanded the quarantine area in Curry County to 264 square miles (USDA APHIS 2013). 

Pathologists have found no new infestations from the movement of nursery stock outside of Oregon’s 

quarantine area, which suggests the quarantine program established in 2002 has been effective (USDA 

APHIS 2014). 

The Coos Bay District has been using an integrated pest management approach to control all detected 

sudden oak death infestations. Treatments have included cutting, piling, and applying herbicides to host 

species within 300 feet of infected trees. Treatments have typically included broadcast or pile burning of 

cut material. Pathologists from the Oregon Department of Forestry and the U.S. Forest Service have 

performed follow-up surveys until the area has been determined to be disease-free for two successive 

years. If the disease is still present, the area has been retreated. The Coos Bay District has been planting 

treatment areas with Douglas-fir within two years of treatment. 
453 | Page

Affected Environment 

In 2001, Oregon had several infection centers in close proximity to one another on private residential, 

industrial forestland and on BLM-administered lands within the planning area. All of the western Oregon 

districts are at risk for sudden oak death infestations (Václavík et al. 2010), but Coos Bay District is the 

only one currently with known sites. 

Sudden oak death infestation Zone 1 represents the broader infested area over the period of 2001 through 

2013 (Figure 3-102). The Coos Bay District manages over 10,000 acres (almost 15 percent) of the total 

area within Zone 1. Phytophthora ramorum infests almost 1,000 acres (10 percent) of the Coos Bay 

District administered lands in Zone 1. Because the pathogen thrives in wet environments, trees closer to 

streams have a higher infection rate than those in upland habitats. More than 25 percent of the infested 

area is either within one site-potential tree height of perennial and fish-bearing streams or within 50 feet 

on non-fish-bearing intermittent streams, or both. 

Figure 3-102. Sudden oak death infestation zones as of 2013 and expected expansion zones by 2023 and 

2033 
454 | P a g e

Between 2001 and 2013, the BLM implemented integrated pest management treatments to control sudden 

oak death on 959 acres. Most areas were treated using more than one method. In 2013, the Coos Bay 

District treated 46 acres by cutting and piling, over 160 acres by pile burning, and 24 acres by herbicide 

treatments. No retreatments occurred in 2013. The BLM’s cumulative treatments between 2001 and 2013 

include more than 830 acres of cutting and piling, almost 700 acres of pile burning, 17 acres of broadcast 

burns, and almost 80 acres of retreatments.

Environmental Consequences

The intensity and area of sudden oak death infestations would vary under the different treatment strategies 

over time. See Table 3-10 for sudden oak death infestations levels by infestation zone over the next 10 

and 20 years for each of the alternatives and the Proposed RMP.

Table 3-79. Sudden oak death infestations levels by infestation zone over the next 10 and 20 years

Infestation Zone

(Time Frame)

Alt. A

(Acres)

Alt. B

(Acres)

No Action,

Alt. C and D

(Acres)

PRMP

(Acres)

Zone 1 (2014–2023) 10,013 4,440 1,918 1,918

Zone 2 (2014–2023) 4,893 2,111 780 780

Zone 3 (2014–2023) 305 39 - -

Total all zones (2014–2023) 15,211 6,590 2,698 2,698

Zone 1 (2024–2033) 10,013 5,874 2,877 2,877

Zone 2 (2024–2033) 8,143 3,978 1,560 1,560

Zone 3 (2024–2033) 3,050 1,429 584 584

Total all zones (2024–2033) 21,206 11,281 5,021 5,021

Under Alternative A, the BLM would not treat sudden oak death infestations, which would result in the 

most intense and largest levels of infestations on BLM-administered lands. Left untreated, infected trees 

would produce and release spores over several years, allowing rapid and uncontrolled infestation on 

BLM-administered lands. The highest levels of tanoak mortality would occur under Alternative A. In this 

alternative, by the end of the first decade, sudden oak death infestations would occupy all BLMadministered lands in Zone 1 (10,013 acres). Infestations would occupy all of the BLM-administered 

lands within the quarantine area and a quarter of the remaining BLM-administered lands within Zone 2. 

Sudden oak death infestations would occupy 1 percent (305 acres) of the BLM-administered lands in 

Zone 3 within the first 10 years. Sudden oak death would infest 87 percent (21,206 acres) of BLMadministered lands in the cumulative three-zone area by the end of the second decade under Alternative 

A.

Under Alternative B, the BLM would not implement treatments within the Riparian Reserve, but would 

treat all detected infestations outside of the Riparian Reserve. Sudden oak death would spread and 

intensify from the untreated areas in the Riparian Reserve, but Alternative B would result in a smaller 

increase in infected acres than Alternative A. Spores produced within the Riparian Reserve from untreated 

trees would spread to both additional hosts within and outside of the Riparian Reserve for several years. 

Ultimately, more tanoak would die from this intermediate treatment strategy under Alternative B than 

would die under the aggressive strategy prescribed under the No Action, Alternatives C and D, and the 

Proposed RMP. By the end of the first decade, the infestation would have increased in Zone 1 and entered 
455 | P a g e

Zones 2 and 3. Cumulatively, the infestation would cover almost 6,590 acres. By the end of the second 

decade, the infestation would have increased in all zones, with a cumulative total infestation covering 

11,281 acres or 47 percent of BLM-administered lands in the cumulative three-zone area.

Under Alternatives A and B, sudden oak death infestations would occupy 100 percent of the Riparian 

Reserve area in Zone 2 and almost 90 percent in the cumulative three-zone area by 2033.

The lowest amount of sudden oak death infestation intensification and increase in infested acres would 

occur under the No Action alternative, Alternatives C and D, and the Proposed RMP, because the BLM 

would treat all detected infestations. The infestation would still increase under this treatment strategy, as it 

has over the past 10 years. Spore loads would have less opportunity than under Alternatives A and B to 

increase and spread to new hosts due to rapid response treatments. By the end of the first decade, the 

infestation would increase in both Zones 1 and 2 and would total 2,698 acres. By the end of the second 

decade, the infestation would enter Zone 3 and the cumulative total for all zones would be 5,021 acres or 

21 percent of BLM-administered lands in cumulative three-zone area. Under the No Action alternative, 

Alternatives C and D, and the Proposed RMP, 25 percent of the Riparian Reserve area in Zone 2 and 27 

percent of the Riparian Reserve area in the cumulative three-zone area would have sudden oak death 

infestations. Under the No Action alternative, Alternatives C and D, and the Proposed RMP, the Riparian 

Reserve in Zone 3 would still be free of infestations by 2023.

The acreage of sudden oak death treatments under Alternative B would be substantially greater than under 

the No Action alternative, Alternatives C and D, and the Proposed RMP. Even though Alternative B 

would not apply treatments within the Riparian Reserve, the greater acreage of infestation under 

Alternative B would result in more acres of treatment than under the No Action alternative, Alternatives 

C and D, and the Proposed RMP. Decadal initial sudden oak death treatments under Alternative B would 

be almost two times higher than the expected treatment levels under the No Action alternative, 

Alternatives C and D, and the Proposed RMP over the next 10 years, and one and a half times greater in 

the second 10 years (Table 3-80).

Table 3-80. Initial sudden oak death treatment levels over the next 10 and 20 years

Sudden Oak Death

Decadal Treatment Periods

Alt. A

(Acres)

Alt. B

(Acres)

No Action,

Alt. C and D

(Acres)

PRMP

(Acres)

Initial treatments for 2014–2023 - 3,292 1,777 1,777

Initial treatments for 2024–2033 - 3,854 2,536 2,536

Cumulative Treatments - 7,146 4,313 4,313
456 | P a g e

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Washington State Lake Protection Association. 2011. More lakeside neighbors: nutria now found in Washington. Waterline 

Newsletter. http://www.walpa.org/waterline/june-2011/more-lakeside-neighbors-nutria-now-found-in-washington/.

Weidemer, S., and S. Chan. 2008. On the lookout for aquatic invaders: identification guide for the Pacific Northwest. Oregon Sea 

Grant Program, Oregon State University, Corvallis, OR. 71 pp. http://seagrant.oregonstate.edu/sgpubs/lookout-aquaticinvaders-identification-guide-west.
457 | P a g e

Lands and Realty

Key Points

 Under the Proposed RMP and all alternatives, BLM-administered lands would be generally 

available for rights-of-way. Alternative D would most constrain the BLM’s ability to grant rightsof-way compared to the current conditions.

Issue 1

How would the alternatives affect land tenure in western Oregon?

Summary of Notable Changes from the Draft RMP/EIS

This analysis of right-of-way avoidance areas and exclusion areas does not present acreage by specific 

criteria (e.g., ACECs and Recreation Management Areas). These specific criteria have substantial 

geographic overlap, creating confusion and errors related to the acreage associated with each specific 

criterion. Instead, the BLM identifies the specific criteria and presents the total acreage for avoidance 

areas and exclusion areas for all alternatives and the Proposed RMP.

Summary of Analytical Methods

The BLM identified the number of acres in each alternative and the Proposed RMP that would be 

included in each land tenure zone and considered the potential impact on the BLM’s land holdings in 

western Oregon taking into account recent trends in land acquisition, exchange, and disposal.

Background

Through RMP-level decisions, the BLM places all of BLM-administered lands into one of the following 

three Land Tenure Zones:

 Lands in Zone 1 are retained under BLM administration

 Lands in Zone 2 are available for exchange to enhance public resource values, improve 

management capabilities, or reduce the potential for land use conflict

 Lands in Zone 3 are available for disposal using appropriate disposal mechanisms

Across the action alternatives and the Proposed RMP, the BLM used the following criteria to determine 

land tenure zones:

 Zone 1 lands would include:

o Designated and Suitable Wild and Scenic River corridors

o Wilderness Areas

o Wilderness Study Areas

o National Trail management corridors

o Areas of Critical Environmental Concern (including Research Natural Areas and 

Outstanding Natural Areas)

o Congressionally designated Outstanding Natural Areas

o Lands acquired with Land and Water Conservation Funds
458 | P a g e

In addition to the criteria above, the Proposed RMP also would include District-Designated 

Reserve – Lands Managed for their Wilderness Characteristics in Zone 1.

 Zone 2 lands would include all BLM-administered lands not listed in the descriptions of both 

Zone 1 and Zone 3 lands.

 Zone 3 lands would include:

o Lands that are either not practical to manage or are uneconomical to manage because of 

their intermingled location and non-suitability for management by another Federal 

agency

o Survey hiatuses – an area between two surveys where the record describes them to have 

one or more common boundary lines with no omission

o Unintentional encroachments – an unintended unlawful and adverse intrusion within 

the boundary of BLM property where the BLM has discretion to determine if the lands 

are suitable for disposal

Appendix K provides information on criteria for specific land tenure adjustments, including specific 

acquisition, exchange, and disposal criteria.

Affected Environment

Since the 1995 RMP, the BLM has acquired 8,962 acres of lands by purchase, which encompass 0.36 

percent of lands within the decision area. Ongoing land acquisition projects include the Sandy River/ 

National Historical Oregon Trail in the Salem District.

The majority of the decision area is currently within Zone 2 (suitable for exchange). Table 3-81 presents 

the land tenure acreages for the alternatives and the Proposed RMP. Since the 1995 RMPs, the BLM has 

made only limited use of land exchanges (22,390 acres acquired; 7,367 acres disposed). Federal 

legislation rather than discretionary agency action directed most land exchanges and transfer activities 

within the decision area.

The 1995 RMP designated 18,266 acres (approximately 0.7 percent of the decision area) as Zone 3 (i.e.,

suitable for disposal). The BLM has sold 3,798 acres of Zone 3 lands since 1995. The BLM sold these 

lands primarily to resolve unintentional encroachment cases where an individual had unintentionally built 

a development on BLM-administered lands. The BLM does not sell lands identified for disposal if 

project-level reviews show conflicts with the land tenure adjustment criteria found in Appendix K.

Environmental Consequences

The only variation among the action alternatives and the Proposed RMP comes from the arrangement and 

acreage of Areas of Critical Environmental Concern. The adjustment in acres for Areas of Critical 

Environmental Concern affects both Zone 1 and Zone 2 lands, (i.e., as more acres are proposed for Areas 

of Critical Environmental Concern, the difference of acres is reflected in Zone 2). Zone 3 acreage does 

not adjust per alternative or the Proposed RMP (Table 3-81). Appendix K lists the specific lands that 

would be in Land Tenure Zone 3.
459 | P a g e

Table 3-81. Land tenure zone within the decision area by alternative and the Proposed RMP

Land Tenure Zone No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Zone 1 – Lands Suitable 

for Retention 188,249 199,582 193,019 191,696 199,376 219,953

Zone 2 – Lands Suitable 

for Exchange 2,286,869 2,275,536 2,282,099 2,283,422 2,275,742 2,255,243

Zone 3 – Lands Suitable 

for Disposal 18,537 18,537 18,537 18,537 18,537 18,459

For the Proposed RMP, lands in Zone 1 are greater than in the action alternatives largely due to the 

inclusion of District-Designated Reserve – Lands Managed for their Wilderness Characteristics. The 

acreage of lands in Zone 3 is slightly less in the Proposed RMP than the action alternatives due to updated 

information on which lands would meet the criteria described above. The acreage difference between the 

action alternatives and the Proposed RMP would be approximately 1.2 percent of the planning area. This

variation in acreage would have a negligible effect on the BLM’s ability to exchange lands.

Issue 2

How would the alternatives affect the availability of BLM-administered lands for rights-of-way in western 

Oregon?

Summary of Analytical Methods

The BLM identified the number of acres in each alternative and the Proposed RMP that would be 

designated as right-of-way avoidance and exclusion areas. The BLM then considered how these 

designations would affect the availability of rights-of-way on BLM-administered lands in the decision 

area.

Background

Through RMP-level decisions, the BLM may identify certain BLM-administered lands as right-of-way

avoidance or exclusion areas.

 Right-of-way avoidance areas – Areas with sensitive resource values where the BLM will grant 

future rights-of-way if the BLM determines that the right-of-way proposals are compatible with 

the protection of the values for which the land use was designated, or when no feasible 

alternative route or designated right-of-way corridor is available as applicable with BLM laws 

and policy.

 Right-of-way exclusion areas – The BLM would not grant future rights-of-way except when 

mandated by law.

Upon completion of this RMP revision, the BLM would display right-of-way avoidance areas and rightof-way exclusion areas on map(s) accompanying the approved RMP.

In the action alternatives and the proposed RMP, the BLM used the following criteria to identify BLMadministered lands that it would identify as right-of-way avoidance areas:

 Areas of Critical Environmental Concern (including Research Natural Areas and Outstanding 

Natural Areas)

 Recreation Management Areas (Special and Extensive)

 Wilderness Study Areas
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 Designated and Suitable Wild and Scenic Rivers classified as Scenic or Recreational rivers 

 Visual Resource Management Class II that is not included in right-of-way exclusion areas 

The BLM used the following criteria to identify BLM-administered lands that it would identify as rightof-way exclusion areas: 

 Wilderness Areas 

 District-Designated Reserve – Lands Managed for their Wilderness Characteristics 

 Designated and Suitable Wild and Scenic Rivers classified as Wild rivers 

 Visual Resource Management Class I Areas 

The Proposed RMP used the same criteria with one exception: the Proposed RMP included Wilderness 

Study Areas in right-of-way exclusion areas instead of right-of-way avoidance areas. 

The checkerboard land ownership pattern of O&C lands generates most of the need to cross public lands 

in order to provide access and utilities to intermingled private lands. The BLM generally does not know 

the location and nature of such proposals until the BLM receives an application. 

Currently, most rights-of-way the BLM grants over BLM-administered lands in western Oregon are for 

access roads. In most cases, other linear rights-of-way (for such uses as domestic or irrigation waterlines, 

or utility lines for servicing residences) are authorized within or adjacent to existing road-clearing limits. 

In addition, the BLM has authorized other activities on public land using permits, easements, or leases, 

including: 

 Apiary (beehive) sites 

 Agricultural cultivation of small areas 

 Residential encroachments or other structures pending their removal or long-term authorization 

 National Guard or military reserve training 

 Other miscellaneous short-term activities 

Affected Environment 

BLM-administered lands are currently generally available for needed rights-of-way where consistent with 

local public resource values. Under the 1995 RMPs, the BLM authorized numerous types of rights-ofway, including rights-of-way for county roads, private access roads, power transmission lines, 

communication sites, and bicycle trails. New right-of-way proposals across public lands are likely to 

continue in the future. 

Of the current 6,254 authorized rights-of-way, 78 percent are for roads. In addition, there are 83 

communication sites on BLM-administered lands within the planning area and Appendix K includes the 

inventory of existing communication sites. 

Major existing right-of-way corridors within the planning area are shown in Figure 3-103. Existing 

facilities located within right-of-way corridors include Bonneville Power Administration and private 

electric transmission lines, pipelines, fiber-optic lines, and transportation infrastructure. 
461 | Page

Figure 3-103. Utility corridors 

Pacific Connector Pipeline Project 

The Federal Energy Regulatory Commission released the Jordan Cove Energy and Pacific Connector 

Pipeline Project Draft EIS in November 2014 (FERC 2014) and the Final EIS in September 2015 (FERC 

2015). The Pacific Connector Gas Pipeline project would include an approximately 232-mile-long, 36-

inch-diameter underground natural gas pipeline extending from a proposed Jordan Cove Energy liquefied 

natural gas export terminal in Coos Bay, Oregon, to an interconnection with the existing interstate natural 

gas systems of Ruby Pipeline LLC and Gas Transmission Northwest LLC near Malin, Oregon. The 

proposed route extends across 40 miles (approximately 800 acres) of BLM-administered lands in the 

Coos Bay, Medford, Lakeview, and Roseburg Districts. Implementation of the Pacific Connector Pipeline 

would require a right-of-way grant from the BLM to cross BLM-administered lands. The FERC-prepared 

Final EIS considered amendments to the 1995 RMPs for Coos Bay, Medford, Roseburg, and the Klamath 

Falls Field Office where the proposed action would not conform to those RMPs. Approximately 13 acres 
462 | P a g e

of the proposed route of the pipeline passes through a right-of-way avoidance area within the Klamath 

Falls Field Office of the Lakeview District within the planning area and does not cross any right-of-way 

exclusion areas.

At this time, the Jordan Cove Energy and Pacific Connector Pipeline Project is no longer a reasonably 

foreseeable future action, because the FERC denied the certificate for construction of the Jordan Cove 

Energy and Pacific Connector Pipeline Project on March 11, 2016 (Jordan Cove Energy Project, L.P. and 

Pacific Connector Gas Pipeline, L.P., 154 FERC ¶ 61,190 (2016)).

Environmental Consequences

The analysis shows that right-of-way avoidance area acres range from Alternative A with the least 

avoidance areas (179,436 acres) to Alternative D with the most avoidance acres (871,713 acres) (Table 3-

82). While having fewer acres in avoidance areas than Alternative D, Alternative C would have more than 

double the acres in the No Action alternative. Alternative A has fewer acres than the No Action 

alternative. The large acreage difference is primarily due to differences in the acreage of Recreation 

Management Areas (which are designated in the action alternatives and Proposed RMP as right-of-way 

avoidance areas; see the Background section above), where the range of acreage is from 8,217 acres to 

666,862 acres. With the large acreage of avoidance areas, the BLM’s ability to grant rights-of-way under 

Alternative D, and to a slightly lesser degree under Alternative C, would be constrained relative to the 

current conditions. The Proposed RMP acres are more than the No Action and Alternatives A and B, and 

less than Alternatives C and D.

Table 3-82. Right-of-way avoidance and exclusion areas in the Decision Area

No Action

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

PRMP

(Acres)

Avoidance Acres* 243,928 179,436 326,510 575,444 871,713 456,801

Exclusion Areas 43,590 130,597 93,274 93,274 42,568 107,790

* Right-of-way avoidance total acreage is not a direct sum of the individual criteria acres due to criteria that overlap 

geographically. Areas that overlap with right-of-way exclusion areas are subtracted from the sum of the total avoidance acres 

because right-of-way exclusion is more restrictive than right-of-way avoidance.

The No Action alternative would have the fewest acres in right-of-way exclusion areas (42,382 acres) 

(Table 3-82) and Alternative A would have the most (129,389 acres). This acreage difference of 87,007 

acres accounts for approximately 3.49 percent of the total decision area. The minimal variation in acreage 

for right-of-way exclusion areas would have little effect on the BLM’s ability to grant rights-of-way on 

BLM-administered lands. The Proposed RMP acres are less than Alternative A and more than the other 

alternatives.

References

Federal Energy Regulatory Commission (FERC). 2014. Draft Environmental Impact Statement for the Jordan Cove Liquefaction 

and Pacific Connector Pipeline Projects. November 7, 2014. Washington, D.C. 

http://www.ferc.gov/industries/gas/enviro/eis/2014/11-07-14-eis.asp.

---. 2015. Final Environmental Impact Statement for the Jordan Cove Liquefaction and Pacific Connector Pipeline Projects.

September 30, 2015. Washington, D.C. http://www.ferc.gov/industries/gas/enviro/eis/2015/09-30-15-eis.asp.

---. 2016. Order denying applications for certificate and Section 3 authorization. March 11, 2016. Washington, D.C. 25 pp. 

http://www.ferc.gov/CalendarFiles/20160311154932-CP13-483-000.pdf.
463 | P a g e

Lands with Wilderness Characteristics

Key Points

 Alternative A and the Proposed RMP would provide the largest protection of lands with 

wilderness characteristics within the decision area.

 Alternatives B and C would provide protection of an intermediate amount of lands with 

wilderness characteristics within the decision area.

 The No Action alternative and Alternative D would provide no protection of lands with 

wilderness characteristics within the decision area.

Summary of Notable Changes from the Draft RMP/EIS

The BLM refined the calculation of acres of identified lands with wilderness characteristics. The BLM 

also corrected spatial assignment errors at the unit level in the Draft RMP/EIS analysis of the action 

alternatives, altering the acreage of lands that would be managed for wilderness characteristics for 

Alternatives A, B, and C.

Issue 1

Issue 1: How would the alternatives affect BLM-administered lands with identified wilderness 

characteristics?

Summary of Analytical Methods

This section analyzes the environmental effects to lands with wilderness characteristics outside of 

designated Wilderness Areas and existing Wilderness Study Areas76 within the decision area.

The BLM analyzed the extent to which each alternative or the Proposed RMP would protect or degrade 

identified lands with wilderness characteristics (i.e., size, naturalness, and either outstanding opportunities 

for solitude or primitive and unconfined recreation). The BLM did so by comparing the acres of identified

lands with wilderness characteristics that the BLM would manage for their wilderness characteristics 

under each alternative and the Proposed RMP, as well as considering the acres not managed for identified

wilderness characteristics to which the BLM would apply management actions likely to degrade the 

identified wilderness characteristics.

Managing for wilderness characteristics is inherently incompatible with sustained-yield timber harvest. 

As explained in Chapter 1, the BLM would not include managing O&C lands for wilderness 

characteristics in areas dedicated to sustained-yield timber production. While timber harvest practices

would vary among alternatives and the Proposed RMP, all lands within the Harvest Land Base would 

eventually be subject to sustained-yield timber harvest, which is incompatible with managing for

wilderness characteristics.

 

76 Designated Wilderness Areas and existing Wilderness Study Areas would continue to be managed to protect their 

wilderness characteristics under all alternatives and the Proposed RMP. As a result, the alternatives and the 

Proposed RMP would not differ in their effects on designated Wilderness Areas and existing Wilderness Study 

Areas.
464 | P a g e

In this analysis, the BLM assumed that wilderness characteristics would persist where the BLM would 

manage lands with wilderness characteristics for their wilderness characteristics. Under Alternatives A, B, 

and C, and the Proposed RMP, the BLM would allocate areas to be managed for their wilderness 

characteristics to the District-Designated Reserve – Lands Managed for their Wilderness Characteristics. 

The BLM also assumed that wilderness characteristics would be lost over time where the BLM would 

manage lands with wilderness characteristics for other resources or land uses (e.g., sustained-yield timber 

production and incompatible recreation). The BLM assumed that any management action that would 

allow surface-disturbing activities that would degrade naturalness would cause adverse effects to 

wilderness characteristics.

Where wildfire threatens safety of property, wildfire response could degrade wilderness characteristics, 

even in the District-Designated Reserve – Lands Managed for their Wilderness Characteristics. However, 

there is no accurate way to predict the exact location and timing of wildfires or the specific wildfire 

response. Therefore, there is no reasonable basis on which to identify a difference in the effect of wildfire 

response under the alternatives or the Proposed RMP on wilderness characteristics at this scale of 

analysis.

Illegal activities, such as illegal motorized travel, could degrade wilderness characteristics, even in the 

District-Designated Reserve – Lands Managed for their Wilderness Characteristics. Although the BLM 

has some site-specific and anecdotal information about illegal public motorized travel activities, the BLM 

does not have a basis for predicting the location or effects of any widespread or systematic illegal public 

motorized travel activities. In addition, much of the decision area has physical limitations to potential 

illegal public motorized travel activities, including dense vegetation, steep slopes, and locked gates. 

Terrain, vegetation, and a greater amount of open spaces in most of the interior/south can lead to 

degradation and erosion in a greater proportion than most of the coastal/north where vegetation is denser 

and terrain is steeper. However, the BLM lacks a basis for characterizing current illegal public motorized 

travel activities or forecasting such potential illegal public motorized travel activities in the future under 

any of the alternatives or the Proposed RMP, at this scale of analysis. Therefore, in this analysis, the BLM 

assumed that members of the public participating in motorized travel recreation would operate vehicles 

consistent with BLM decisions about public motorized travel opportunities.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 125–126).

Background

The BLM’s authority to conduct wilderness reviews, including the establishment of new Wilderness 

Study Areas, expired on October 21, 1993, pursuant to Section 603 of the FLPMA. However, the BLM 

retained the authority under Sections 201 and 202 of the FLPMA to inventory wilderness characteristics 

and to consider such information during land use planning.

As required under the FLPMA and current BLM policy, the BLM updated its inventories of lands with 

wilderness characteristics for the decision area in 2013. This update included BLM-administered lands 

contained in citizens’ wilderness proposals. The impetus for this update was the need for accurate 

information for this RMP revision. In conducting these inventories, the BLM followed the guidance 

provided in BLM Manual 6310 – Conducting Wilderness Characteristics Inventory on BLM Lands 

(USDI BLM 2012). Those inventories are incorporated here by reference and are available at 

http://www.blm.gov/or/plans/rmpswesternoregon/lwci.php.
465 | P a g e

The BLM conducted the inventories using the criteria from Section 2(c) of the Wilderness Act to 

determine the presence or absence of wilderness characteristics: sufficient size of a roadless area, 

naturalness, and outstanding opportunities for solitude or primitive and unconfined recreation. The BLM 

received proposals from the public regarding lands with wilderness characteristics, but these proposals did 

not alter the results of the BLM inventory. The BLM received several proposals for areas that the BLM 

determined do not to meet the minimum size criteria. The Medford District received a detailed citizen 

proposal for the Green Springs Mountain inventory unit, totaling 3,077 acres. The BLM reviewed this 

information and found that this unit did not meet the minimum size requirement, consistent with BLM

Manual 6310 – Conducting Wilderness Characteristics Inventory on BLM Lands, Section .06 C.2.A

(USDI BLM 2012).

As part of this inventory and consistent with Section 2(c) of the Wilderness Act, the BLM evaluated lands 

adjacent to other Federal ownerships. Where these adjacent lands contained wilderness characteristics, the 

BLM included these acres in determining if BLM-lands would meet the minimum size requirement. All 

inventoried lands with wilderness characteristics identified on the Coos Bay and Salem Districts are 

dependent on adjacent Forest Service lands to meet the minimum size requirement.

Under Alternatives A, B, and C, and the Proposed RMP, the BLM would allocate areas to be managed for 

their wilderness characteristics to the District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics. In the design of Alternatives A, B, and C, and the Proposed RMP, if management of a 

portion of an area identified as having wilderness characteristics for other resources or land uses would 

result in an area of less than 5,000 acres that could be managed for wilderness characteristics, none of the 

area would be allocated to the District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics. However, if management of a portion of an area identified as having wilderness 

characteristics for other resources or land uses would result an area of more than 5,000 acres that could be 

managed for wilderness characteristics, the remaining area would be allocated to the District-Designated 

Reserve – Lands Managed for their Wilderness Characteristics.

In Alternative A and the Proposed RMP, the BLM would allocate to the District-Designated Reserve –

Lands Managed for their Wilderness Characteristics all identified lands with wilderness characteristics

that are not within the Harvest Land Base on O&C lands and meet the minimum size requirement. In 

Alternatives B and C, the BLM would allocate to the District-Designated Reserve – Lands Managed for 

their Wilderness Characteristics all identified lands with wilderness characteristics that are outside of the 

Harvest Land Base on O&C lands, are outside of Recreation Management Areas with potentially noncompatible recreation opportunities (motorized and mechanized uses), and meet the minimum size 

requirement. In Alternative D, the BLM would not allocate any lands to the District-Designated Reserve –

Lands Managed for their Wilderness Characteristics and thus would not protect any identified lands with 

wilderness characteristics. The 1995 RMPs did not identify lands with wilderness characteristics and did 

not direct any protection of lands with wilderness characteristics. Therefore, the No Action alternative

would not protect any identified lands with wilderness characteristics.

Affected Environment

Through inventories, the BLM identified 91,003 acres of lands with wilderness characteristics in the Coos 

Bay, Medford, and Salem Districts. Inventories did not identify any lands with wilderness characteristics

in the Eugene and Roseburg Districts or the Klamath Falls Field Office.

The Coos Bay District inventory found one area of 2,473 acres that possesses wilderness characteristics,

refining the area from their 2006 inventory updates. The interdisciplinary review by the BLM concluded

that these acres of the Wasson Creek unit remain valid in terms of relevance and supporting rationale. 

This area on the Coos Bay District relies on adjacent U.S. Forest Service lands containing identified
466 | P a g e

wilderness characteristics to meet the size criterion. The Medford District inventory found seven areas 

that possess wilderness characteristics, totaling 85,899 acres. The Salem District inventory found 4 areas, 

including 9 sub-units that possess wilderness characteristics, resulting in a total of 2,631 acres. All areas 

in the Salem District rely on adjacent designated Wilderness on BLM-administered lands or adjacent 

areas on other Federal lands containing wilderness characteristics to meet the size criterion. Table 3-83

lists and Map 3-4 displays the areas with wilderness characteristics identified by the BLM through 

inventories. 

Table 3-83. BLM-administered lands with wilderness characteristics in the decision area 

District/

Field Office

Sub-unit

(Name)

Identified

BLM-administered

Lands

(Acres)

Coos Bay

Wasson Creek - 2,473

Eugene

No lands were found to possess wilderness characteristics

Klamath Falls

No lands were found to possess with wilderness characteristics

Medford

Berry Creek - 6,254

Burton Nine Mile - 6,103

Dakubetede - 5,099

Round Top Mountain - 5,295

Wellington - 5,712

Whiskey Creek - 6,187

Wild Rogue - 51,249

Roseburg

No lands were found to possess wilderness characteristics

Salem

Bull of the Woods/Opal Creek Additions Nasty Rock 1,197

Bull of the Woods/Opal Creek Additions Evans Mountain 280

Table Rock Wilderness Additions Table Rock 95

Salmon Huckleberry Additions Boulder Creek 506

Salmon Huckleberry Additions Eagle River 14

Salmon Huckleberry Additions Salmon River 119

Clackamas Wilderness/South Fork Clackamas River Memaloose Creek 200

Clackamas Wilderness/South Fork Clackamas River South Fork Clackamas #1 178

Clackamas Wilderness/South Fork Clackamas River South Fork Clackamas #2 42

Totals 91,003
467 | Page

INSERT MAP HERE 

Map 3-4. Lands with wilderness characteristics within the decision area 
468 | P a g e

Environmental Consequences

The No Action alternative would not protect any identified lands with wilderness characteristics.

Management actions would degrade wilderness characteristics over time, and, eventually, wilderness 

characteristics would be lost in all 91,003 acres of identified lands with wilderness characteristics.

The action alternatives and the Proposed RMP vary in the acreage of identified lands with wilderness 

characteristics that would be allocated to the District-Designated Reserve – Lands Managed for their 

Wilderness Characteristics. Table 3-84 and Figure 3-104 show the acres of identified lands with 

wilderness characteristics that the BLM would allocate to the District-Designated Reserve – Lands 

Managed for their Wilderness Characteristics.

Table 3-84. Inventoried lands with wilderness characteristics within the decision area allocated to the 

District-Designated Reserve – Lands Managed for their Wilderness Characteristics

District Unit Name

Identified

BLM-administered

Lands

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Coos Bay Wasson Creek 2,473 2,473 2,473 2,472 - 2,473

Medford

Berry Creek 6,254 6,058 5,160 5,468 - 5,288

Burton Nine Mile 6,103 5,949 6,103 -* - 6,103

Dakubetede 5,099 -* -* -* - -*

Round Top Mountain 5,295 5,295 5,295 -* - 5,295

Wellington 5,712 -* -* -* - -*

Whiskey Creek 6,187 6,187 6,187 6,187 - 6,187

Wild Rogue 51,249 51,214 51,249 51,249 - 51,246

Salem

Bull of the Woods/Opal Creek 

Additions–Nasty Rock† 1,197 1,187 - 837 - 1,185

Bull of the Woods/Opal Creek 

Additions–Evans Mountain 280 250 - 142 - 234

Table Rock Wilderness 

Additions 95 95 58 55 - 95

Salmon Huckleberry 

Additions–Boulder Creek 506 506 - - - 506

Salmon Huckleberry 

Additions–Eagle River 14 7 - - - 7

Salmon Huckleberry 

Additions–Salmon River 119 119 - 119 - 119

Clackamas Wilderness 

Additions–Memaloose Creek 200 169 - 163 - 169

Clackamas Wilderness 

Additions–South Fork 

Clackamas #1

178 158 - 158 - 158

Clackamas Wilderness 

Additions–South Fork 

Clackamas #2

42 42 - 42 - 42

Totals 91,003 79,709 76,525 66,190 - 79,107

* The total acres of contiguous inventoried lands with wilderness characteristics remaining outside the Harvest Land Base or 

incompatible Recreation Management Areas would drop below 5,000 acres and would no longer meet the minimum requirements 

to be considered for allocation to the District-Designated Reserve – Lands Managed for their Wilderness Characteristics.

† Bull of the Woods/Opal Creek Additions-Nasty Rock contains 8 acres of overlapping Harvest Land Base, which are also 

overlapping Recreation Management Areas.
469 | P a g e

Figure 3-104. Acres of inventoried lands with wilderness characteristics allocated to the DistrictDesignated Reserve – Lands Managed for their Wilderness Characteristics

Under Alternatives A, B, and C, and the Proposed RMP, the BLM would manage the District-Designated 

Reserve – Lands Managed for their Wilderness Characteristics with a suite of measures to protect 

wilderness characteristics, including—

 Designating the area as closed to public motorized travel activities;

 Designating the area as a right-of-way exclusion area;

 Designating the area as Visual Resources Management Class II;

 Closing the area to salable mineral material disposal;

 Requiring stipulations on leasable minerals; and

 Recommending the area for withdrawal from locatable mineral entry.

Through these protective measures, the BLM would successfully protect lands with wilderness 

characteristics where allocated to the District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics.

Under Alternative A, the BLM would allocate 79,709 acres (88 percent) of identified lands with

wilderness characteristics to the District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics. On the remaining 11,294 acres (12 percent) of identified lands with wilderness 

characteristics, management actions would degrade wilderness characteristics over time, and, eventually, 

wilderness characteristics would be lost. Identified lands with wilderness characteristics within the 

Dakubetede and Wellington units would drop below the 5,000-acre minimum size requirement under 

Alternative A, and therefore the entire units would not be allocated to the District-Designated Reserve –

Lands Managed for their Wilderness Characteristics.

Under Alternative B, the BLM would allocate 7 units, totaling 76,525 acres (84 percent) of identified

lands with wilderness characteristics to the District-Designated Reserve – Lands Managed for their 

Wilderness Characteristics. On the remaining 14,478 acres (16 percent) of identified lands with 

wilderness characteristics, management actions would degrade wilderness characteristics over time, and, 

eventually, wilderness characteristics would be lost. Identified lands with wilderness characteristics 

0

79,709 76,525

66,190

0

79,107

0

20,000

40,000

60,000

80,000

100,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

District-Designated Reserve 

– Lands Managed 

for their Wilderness Characteristics (Acres)
470 | P a g e

within the Dakubetede and Wellington units would drop below the 5,000-acre minimum size requirement 

under Alternative B, and therefore the entire units would not be allocated to the District-Designated 

Reserve – Lands Managed for their Wilderness Characteristics.

Under Alternative C, the BLM would allocate 11 units, totaling 66,190 acres (73 percent) of identified

lands with wilderness characteristics to the District-Designated Reserve – Lands Managed for their 

Wilderness Characteristics. On the remaining 24,813 acres (27 percent) of identified lands with 

wilderness characteristics, management actions would degrade wilderness characteristics over time, and, 

eventually, wilderness characteristics would be lost. Identified lands with wilderness characteristics 

within the Burton Nine Mile, Dakubetede, Round Top Mountain, and Wellington units would drop below 

the 5,000-acre minimum size requirement under Alternative C, and therefore the entire units would not be 

allocated to the District-Designated Reserve – Lands Managed for their Wilderness Characteristics.

Under Alternative D, the BLM would not allocate any lands to the District-Designated Reserve – Lands 

Managed for their Wilderness Characteristics and therefore would not protect any identified lands with 

wilderness characteristics, similar to the No Action alternative. Management actions would degrade 

wilderness characteristics over time, and, eventually, wilderness characteristics would be lost in all 

91,003 acres of identified lands with wilderness characteristics.

Under the Proposed RMP, the BLM would allocate 79,107 acres (87 percent) of identified lands with

wilderness characteristics to the District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics. On the remaining 11,896 acres (13 percent) of identified lands with wilderness 

characteristics, management actions would degrade wilderness characteristics over time, and, eventually, 

wilderness characteristics would be lost. Identified lands with wilderness characteristics within the 

Dakubetede and Wellington units would drop below the 5,000-acre minimum size requirement under the 

Proposed RMP, and therefore the entire units would not be allocated to the District-Designated Reserve –

Lands Managed for their Wilderness Characteristics. The Proposed RMP includes additional management 

direction not included in Alternatives A, B, and C, which would provide specific restrictions on 

management actions that could adversely affect wilderness characteristics within the District-Designated 

Reserve – Lands Managed for their Wilderness Characteristics (see Appendix B).

Lands with Wilderness Characteristics in the Harvest Land Base

In lands with wilderness characteristics that would not be allocated to the District-Designated Reserve –

Lands Managed for their Wilderness Characteristics, wilderness characteristics would be lost over time. 

However, that loss would occur only as the BLM would implement management actions over time, and 

the rate and extent of implementation of management actions that would adversely affect wilderness 

characteristics would vary by land use allocation. Lands with wilderness characteristics that would be 

allocated to the Harvest Land Base would be most susceptible of all land use allocations to rapid and 

extensive loss of wilderness characteristics, because the BLM would implement timber harvest eventually 

on all lands within the Harvest Land Base and because of the inherent incompatibility of managing for 

wilderness characteristics and sustained-yield timber harvest. Table 3-85 shows the acres of lands with 

wilderness characteristics that would be allocated to the Harvest Land Base.
471 | P a g e

Table 3-85. Inventoried BLM-administered lands with wilderness characteristics allocated to the Harvest 

Land Base

District Unit Name

Identified

BLM-administered

Lands

(Acres)

No 

Action77

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

PRMP

(Acres)

Coos Bay Wasson Creek 2,473 - - - 1 146 -

Medford

Berry Creek 6,254 2,572 196 1,094 786 613 966

Burton Nine Mile 6,103 5,051 154 - - 2,522 -

Dakubetede 5,099 4,322 222 734 769 634 455

Round Top Mountain 5,295 - - - - 25 -

Wellington 5,712 4,530 1,425 1,837 1,923 1,520 1,540

Whiskey Creek 6,187 2,892 - - - 350 -

Wild Rogue 51,249 3,705 35 - - 2,835 3

Salem

Bull of the Woods/Opal 

Creek Additions–Nasty 

Rock

1,197 - 10 12 112 125 12

Bull of the Woods/Opal 

Creek Additions–Evans 

Mountain

280 222 30 47 138 11 46

Table Rock Wilderness 

Additions 95 - - 37 37 42 -

Salmon Huckleberry 

Additions–Boulder 

Creek

506 67 - - 93 - -

Salmon Huckleberry 

Additions–Eagle River 14 7 7 7 8 8 7

Salmon Huckleberry 

Additions–Salmon 

River

119 - - - - - -

Clackamas Wilderness 

Additions–Memaloose 

Creek

200 42 31 29 37 22 31

Clackamas Wilderness 

Additions–South Fork 

Clackamas #1

178 73 20 20 20 20 20

Clackamas Wilderness 

Additions–South Fork 

Clackamas #2

42 20 - - - - -

Totals 91,003 23,502 2,130 3,817 3,924 8,873 3,080

Under the No Action alternative, the BLM would allocate 23,502 (26 percent) of identified lands with 

wilderness characteristics to the Harvest Land Base, more than any other alternative or the Proposed 

RMP. Under the Alternative A, the BLM would allocate 2,130 acres (2 percent) of identified lands with 

wilderness characteristics to the Harvest Land Base, less than any other alternative and the Proposed 

RMP. Under the Proposed RMP, the BLM would allocate 3,080 acres (3 percent) of identified lands with 

wilderness characteristics to the Harvest Land Base, less than any alternative except Alternative A.

 

77 The Matrix and Adaptive Management Area allocations in the No Action alternative are equivalent to the Harvest 

Land Base in the action alternatives and Proposed RMP.
472 | P a g e

Lands with Wilderness Characteristics in Recreation Management

Areas

Wilderness characteristics would be lost within Recreation Management Areas where the BLM would 

manage for non-compatible public motorized and mechanized recreation use. Table 3-86 shows the acres 

of lands with wilderness characteristics that would be in the Recreation Management Areas where the 

BLM would manage for non-compatible motorized and mechanized recreation use. These acreages 

overlap to some extent with the acreages allocated to the Harvest Land Base. That is, some lands with 

wilderness characteristics would be both allocated to the Harvest Land Base and would be within 

Recreation Management Areas where the BLM would manage for non-compatible public motorized and 

mechanized recreation.

Table 3-86. Inventoried BLM-administered lands with wilderness characteristics with incompatible 

recreation management designations78

District Unit Name

Identified

BLM-administered 

Lands

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Coos Bay Wasson Creek 2,473 - - - 2,473 -

Medford

Berry Creek 6,254 - - - - -

Burton Nine Mile 6,103 - - 5,829 5,829 -

Dakubetede 5,099 - 1 3,917 3,917 -

Round Top Mountain 5,295 - - 5,295 5,295 -

Wellington 5,712 - - 8 170 -

Whiskey Creek 6,187 - - - - -

Wild Rogue 51,249 - - - - -

Salem

Bull of the Woods/Opal 

Creek Additions–Nasty 

Rock

1,197 - 121 121 121 -

Bull of the Woods/Opal 

Creek Additions–Evans 

Mountain

280 - - - - -

Table Rock Wilderness 

Additions 95 - - 3 3 -

Salmon Huckleberry 

Additions–Boulder Creek 506 - - - - -

Salmon Huckleberry 

Additions–Eagle River 14 - 14 14 14 -

Salmon Huckleberry 

Additions–Salmon River 119 - - - - -

Clackamas Wilderness 

Additions–Memaloose 

Creek

200 - - - 200 -

Clackamas Wilderness 

Additions-South Fork 

Clackamas #1

178 - - - - -

Clackamas Wilderness 

Additions-South Fork 

Clackamas #2

42 - - - - -

Totals 91,003 - 136 15,188 18,022 -

 

78 This table does not include the No Action alternative because the Recreation Management Area designations

under the 1995 RMPs differ from the action alternatives and the Proposed RMP (see the Recreation section of this 

chapter).
473 | P a g e

Under Alternative A and the Proposed RMP, no lands with wilderness characteristics would be within 

Recreation Management Areas where the BLM would manage for non-compatible public motorized and 

mechanized recreation use. Under Alternative B, 136 acres (less than 1 percent) of lands with wilderness 

characteristics would be within Recreation Management Areas where the BLM would manage for noncompatible public motorized and mechanized recreation use. Under Alternative C, 15,188 acres (17 

percent) of lands with wilderness characteristics would be within Recreation Management Areas where 

the BLM would manage for non-compatible public motorized and mechanized recreation use. Under 

Alternative D, 18,022 acres (20 percent) of lands with wilderness characteristics would be within 

Recreation Management Areas where the BLM would manage for non-compatible public motorized and 

mechanized recreation use, more than any other action alternative and the Proposed RMP.

Summary

The No Action alternative and Alternative D would provide no protection for lands with wilderness 

characteristics, and would allocate the most acreage of lands with wilderness characteristics to the 

Harvest Land Base or would include the most acreage within Recreation Management Areas where the 

BLM would manage for non-compatible public motorized and mechanized recreation use than in other 

alternatives or the Proposed RMP. As a result, wilderness characteristics would most quickly be lost 

under the No Action alternative and Alternative D and would eventually be lost on all identified lands 

with wilderness characteristics in the decision area under these alternatives.

Alternatives B and C would provide more protection of wilderness characteristics than the No Action 

alternative and Alternative D, but less than Alternative A and the Proposed RMP.

Alternative A and the Proposed RMP—

 Would allocate the most lands with wilderness characteristics to the District-Designated Reserve 

– Lands Managed for their Wilderness Characteristics,

 Would allocate the least acreage of lands with wilderness characteristics to the Harvest Land 

Base, and

 Would not include any lands with wilderness characteristics within Recreation Management 

Areas where the BLM would manage for non-compatible public motorized and mechanized 

recreation use.

As a result, Alternative A and the Proposed RMP would provide the most protection of wilderness 

characteristics.

References

USDI BLM. 2012. Conducting Wilderness Characteristics Inventory on BLM Lands Manual 6310. Release 6-129. March 14,

2012. Washington, D. C. http://www.blm.gov/or/plans/rmpswesternoregon/files/lwci-manual.pdf.

---. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, Oregon/Washington 

State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.
474 | P a g e

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475 | P a g e

Livestock Grazing

Key Points

 Under Alternatives A, B, and C, BLM-administered lands available for livestock grazing would 

decrease (from the No Action alternative), from 490,047 acres (20 percent of the decision area) to 

366,231 acres (15 percent of the decision area). This change would occur through the BLM 

making 47 allotments or leases unavailable for livestock grazing.

 Under the Proposed RMP, BLM-administered lands available for livestock grazing would 

decrease (from the No Action alternative), from 490,047 acres (20 percent of the decision area) to 

360,303 acres (15 percent of the decision area). This change would occur through the BLM 

making 52 allotments or leases unavailable for livestock grazing.

 Under Alternative D, the BLM would no longer authorize livestock grazing within the decision 

area, a change that would affect 490,047 acres (20 percent of the decision area). This change 

would occur by the BLM terminating existing livestock grazing authorizations and making all 

allotments unavailable for livestock grazing.

Summary of Notable Changes from the Draft RMP/EIS

The BLM identified five additional allotments as appropriate to consider making unavailable for livestock 

grazing in the Medford District. These five allotments are Upper Table Rock, Clear Creek, Deer Creek, 

Ferns Lease, and Billy Mountain. Upper Table Rock and Clear Creek held active permits, but the 

allotments had been in non-use status for more than 5 years, and the BLM worked with the permittees to 

close these permits since the release of the Draft RMP/EIS. The Deer Creek allotment has been vacant 

since 2005, and there are no proposals from current permittees to graze the allotment. The Ferns Lease 

allotment has no current livestock grazing authorization, no existing permit, and has been vacant for more 

than 10 years. There are no proposals from current permittees to graze livestock on this allotment. The 

Billy Mountain allotment underwent proclamation and relinquishment in December 2015.

Issue 1 includes additional information related to Special Recreation Management Area and Area of 

Critical Environmental Concern designations. Issues 2 and 3 were moved to the ‘considered, but not 

analyzed in detail’ because of a lack of variation amongst the alternatives and the Proposed RMP.

Background

The 1934 Taylor Grazing Act (43 U.S.C. 315 et seq.) which established a system for granting livestock 

grazing privileges on Federal land provides for livestock grazing management on both BLM-administered 

lands within a livestock grazing district (through Section 3 permits) and those outside a livestock grazing 

district (through Section 15 leases). The BLM manages Section 3 permits and Section 15 leases under 

different policies. The only permits administered under Section 3 in the decision area are within a 

livestock grazing district described as the ‘Gerber Block’ in the Klamath Falls Field Office.

The majority of BLM-administered lands within the decision area are outside of established livestock 

grazing districts. Where livestock grazing does take place, Section 15 of the Taylor Grazing Act permits 

livestock grazing on this land through leases. These allotments are comprised of private land intermingled 

with BLM-administered lands. The private land typically provides the majority of livestock grazing acres. 

The BLM gives preference for leases to the owner of the private land nearby and adjoining BLMadministered lands. The term of BLM permit or leases is generally for a period of 10 years.
476 | P a g e

Only the Coos Bay District, Klamath Falls Field Office, and Medford District administer livestock 

grazing in the decision area. The BLM does not currently administer livestock grazing within the Eugene, 

Roseburg, or Salem Districts.

Issue 1

How would each of the alternatives affect the number of allotments available for livestock grazing and 

the associated acres of BLM-administered lands and animal unit months of forage allocated for livestock 

grazing?

Summary of Analytical Methods

The BLM compared the number of allotments that would be available for livestock grazing on BLMadministered lands under each alternative and the Proposed RMP. The number of acres and animal unit 

months (AUMs) associated with the available allotments were also considered. The BLM did not include 

small exclosures within an allotment that exclude livestock grazing for the purpose of this analysis. 

Variability exists between legacy acreage and geospatial acreage; for consistency, geospatial data was 

typically used.

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which is incorporated here by reference (USDI BLM 

2014, pp. 62–65).

Affected Environment

The Coos Bay District, Klamath Falls Field Office, and Medford District currently have 490,047 acres (20 

percent of the decision area) of BLM-administered lands that authorize livestock grazing allotments in the 

planning area (Table 3-87).

Table 3-87. BLM-administered livestock grazing allotments in the decision area

District/

Field Office

Allotments*

(Number)

Total BLM-administered 

Lands Within Allotments

(Acres)

Active Use

(AUMs)

Permittees

(Number)

Coos Bay 4 544 120 4

Klamath Falls 94 203,582 13,219 63

Medford 91

†

285,920 11,886 43

Totals 189 490,047 25,225 110

* Allotments include those vacant and without a current permit/lease and closed. These do not include unallotted lands.

† This count includes 11 allotments that have been removed from the reporting system due to inactivity (no livestock grazing has 

occurred) since before the 1995 RMP but have never had decisions considered regarding their availability for livestock grazing.

Since adoption of the 1995 RMP, the number of vacant allotments has increased across the planning area. 

A vacant allotment is an allotment that currently does not have an active permit or lease. Some allotments 

have been vacant since the 1970s. The reasons for the increase in vacant allotments include:

 Relinquishment by operators

 Cancellation due to nonuse or noncompliance

 Lack of interest

 Difficulties within an allotment because of intermingled private land
477 | P a g e

 Conflicts with other users of public land

 Lack of fencing to control livestock on public land

 Change of boundary fencing that excludes BLM-administered lands

Table 3-88. Current livestock grazing levels compared to 1995 RMP levels

District/

Field Office*

1995 RMP Levels 2014 Levels†

Available 

AUMs

Active 

Allotments

Vacant 

Allotments

Active Use

(AUMs)

Active 

Allotments

Vacant 

Allotments

Coos Bay 270 7 - 120 0 4

Klamath Falls 13,662 95 - 13,210 82 13‡

Medford 17,458 99 18 12,000 46 45

Totals 31,390 201 18 25,225 128 63

* For reporting purposes, all allotments and AUMs the districts administer are counted including vacant allotments and their 

associated AUMs. Active allotments in this table are allotments with a current permit or lease. Some of these allotment acres and 

associated AUMs do not occur within the planning area. Suspended AUMs are not counted in this table.

† Previous decisions within the planning area have made allotments unavailable since 1995 levels and are not reflected in the 

2014 levels.

‡ Several of these vacant allotments in the Klamath Falls Field Office have been made unavailable to livestock grazing through 

decisions preceding this RMP revision.

Existing livestock grazing leases or permits within the BLM-administered lands in the decision area 

authorize 25,225 AUMs. Current levels of available livestock grazing are 6,165 AUMs less than 

permitted levels in 1995. These AUMs are available for livestock grazing, but some allotments are vacant 

and not being used. Actual levels of livestock use vary due to annual fluctuations of individual livestock 

operations or environmental conditions such as relinquishment by operators, transfers, and drought, or 

changes in livestock grazing leases or permits due to nonuse, noncompliance, or lack of interest. The 

change in use of allotments is due to several reasons including the voluntary elimination of livestock 

grazing associated with the Cascade-Siskiyou National Monument, the combination of multiple 

allotments into one, the division of allotments into more than one, and the reduction in livestock grazing 

for resource protection.

There are six allotments within the planning area containing acreage in the Cascade-Siskiyou National 

Monument in addition to acreage in the decision area. All acres within the monument are outside the 

decision area. Table 3-89 displays the acres of each allotment that overlaps the decision area and the 

monument. The Klamath Falls Field Office administers the Dixie and Buck Mountain Allotments, and the 

Medford District administers the Deadwood Allotment. The Keene Creek Allotment, Siskiyou Allotment, 

and Soda Mountain Allotment have been made unavailable to livestock grazing through previous 

decisions and public law and are not evaluated as part of this analysis.
478 | P a g e

Table 3-89. BLM-administered livestock grazing allotments in the decision area that overlap the Cascade 

Siskiyou National Monument (CSNM)

Allotment

Name

Allotment

Number

CSNM

(Acres)

Decision Area

(Acres)

Total

AUMs Availability Status

Buck Mountain 00103 739 7,416 204 Available

Deadwood 20106 37 7,967 788 Available

Dixie 00107 1283 4,439 320 Available

Keene Creek 10115 10,600 13,019 -

Made unavailable for livestock 

grazing through previous decision 

and law (Pub. L. 111-11)

Siskiyou 10118 2,163 260 -

Made unavailable for livestock 

grazing through previous decision 

and law (Pub. L. 111-11)

Soda Mountain 10110 35,619 413 -

Made unavailable for livestock 

grazing through previous decision 

and law (Pub. L. 111-11)

Environmental Consequences

Under all alternatives and the Proposed RMP, all components of livestock grazing authorizations (acres 

for livestock grazing, number of allotments, AUMs, and permittees/lessees) would either remain the same 

or decrease as shown in Table 3-90. The No Action alternative would retain all allotments in their current 

management status and level of livestock grazing authorizations. Alternatives A, B, and C, would make 

allotments that have generally been vacant or inactive for 5 or more years unavailable for livestock 

grazing. Under the Proposed RMP, the BLM would make unavailable to livestock grazing those 

allotments that have generally been vacant, inactive, or in non-use status for 5 years or more (see 

Appendix B for those allotments proposed to be made unavailable). Under Alternative D, the BLM

would cease to authorize any livestock grazing within the decision area and receive no payments for 

AUMs.
479 | P a g e

Table 3-90. Livestock grazing availability for the Coos Bay District, Klamath Falls Field Office, and 

Medford District

District/

Field Office

Alternative/

Proposed 

RMP

Allotments

Available for 

Livestock Grazing 

(Number)

BLMadministered

Lands

(Acres)

Active 

Use

(AUMs)

Permittees

(Number)

Coos Bay

No Action 4 544 120 4

Alt. A, B, C - - - -

Alt. D - - - -

PRMP - - - -

Klamath Falls

No Action 94 203,582 13,219 63

Alt. A, B, C 92 203,377 13,199 63

Alt. D - - - -

PRMP 92 203,377 13,199 63

Medford

No Action 91 285,920 11,886 43

Alt. A, B, C 50 162,854 9,588 43

Alt. D - - - -

PRMP 45 151,949 9,197 41

Totals

No Action 189 490,047 25,225 106

Alt. A, B, C 142 366,231 22,787 106

Alt. D - - - -

PRMP 137 355,326 22,396 104

Although the Proposed RMP shows a decrease in permittees and allotments, these were allotments in 

non-use or vacant status. Therefore, these decreases would not reduce the number of allotments or 

permittees that currently have an active permit or lease in 2015.

Under Alternatives A, B, and C, the number of allotments available for livestock grazing would decrease 

from 189 to 142. The associated acres of BLM-administered lands and AUMs of forage available for 

livestock grazing through the issuance of livestock grazing leases or permits would decrease from 490,047 

acres (20 percent of the decision area) and 25,225 AUMs, to 366,231 acres (15 percent of the decision 

area) and 22,787 AUMs (Table 3-90). In the Proposed RMP, an additional four allotments would be made 

unavailable for livestock grazing. The associated acres of BLM-administered lands and AUMs of forage 

available for livestock grazing would decrease an additional 5,928 acres and 216 AUMs on the Medford 

District compared to Alternatives A, B, and C. In Alternative D, the BLM would terminate existing 

livestock grazing authorizations and make all allotments unavailable for livestock grazing. The number of 

AUMs billed would remain at current levels in all alternatives except Alternative D.

Figure 3-105 and Figure 3-106 show the acres and number of allotments available for livestock grazing

and Figure 3-107 shows the associated AUMs available.
480 | P a g e

Figure 3-105. Allotments available for livestock grazing

Figure 3-106. Acres available for livestock grazing

Figure 3-107. Allocated livestock grazing AUMs

4

94 91

0

92

50

0 0 0 0

92

45

0

25

50

75

100

Coos Bay Klamath Falls Medford

Number of Available 

Allotments

District/Field Office

No Action Alt. A, B, C Alt. D PRMP

544

203,582

285,920

0

203,377

159,523

0 0 0 0

203,377

151,949

0

100,000

200,000

300,000

400,000

Coos Bay Klamath Falls Medford

Available Allotment Acres

District/Field Office

No Action Alt. A, B, C Alt. D PRMP

120

13,219

11,886

0

13,199

9,529

0 0 0 0

13,199

9,197

0

5,000

10,000

15,000

Coos Bay Klamath Falls Medford

Available AUMs

District/Field Office

No Action Alt. A, B, C Alt. D PRMP
481 | P a g e

In the Medford District, Alternatives A, B, and C, and the Proposed RMP would decrease the number of 

available allotments as compared to the No Action alternative. This decrease would occur on allotments 

vacant for 5 years or more. In Alternatives A, B, and C, the BLM would reduce the number of available 

allotments by 47. The associated BLM-administered lands would decrease by 127,146 acres and by 2,497 

AUMs. Under the Proposed RMP, the number of allotments would decrease by 52 from the No Action 

alternative with a decrease of 134,720 acres and of 2,829 AUMs. 

In the Klamath Falls Field Office, Alternatives A, B, C, and Proposed RMP would decrease the number 

of allotments available to livestock grazing by two compared to the No Action alternative. A portion of 

the Edge Creek, Chicken Hills, and Chase Mountain allotments (5,908 acres) is fenced off from livestock 

grazing and is included in the Klamath River Area of Critical Environmental Concern. The BLM would 

cease authorizations for livestock grazing in Alternatives A, B, and C, and the Proposed RMP. No AUMs 

are currently associated with these ACEC acres and no livestock grazing is currently occurring. The 

remainder of the Edge Creek Allotment would continue to be available for livestock grazing. The BLM 

would also cease authorizations for the Plum Hills Allotment, a vacant allotment with 160 acres and 20 

available AUMs. 

In the Coos Bay District, all action alternatives and the Proposed RMP would decrease the number of 

available leases as compared to the No Action alternative. The decrease would occur on four allotments 

covering approximately 544 acres with 120 AUMs that would be unavailable for livestock grazing. As 

these allotments are currently vacant, the number of permittees would not change. 

Under Alternative D, the BLM would no longer authorize livestock grazing within the decision area, a 

change that would make 189 allotments unavailable. This would occur on 490,047 acres (20 percent of 

the decision area) compared to the No Action alternative. A total 25,225 AUMs would be unavailable for 

livestock grazing, and the BLM would terminate existing permits and leases for 106 permittees. The BLM 

would no longer collect fees on these AUMs. The BLM addresses the effect of the termination of grazing 

permits under Alternative D on revenues to the BLM under Issue 1 and on jobs and earnings in the 

planning area under Issue 2 of the Socioeconomics section of this chapter. Alternative D would have the 

greatest effect to livestock grazing for the Klamath Falls Field Office and the Medford District when 

compared to the other alternatives and the Proposed RMP. 

Figure 3-108 shows allotted BLM-administered lands within the planning area by allotment status within 

the Coos Bay District, the Klamath Falls Field Office, and the Medford District. 
482 | Page

Figure 3-108. Livestock grazing allotments on BLM-administered lands by livestock grazing availability 

under the Proposed RMP 

Livestock Grazing within SRMAs and ACECs 

Acres and total number of allotments within Special Recreation Management Areas (SRMA) or Areas of 

Critical Environmental Concern (ACEC) vary by alternative (see Chapter 2). Some SRMAs and ACECs 

may additionally regulate or restrict livestock grazing within the designated areas’ boundaries. These 

discussions do not include Alternative D, under which all allotments would be unavailable to livestock 

grazing. 

Special Recreation Management Areas 

In the Medford District and the Klamath Falls Field Office in Alternatives A, B, and C, and the Proposed 

RMP, management of SRMAs could have an effect on the number of acres available for livestock grazing 

through site-specific protection (e.g., exclosures) or management actions (e.g., restricting season of use). 
483 | P a g e

The BLM may decrease stocking levels through subsequent agreements or necessary decisions. 

The BLM would still issue land use authorizations through leases, permits, and easements if livestock 

grazing was compatible with SRMA recreation objectives and not interfere with recreation opportunities 

and setting characteristics.

79 Those areas designated as SRMAs would decrease acres available to 

livestock grazing as shown in Table 3-91 if livestock grazing is determined to be incompatible within 

those areas. Alternatives B and C, and the Proposed RMP would decrease 3 percent and Alternative A 

would decrease 0.4 percent of acres currently available to livestock grazing.

Table 3-91. Acres of SRMAs within available allotments within the planning area

SRMA Lands Within Allotments Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

PRMP

(Acres)

Allotments Available for Livestock 

Grazing 1,426 10,809 10,531 9,372

Areas of Critical Environmental Concern

In the Coos Bay District, the Klamath Falls Field Office, and the Medford District, under the No Action 

alternative, Alternatives A, B, and C, and the Proposed RMP, ACEC designations may affect the number 

of acres available for livestock grazing. Effects may occur through site-specific protection (e.g.,

exclosures) or management actions (e.g., restricting season of use) to maintain or enhance relevant and 

important values. The BLM may decrease stocking levels through subsequent agreements or decisions.

Designation of ACECs would allow land use authorizations through leases, permits, and easements when 

compatible with the special management needed to retain relevant and important values of the ACEC. 

Where livestock grazing is found to be incompatible with protection of the relevant and important values 

of the ACEC, those areas may require management that would decrease acres available to livestock 

grazing. Table 3-92 shows the total acres of ACECs that would be designated that occur within 

authorized grazing allotments under the alternatives and the Proposed RMP. The No Action Alternative 

would decrease the largest number of acres available to livestock grazing, affecting 16,453 acres (3

percent) of the planning area. The Proposed RMP would decrease 7,165 acres (2 percent) of acres 

available to livestock grazing. Alternative A would decrease 8,195 acres (2 percent), and Alternative B 

would decrease 4,622 acres (1 percent) available for livestock grazing.

Table 3-92. Acres of ACECs within authorized allotments for each alternative and the Proposed RMP

within the planning area

ACEC Lands Within 

Allotments

No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

PRMP

(Acres)

Allotments Available for 

Livestock Grazing 16,453 8,195 4,622 4,713 7,165

 

79 New guidance on applying RMA allocations on BLM-administered lands creates a marked difference in how 

RMA designations are defined under the No Action alternative and the action alternatives and the Proposed RMP. 

SRMAs, under the No Action alternative, would include lands not managed for recreation as the primary use, and 

the BLM would not manage SRMAs under the No Action in a manner that would prioritize recreational uses over 

other land management uses, including livestock grazing. Because the RMA designation definitions differ between 

the No Action alternative, the action alternatives, and the Proposed RMP, the relative ranking analysis can only be 

used for the action alternatives and the Proposed RMP.
484 | P a g e

Issues Considered but not Analyzed in Detail

How would each of the alternatives affect the attainment of Standards for Rangeland Health and 

Guidelines for Livestock Grazing Management on those lands allocated for livestock grazing?

Current livestock grazing regulations direct the BLM to manage livestock grazing in accordance with 

Standards for Rangeland Health. The BLM developed the 1997 Standards for Rangeland Health and 

Guidelines for Livestock Grazing Management for Public Lands in Oregon and Washington (USDI BLM 

1997) in consultation with Resource Advisory Councils, Provincial Advisory Committees, tribes, and 

others. These standards are the basis for assessing and monitoring rangeland conditions and trend. The 

BLM implements appropriate action to address the failure to meet standards or conform to guidelines 

resulting from livestock grazing management or practices on BLM-administered lands through 43 CFR 

4180.2(c). Implementation of livestock grazing under all alternatives and the Proposed RMP except 

Alternative D would be required to conform to these standards, guidelines, and regulations. Alternative D 

does not authorize livestock grazing and therefore these standards, guidelines, and regulations are not 

applicable.

The BLM has assessed 65 percent of livestock grazing allotments and leases within the decision 

area to determine whether they are meeting rangeland health standards. Completed Rangeland 

Health Assessments by allotment are available on BLM web sites for the Lakeview and Medford 

Districts. As shown in Table 3-93, the BLM found livestock grazing to be a contributing factor in 

not meeting rangeland health standards in twelve allotments: five in Medford and seven in Klamath 

Falls. In those allotments, the BLM has taken appropriate action by adjusting livestock grazing 

management pursuant to direction in 43 CFR 4180.2(c) to ensure significant progress toward 

meeting the standards and to eliminate livestock grazing as the causal factor for not meeting the 

health standard. Adjusting livestock grazing management generally requires changes in livestock 

numbers, season of use, and animal unit months, construction of range improvements, or 

implementation of intensive livestock grazing systems. Under all alternatives and the Proposed 

RMP, except Alternative D, the BLM would continue to manage livestock grazing on these twelve

allotments in a manner that will result in significant progress toward fulfillment of the standards. 

Under Alternative D, the BLM would cease to authorize livestock grazing. This removal of 

livestock grazing would allow some allotments not meeting rangeland health standards to recover 

at a faster rate when compared to the other alternatives and the Proposed RMP.
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Table 3-93. Rangeland Health Standards Assessments for the Coos Bay District, Klamath Falls Field 

Office, and Medford District

Assessments Coos Bay Klamath Falls Medford

Allotments Acres Allotments Acres Allotments Acres

Rangelands Meeting All 

Standards or are Making 

Significant Progress Toward 

Meeting the Standards

4 543 52 108,417 20 32,383

Rangelands Not Meeting All 

Standards with Appropriate 

Action Taken to Ensure 

Significant Progress Toward 

Meeting the Standard 

(Livestock was a contributing

factor)

- - 7 35,376 5 15,312

Rangelands Not Meeting All 

Standards or Making 

Significant Progress Toward 

Meeting the Standard Due to 

Causes Other Than Livestock 

Grazing

- - 11 50,236 25 125,117

Allotments Assessed and 

Closed to Livestock Grazing 

with a Previous Decision

- - - - 3 13,692

Total Assessed 4 543 70 194,029 50 186,504

Allotments Not Assessed - - 25 15,349 41 113,202

Totals 4 543 95 209,377 91 299,706

The BLM is completing Rangeland Health Assessments on the grazed allotments lacking an 

assessment within the decision area based on district priorities. Should assessments find livestock 

grazing to be a contributing factor to not meeting rangeland standards, the BLM would take 

appropriate action by adjusting livestock grazing management pursuant to direction in 43 CFR 

4180.2 to ensure significant progress toward meeting the standards and to eliminate livestock 

grazing as the causal factor for not meeting the health standard.

Across 36 allotments within the decision area, 11 in Klamath Falls and 25 in Medford are currently not 

meeting all standards or making significant progress towards meeting standards for reasons other than 

livestock grazing. Opportunities to achieve desired rangeland health conditions may be limited in some 

areas due to past management activities and may not be possible to achieve through changes in livestock 

grazing management or even through removal of livestock grazing. An example of this would be historic 

vegetative treatments that converted an area from a perennial grass/forb understory to an invasive plant

understory (e.g., medusahead, dogtail, and bulbous bluegrass). In this situation, the upland Rangeland 

Health Standard 1 may not be met though any livestock grazing management to include the removal of 

livestock unless intensive reseeding combined with intensive weed treatments are additionally 

implemented.
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How would each of the alternatives affect the BLM’s ability to provide forage on those lands allocated for 

livestock grazing?

Current forage conditions within individual allotments are variable based on historic livestock grazing

levels, past management actions, and current livestock grazing management. Past timber harvest activities 

within allotments created canopy openings that provide increased forage for livestock. Forest 

management actions proposed under the alternatives considered in this analysis would be expected to 

continue to influence forage conditions. In alternatives including regeneration harvest within the analysis 

area (i.e., BLM-administered lands within allotments), forage production is assumed to temporarily 

improve during the initial years post-harvest due to the decreased competition between understory and 

overstory vegetation. Alternatives A, B, and C, and the Proposed RMP include varying intensities of 

regeneration harvest on varying acres within the analysis area; however, the overwhelming majority of 

the Harvest Land Base in the allotments are within the uneven-aged timber are and would receive unevenaged forest management. Changes to forage production by alternative or the Proposed RMP, including the 

moderate increases of forage availability within the analysis area, may affect livestock distribution within 

allotments; however, no increases in stocking rate would occur due to increases in available forage. These 

alternatives and the Proposed RMP would continue to provide adequate livestock forage for livestock 

grazing levels. Alternative D closes all allotments and so there are no acres to consider for forage 

production.

References

USDI BLM. 1997. Standards for rangeland health and guidelines for livestock grazing management for public lands administered 

by the Bureau of Land Management in the states of Oregon and Washington. Oregon State Office, Portland, OR. 22 pp. 

http://www.blm.gov/or/resources/recreation/csnm/files/rangeland_standards.pdf.

---. 2014. Resource management plans for western Oregon planning criteria. Bureau of Land Management, Oregon/Washington 

State Office, Portland, OR. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php.

Walburger, K. T., T. DelCurto, and M. Vavra. 2007. Influence of forest management and previous herbivory on cattle diets. 

Rangeland Ecology & Management 60(2): 172–178. http://dx.doi.org/10.2111/05-223R3.1.
487 | P a g e

Minerals

Key Points

 Lands closed to salable mineral material disposal would decrease from 13 percent of the decision 

area under the No Action alternative to between 9 and 10 percent for the action alternatives and 

the Proposed RMP. The locations of these closed areas would be more widely dispersed in the 

action alternatives and the Proposed RMP than in the No Action alternative.

 Under the action alternatives and the Proposed RMP, the BLM would recommend for withdrawal 

from locatable mineral entry between 6 and 8 percent of the decision area, in addition to the 4 

percent already withdrawn.

o Almost half of lands recommended for withdrawal under the Proposed RMP are ranked 

as high for mineral occurrence and development. The withdrawal of these lands from 

locatable mineral entry would curb the development of mineral resources.

 The decision area would remain open to leasable mineral development under various stipulations

in the alternatives and the Proposed RMP except where lands are already closed by legislation.

Summary of Notable Changes from the Draft RMP/EIS

The BLM updated information on mining claims, Notices, and pending or authorized Plans of Operation 

in the decision area based on recent data and analysis. The analysis of areas closed to salable mineral

material disposal and recommended for withdrawal from locatable mineral entry does not present acreage 

by specific criteria (e.g., ACECs and Recreation Management Areas) because these criteria overlap 

geographically, creating confusion and errors related to the acreage associated with each specific 

criterion. Thus, the Proposed RMP/Final EIS identifies the criteria but presents acreage by areas closed to 

salable mineral material disposal and recommended for withdrawal from locatable mineral entry for the 

alternatives and the Proposed RMP.

Background

The BLM oversees the mineral estate on nearly 40 million acres of BLM-administered lands, U.S. Forest 

Service lands, and other federally administered and Indian Trust lands in Oregon. Within the decision 

area, the BLM manages approximately 2.5 million acres of Federal surface ownership and an additional 

68,700 acres of sub-surface Federal minerals with private surface ownership. Table 3-94 lists acres by 

district.
488 | P a g e

Table 3-94. Acres of surface and mineral estate within the decision area

District/

Field Office

Federal Surface

and Mineral Estate

(Acres)*

Federal Minerals

and Private Surface

(Acres)*

Coos Bay 329,600 12,200

Eugene 317,400 1,300

Klamath Falls 212,000 21,000

Medford 866,300 4,700

Roseburg 425,600 1,700

Salem 398,100 27,800

Totals 2,549,000 68,700

* Data from the 2008 Final EIS (USDI BLM 2008) and district-specific information

Physiography

The planning area contains five geologic physiographic regions: the Coast Range, Willamette Valley, 

Cascade Mountains (High and Western), Klamath Mountains, and the Basin and Range (Figure 3-109).80

Each region’s unique geology influences the mineral occurrences.

Figure 3-109. Physiographic regions in Oregon

(Orr and Orr 2012)

Mineral Resources of the Planning Area

The Oregon Department of Geology and Mineral Industries (DOGAMI) database (MILO) shows that the 

vast majority of mineral resources used in Oregon are common rock used in construction and road 

surfacing (http://www.oregongeology.org/sub/milo/index.htm). There are over 5,500 mapped quarry sites 

throughout the planning area. The MILO database shows 300 occurrences for other mineral commodities 

such as clay, limestone, pumice, and silica sand throughout the planning area. There are 150 occurrences 

 

80 These regions are different from the terrestrial physiographic regions described in the FEMAT Report (1993) and 

illustrated in Figure 3-187.
489 | P a g e

for coal with most sites in coastal areas concentrated around Coos Bay. In addition, the database shows 

3,300 metal occurrences with gold, silver, copper, nickel, chromite, and other minerals with nearly all 

minerals located in southwest Oregon.

Coast Range Mineral Resources

Coal seams occur throughout the Coast Range with the majority in Coos County. In the Coos Bay 

District, there is a coalbed natural gas area of mutual interest. The Coast Range has potential for oil and 

gas development. The State’s first commercial gas field was located in 1979 near Mist, Oregon in 

Columbia County. This field has 18 wells, which have produced 65 billion cubic feet of gas. Other 

economically valuable minerals include beach placers containing gold and platinum in locations from 

Cape Blanco to Cape Arago.

Willamette Valley Mineral Resources

Deeply weathered basalts with bauxite enriched with aluminum and iron occur in the Willamette Valley 

with the thickest deposits in Washington and Columbia counties. Limonite localities also occur in Lake 

Oswego. A 20-mile-wide belt of cinnabar exists in Lane, Douglas, and Jackson Counties, which has been 

mined for mercury, especially near the southern end of the Willamette Valley.

Cascade Mountains Mineral Resources

Gold and silver have been mined in the Bohemia Mountain region south of Cottage Grove and the 

Quartzville and Blue River mining districts by McKenzie Bridge. The North Santiam mining district has 

also historically yielded copper, zinc, lead, silver, and gold. A series of hot springs (in an irregular 12-

mile-wide north/south-oriented belt) mark a thermal boundary existing between the High Cascades and 

Western Cascades. Temperatures of the waters can range between 90 and 190 °F in certain areas. The 

thermal gradients of the region may represent a large potential source of renewable geothermal energy. 

More information is available in the Sustainable Energy section of this chapter.

Klamath Mountains Mineral Resources

The Klamath Mountains has substantial mineral resources due to its geologic diversity. Mineralization is 

primarily attributed to tectonic plate evolution and secondarily to later plutonic intrusion. This area has 

historically produced gold, silver, copper, nickel, and chromite along with other minerals. Most of these 

minerals are closely associated with ophiolites and plutons in the areas of Ashland, Gold Hill, and Grants 

Pass. As much as 75 percent of the gold produced from this area has come from placers deposits. Copper 

was historically mined from the Josephine ophiolite near Grants Pass. Nickel was historically mined from

weathered ophiolites near the town of Riddle and chromite was mined from ophiolites throughout the 

Klamath Mountains. Chromite-rich beach sands derived from the Klamath Mountains can be found on the 

southern Oregon coast.

Basin and Range Mineral Resources

Historically, uranium, mercury, and borax have been produced in this area. Diatomite occurs near the 

Sprague River. This region has a thin crust with numerous faults and high heat flow, which creates an 

increased possibility for geothermal resources. More information is available in the Sustainable Energy 

section of this chapter. 
490 | P a g e

Issue 1

How would the alternatives affect salable mineral material disposal?

Summary of Analytical Methods

The BLM evaluated how the acreage proposed for closure to salable mineral material disposal under each 

alternative and the Proposed RMP would affect potential future development of this resource. Under each 

action alternative and the Proposed RMP, the BLM would close District-Designated Reserve – Lands 

Managed for their Wilderness Characteristics, eligible Wild and Scenic River segments, some Areas of 

Critical Environmental Concern (ACECs), and some Recreation Management Areas (RMAs) to salable 

mineral material disposal. Upon the completion of this RMP revision, the BLM would display the areas 

closed to salable mineral material disposal on map(s) accompanying the approved RMP.

The BLM evaluated data supplied by LR2000,81 by each district, and from the Oregon Department of 

Geology and Mineral Industries to determine the location of mineral material sites, which are primarily 

rock quarries in the decision area. The BLM determined that this data could not be utilized to predict the 

location of future mineral material sites. The BLM did not complete reasonably foreseeable development 

scenarios and Mineral Potential Reports for salable mineral materials for this Proposed EIS/Final EIS. All 

estimates are based on broad-scaled “trends” review, which presents professional opinion rather than a 

methodological approach.

The Planning Criteria, which the BLM incorporates here by reference (USDI BLM 2014, p.104), provides 

more detailed information on analytical assumptions, methods and techniques, and geographic and 

temporal scales.

Background

Salable mineral materials include common variety quarry rock used in construction and road surfacing as 

well as sand and gravel, clay, and volcanic pumice and cinders. Regulations found in 43 CFR 3600 –

Mineral Materials Disposal, guide the exploration, development, and disposal of mineral material 

resources and the protection of resources and the environment. The disposal of mineral materials includes 

direct sales to the public at fair market value, and issuing free-use permits to government entities or nonprofit organizations. Disposal of these mineral materials is at the discretion of the BLM.

The primary salable mineral material in the decision area is quarry rock. The BLM, private companies, 

and local governments use the majority of this quarry rock for road surfacing. Other uses of quarry rock 

include rock material for fish enhancement projects, jetties, boat ramps, and reclamation projects. The 

BLM also disposes sand, gravel, soil, fill material, clay, volcanic pumice and cinders, and specialty stone 

through open sales and free use permits.

Affected Environment

The use of mineral materials is dependent on demand by the BLM, private companies, local governments, 

and the public. Figure 3-110 and Figure 3-111 display the number of sales across the decision area and 

the mineral material production by cubic yard for the years 2007–2013 (LR2000).

 

81 LR2000 is a BLM database containing information about minerals.
491 | P a g e

Figure 3-110. Number of sales or permits for mineral material by year in the decision area 

Figure 3-111. Sales volume of mineral material produced by years 2007–2013 in the decision area 

This mineral material disposal data from 2007 to 2013 includes 192 small sales of less than 5 cubic yards 

each. These sales account for 40 percent of the total mineral material sales, but constitute a small fraction 

of the total volume of mineral material sold. These small sales are from the Medford District and 

represent public purchases from designated rock quarries for home landscaping projects. 

There are 681 developed quarry sites in the decision area, based on the BLM inventory of existing rock 

quarry sites. Figure 3-112 illustrates the spatial distribution of existing quarry sites in the decision area. 

The majority of these sites are hard rock quarries, though a limited number of sites produce pumice, sand, 

gravel, or dimension stone. Many of these sites were developed before the 1990s and have been in use 

intermittently. The footprint—or area of disturbance—of quarry sites is variable and ranges 

89

79

41

92

75

61

48

0

20

40

60

80

100

2007 2008 2009 2010 2011 2012 2013

Number of Sales/Permits

Fiscal Year

24,290

45,290

5,100

24,340

46,310

35,555

11,070

0

10,000

20,000

30,000

40,000

50,000

2007 2008 2009 2010 2011 2012 2013

Sales Volume (Cubic Yards)

Fiscal Year
492 | Page

approximately from 0.01 to 5 acres. A typical quarry is less than 0.5 acre in size. The BLM estimates that 

that approximately 25–33 percent of rock quarries are near depletion, with a few thousand cubic yards of 

rock remaining at each site. At some quarries, continued removal would require expansion of the existing 

footprint. 

Figure 3-112. Developed quarry sites in the decision area from 2014 district inventories 

The BLM does not have a complete inventory of potential rock quarry sites in the decision area. The 

BLM locates rock quarries based on the suitability of the available rock to meet required specifications. 

However, access, proximity to area of use, and environmental considerations are also important factors in 

determining quarry development. 

Table 3-95 shows the number of rock quarry sites in the decision area as of 2014 based on district 

inventories. 
493 | P a g e

Table 3-95. Rock quarry sites in the decision area

District/

Field Office Quarry Sites

Coos Bay 31

Eugene 87

Klamath Falls 13

Medford 250

Roseburg 203

Salem 97

Total 681

All of the salable activity previously described takes place on BLM-administered lands that are open to 

salable mineral material disposal. Table 3-96 provides a breakdown by district of the acres of BLMadministered lands that are currently closed to salable mineral material disposal. Closed non-discretionary 

lands, which total 31,530 acres, would remain closed under the alternatives and the Proposed RMP. The 

Salem District has the most lands closed to discretionary salable mineral material disposal and Roseburg 

the least.

Table 3-96. Acres of lands currently closed to salable mineral material disposal (i.e., the No Action 

alternative)

District/

Field Office

Closed

Non-discretionary*

†

(Acres)

Closed

Discretionary*

†

(Acres)

Totals

(Acres)

Coos Bay 600 14,700 15,300

Eugene 100 9,100 9,200

Klamath Falls 300 14,500 14,800

Medford 24,600 20,800 45,400

Roseburg 30 8,400 8,430

Salem 5,900 220,400 226,300

Totals 31,530 287,900 319,430

* Legal mandates establish non-discretionary closures while a discretionary closure is the result of an agency management 

decision.

† Data from the 2008 Final EIS (USDI BLM 2008)

See Appendix M for more information regarding trends in salable mineral material developments.

Environmental Consequences

Figure 3-113 and Table 3-97 list acres that the BLM would close to salable mineral material disposal for 

the alternatives and the Proposed RMP.
494 | P a g e

Figure 3-113. Acres closed to salable mineral material disposal in the decision area

* Legal mandates establish non-discretionary closures while a discretionary closure is the result of an agency management 

decision.

† ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible Wild and 

Scenic Rivers

Table 3-97. Acres closed to salable mineral material disposal in the decision area

Land Category No 

Action Alt. A Alt. B Alt. C Alt. D PRMP

Closed Discretionary* under the 

1995 RMPs (Acres) 287,900

Closed Discretionary* under the 

1995 RMPs (Percent) 12%

Special Areas†(Acres) 200,878 194,858 215,053 207,655 217,711

Special Areas†(Percent) 8% 8% 9% 9% 9%

Closed Non-discretionary* (Acres) 31,530

Closed Non-discretionary* 

(Percent) 1%

Totals (Acres) 319,430 232,408 226,388.09 246,583.1 239,185.1 249,241

Totals (Percent) 13% 9% 9% 10% 10% 10%

* Legal mandates establish non-discretionary closures while a discretionary closure is the result of an agency management 

decision.

† ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible Wild and 

Scenic Rivers

31,530 31,530 31,530 31,530 31,530 31,530

287,900

200,878 194,858

215,053 207,655 217,711

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

No Action Alt. A Alt. B Alt. C Alt. D PRMP

Closed to Salable Mineral Material Disposal (Acres)

Closed Non-discretionary* Closed Discretionary* Special Areas†
495 | P a g e

The action alternatives and the Proposed RMP would open more land to salable mineral material disposal

than the No Action alternative. Under the No Action alternative, 13 percent of the decision area is closed 

to salable mineral material disposal with the majority in the Salem District (Table 3-96). Under the action 

alternatives and the Proposed RMP, the BLM would reduce the total acres closed to salable mineral

material disposal to between 9 and 10 percent of the decision area (Table 3-97). Because of uncertainties 

with regard to opportunities for salable mineral material disposal on BLM-administered lands, such as 

location and extent, specific environmental or socioeconomic effects of increasing the acreage of lands 

available for salable mineral material disposal would be speculative.

Data is not readily available to display spatially the areas closed to salable mineral material disposal under 

the No Action alternative; therefore, a comparison map is not included in this analysis.

Appendix F lists each ACEC and Appendix O lists each RMA and each status of open or closed to 

salable mineral material disposal under the action alternatives and the Proposed RMP.

Appendix M contains a review of trends in salable mineral developments.

Issue 2

How would the alternatives affect acres of land recommended for withdrawal from locatable mineral

entry?

Summary of Analytical Methods

The BLM identified by the alternatives and the Proposed RMP acres of land recommended for 

withdrawal from locatable mineral entry, subject to valid existing rights (see Appendix X). The BLM 

assumed that areas recommended for withdrawal from locatable mineral entry to be withdrawn for the 

purposes of this analysis. The BLM would make recommendations for withdrawals, but adoption of the 

Proposed RMP would not actually withdraw lands from locatable mineral entry because the BLM does 

not have the authority to withdraw lands from locatable mineral entry. Congress can designate 

withdrawals from locatable mineral entry or the BLM can begin a withdrawal process for a decision to be 

signed by the Secretary of Interior. Any such future withdrawals would affect only new claims and would 

not alter or affect valid existing claims.

The BLM ranked each ACEC, RMA, District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics, and eligible Wild and Scenic River (WSR) that would be recommended for withdrawal as 

high, medium, or low, in terms of the their potential development for mineral resources. While not a 

Mineral Potential Report, this ranking is based on geology, mining claim density, historic mines, 

prospects, and occurrences. This ranking can be used to determine the potential impact to mineral 

development for each recommended withdrawal. Withdrawing areas ranked as high would be expected to 

have a greater impact to the possible development of a mineral resource then withdrawing areas ranked as 

low. The BLM also analyzed the potential impacts on mining claim fee revenue.

While the BLM will not complete a formal mineral potential report for locatable minerals for this RMP 

revision, prior to an actual withdrawal, the BLM must prepare a mineral potential report for each 

recommended withdrawal proposal.
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The BLM estimated the historic mineral occurrence and development for each ACEC, RMA, DistrictDesignated Reserve – Lands Managed for their Wilderness Characteristics, and eligible WSRs that the 

BLM would recommend for withdrawal from locatable mineral entry under each action alternative and 

the Proposed RMP. For this evaluation, the BLM relied on the Mineral Resource Map of Oregon (1984) 

for geology, location of mineral deposits, and mining history, and on LR2000 for the number of claims 

per quarter section of closed and active mining claims. The rankings vary from high to low in terms of 

historic mineral occurrence or development.

Under the action alternatives and the Proposed RMP, the BLM would recommend areas such as ACECs, 

RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible 

WSRs for withdrawal from locatable mineral entry because locatable mineral development in such areas 

would conflict with or preclude management of the special values for which the BLM would designate 

such areas. If not withdrawn, locatable mineral development under the Mining Law of 1872 could still 

occur within these areas, which could result in loss of the special values for which the BLM would 

designate these areas through this RMP revision.

High historic mineral occurrence or development areas include—

 Regions with historic gold mining;

 Areas with laterites and beach placers that contain more than 10 active or closed mining claims:

 Areas with favorable geology for mineral production or potential and also containing more than 

10 active or closed mining claims; and

 Areas with more than 30 active or closed mining claims.

Medium historic mineral occurrence or development areas include—

 Areas with favorable geology for mineral production or potential;

 Areas with laterites, beach placers, and no mining claims; and

 Areas with 1–30 active or closed mining claims.

Low historic mineral occurrence or development areas are any areas that do not fall into the high or 

medium categories.

The Planning Criteria, which the BLM incorporates here by reference (USDI BLM 2014, p.104), provides 

more detailed information on analytical assumptions, methods and techniques, and geographic and 

temporal scales.

Background

Locatable minerals include gold, silver, copper, lead, zinc, nickel, and chromite as well as certain 

nonmetallic minerals determined to be uncommon such as fluorspar and certain varieties of limestone. 

The Mining Law of 1872 as amended gives citizens the right to prospect, explore, and develop locatable 

minerals on lands open to mineral entry. BLM regulations in 43 CFR 3000 – Minerals Management: 

General, 3700 – Multiple Use; Mining, and 3800 – Mining Claims under the General Mining Laws, 

establish procedures for locating mining claims and the surface management and occupancy of mining 

claims. Regulations include preventing unnecessary or undue degradation, compliance with Federal and 

state laws, and operation performance standards. Development of locatable minerals on O&C lands and 

Coos Bay Wagon Road lands are covered under specific regulations (43 CFR 3821).

A withdrawal from locatable mineral entry removes lands from the location of new mining claims and 

places certain requirements on existing mining claims for development of the minerals. After lands are 

withdrawn, the BLM will not approve a Plan of Operations or allow Notices to proceed until the BLM has 
497 | P a g e

prepared a mineral examination report to determine mining claim validity. Cost recovery applies to this 

process. The action alternatives and the Proposed RMP would make recommendations for withdrawals 

but would not actually withdraw lands from locatable mineral entry. As explained above in Analytical 

Methods, the BLM does not have the authority to withdraw lands from locatable mineral entry. 

Surface management regulations at 43 CFR 3809.11(c) require a Plan of Operations for any mining 

operations causing surface disturbance greater that casual use in some special areas, including designated 

ACECs, areas designated as part of the National Wilderness Preservation System, areas in the National 

Wild and Scenic Rivers System, and areas designated as closed for public motorized access (as defined in 

43 CFR 8340.0–5). In addition, the regulations at 43 CFR 3809.11(c)(6) require a Plan of Operations for 

any mining operations causing surface disturbance greater than casual use in any lands or waters known 

to contain federally proposed or ESA-listed threatened or endangered species or their proposed or 

designated critical habitat, unless BLM allows for other action under a formal land-use plan or threatened 

or endangered species recovery plan. 

The Proposed RMP, pursuant to 43 CFR 3809.11(c)(6), would create two exceptions to the requirement 

such that a Plan of Operations is required for any mining activities greater than casual use such as Noticelevel operations when the activities are located within lands or waters known to contain federally 

proposed or ESA-listed threatened or endangered species or their proposed or designated critical habitat. 

Under the Proposed RMP, an operator would not be required to submit a Plan of Operations for Noticelevel activities in the following two situations: 

 When pursuant to Section 7 of the ESA, the BLM determines that the notice-level activity will 

have no effect on federally proposed or listed threatened or endangered species or their proposed 

or designated critical habitat 

 When the BLM has completed consultation to the extent required under section 7(a)(2) of the 

ESA and the U.S. Fish and Wildlife Service or National Marine Fisheries Service has concurred 

with the BLM’s finding that the notice-level activity is not likely to adversely affect federally 

proposed or listed threatened or endangered species or their proposed or designated critical 

habitat (Appendix B) 

In contrast, the action alternatives would allow Notice-level mining proposals located in lands or waters 

known to contain federally proposed or ESA-listed threatened or endangered species or their proposed or 

designated critical habitat to remain a Notice if the BLM determines that the proposal would have no 

effect on ESA-listed species or their proposed or designated critical habitat (USDI BLM 2015, p. 923). 

Affected Environment 

The planning area contains over 3,300 occurrences of locatable mineral resources and has a long history 

of mineral development (DOGAMI MILO). BLM mining claim records show that approximately 39,500 

claims have been located on public lands in the planning area since the BLM recording requirements 

began with the passage of the FLPMA. The 1,292 mining claims in the decision area indicate ongoing 

interest in locatable minerals. 

Table 3-98 lists the number of mining claims, Notices, and pending or authorized Plans of Operation in 

the decision area by district. Figure 3-114 illustrates the general locations of mining claims in the 

decision area. 
498 | Page

Table 3-98. Mining claims, Notices, and pending or authorized Plans of Operation in the decision area as 

of 2015 

District/

Field Office

Mining

Claims Notices Plans of OperationPending or Authorized

Coos Bay 42 1 -

Eugene 47 1 -

Klamath Falls 1 - -

Medford 1,039 21 8

Roseburg 149 - 1

Salem 14 1 -

Totals 1,292 24 9

Figure 3-114. Mining claims in the decision area in 2015 
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Table 3-99 shows by district the 98,400 acres currently withdrawn from locatable mineral entry. These 

lands would continue to be withdrawn acres under the alternatives and the Proposed RMP. 

Table 3-99. Acres of lands previously withdrawn from locatable mineral entry in the decision area 

District/

Field Office

Previously Withdrawn From

Locatable Minerals

(Acres)*

Coos Bay 12,500

Eugene 15,700

Klamath Falls 5,400

Medford 37,600

Roseburg 5,100

Salem 22,100

Total 98,400

* Data from the 2008 Final EIS (USDI BLM 2008) 

See Appendix M for a description of the trends in locatable mineral developments and regulations. 

Environmental Consequences 

Figure 3-115 and Table 3-100 illustrate previously withdrawn acres in addition to the acres that the BLM 

would recommend for withdrawal from locatable mineral entry by alternative and the Proposed RMP for 

ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and 

eligible WSRs. 
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Figure 3-115. Acres that the BLM would recommend for withdrawal from locatable mineral entry and 

previously withdrawn acres in the decision area

* ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible Wild and 

Scenic Rivers.

Table 3-100. Acres the BLM would recommend for withdrawal from locatable mineral entry and 

previously withdrawn acres in the decision area

Land Category No Action Alt. A Alt. B Alt. C Alt. D PRMP

Special Areas* (Acres) 170,622 168,072 171,584 208,478 208,912

Special Areas* (Percent) 6% 6% 6% 8% 8%

Previously Withdrawn (Acres) 98,400

Previously Withdrawn (Percent) 4%

Totals (Acres) 98,400 269,022 266,472 269,984 306,878 307,312

Totals (Percent) 4% 10% 10% 10% 12% 12%

* ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible Wild and 

Scenic Rivers

About 4 percent of the 2.5 million acre decision area is currently withdrawn from locatable mineral entry 

(Table 3-100). These acres would remain withdrawn under the alternatives and the Proposed RMP. Under 

the action alternatives and the Proposed RMP, the BLM would recommend increasing the lands 

withdrawn from locatable mineral entry; this increase would range from 168,072 acres under Alternative 

B to 208,912 acres in the Proposed RMP. Alternative D and the Proposed RMP would more than triple 

the acres of lands withdrawn by recommending the most acres for withdrawal. Given the variances in 

acreage data because of geographic overlap, there is no appreciable deviation in acreage recommended 

for withdrawal under Alternative D and the Proposed RMP (Table 3-100).

Recommending the withdrawal of an additional 6–8 percent of the decision area would affect the 

development of locatable mineral resources. To understand the effects of the recommended withdrawals, 

98,400 98,400 98,400 98,400 98,400 98,400

0

170,622 168,072 171,584

208,478 208,912

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

No Action Alt A Alt B Alt C Alt D PRMP

Recommended for Withdrawl from 

Locatable Mineral Entry (Acres)

Existing Withdrawn Special Areas*
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the BLM ranked the estimated historic mineral occurrence or development for the acres of land for each 

ACEC, RMA, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and 

eligible WSRs that the BLM would recommend for withdrawal under each action alternative and the 

Proposed RMP. Figure 3-116 shows this ranking by alternative and the Proposed RMP with the 

proportion of acres that fall into each mineral ranking category (High, Medium, and Low). Existing 

withdrawals are not analyzed or ranked, but the acres are included in Figure 3-116.

Figure 3-116. Acres that the BLM would recommend for withdrawal, with mineral ranking of estimated 

prospective mineral occurrence or development for each land category (includes previously withdrawn 

acres)

Figure 3-116 shows that the alternatives vary in the acreage of lands recommended for withdrawal as 

High for prospective mineral occurrence or development. Recommendations for withdrawal of lands 

ranked Medium or Low would have substantially less risk of curbing the development of known and

undiscovered mineral resources. Alternative A would recommend for withdrawal of the largest acreage of 

lands that ranked High (110,431 acres) and Alternative D would recommend for withdrawal of the least 

acreage of lands that ranked High (79,219 acres). The Proposed RMP would recommend for withdrawal 

103,174 acres of lands ranked High, which is approximately half of the total acres recommended for 

withdrawal. Removal of these High-ranked lands from locatable mineral exploration and development 

would influence the development of mineral resources. Although Alternative D and the Proposed RMP 

would recommend the largest acres for withdrawal, Alternative A would have the largest impact on the 

development of mineral resources, as it would recommend for withdrawal of the largest acreage of Highranked lands.

98,400 98,400 98,400 98,400 98,400 98,400

41,072

60,117 62,096 75,041 67,931

19,120

23,317 25,558

54,217

37,809

110,431

84,638 83,930

79,219

103,174

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

No Action Alt A Alt B Alt C Alt D PRMP

Recommended for Withdrawal Based on Prospective 

Mineral Occurrence or Developement Category (Acres)

Existing Withdrawn Low Medium High
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Appendix M contains the estimated ranking of each ACEC, RMA, District-Designated Reserve – Lands 

Managed for their Wilderness Characteristics, and eligible WSR recommended for withdrawal from 

locatable mineral entry.

An additional effect that would occur in association with withdrawing additional lands from locatable 

mineral entry is a potential reduction of revenue collected from public lands through mining claim fees 

paid to the government. To illustrate how this type of withdrawal would affect fees, LR2000 records list

about 3,500 mining claims located in the areas that the BLM would recommend for withdrawal from 

locatable mineral entry under the action alternatives and the Proposed RMP. Using the current fee 

structure for mining claim location, this amount represents approximately $742,000 in revenue paid to the 

government. In addition to these filing fees, there are mining claim maintenance fees (currently $140 per 

year) that in most cases must be paid annually; however these fees are not included in this estimate. While 

withdrawals would not extinguish existing claims, the public cannot file new claims in lands that are 

withdrawn from locatable mineral entry, which results in no new fees collected. However, holders of 

existing claims would still pay maintenance fees as applicable.

Issues Considered but not Analyzed in Detail

How would the alternatives affect the acres of land with fluid leasable mineral restrictions of no surface 

occupancy, conditional surface use, and timing limitations?

Site-specific stipulations such as no surface occupancy, conditional surface uses, and timing restrictions 

would be imposed on each lease as necessary to protect other resource values under the alternatives and 

the Proposed RMP. The BLM is identifying such stipulations for certain areas (Appendix M), but as

access to fluid resources is not closed, and there are no interests in development, there would be no 

foreseeable effects of the alternatives and the Proposed RMP regarding mineral leasing of oil, gas, or 

Coalbed Natural Gas resources. The stipulation of no surface occupancy may affect geothermal resources

the most. The Sustainable Energy section in this chapter contains more information.

The action alternatives and the Proposed RMP would impose fluid mineral stipulations on each ACEC, 

RMA, District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible 

WSR. Table 3-101 lists the acres for which the BLM would propose stipulations. The No Action 

alternative contains the most acreage with stipulations, and Alternative A would contain the least. The 

Proposed RMP would propose stipulations on 246,747 acres. The differences in the action alternatives

and the Proposed RMP are due to differing arrangements in each alternative and the Proposed RMP 

across ACECs, RMAs, District-Designated Reserve – Lands Managed for their Wilderness 

Characteristics, and eligible WSRs. It is important to note that while the No Action alternative acreage 

includes only acres to which the BLM has applied no surface occupancy stipulations, the action 

alternatives and the Proposed RMP acreages include all proposed stipulations to include no surface 

occupancy or conditional surface uses based on resource protection needs (Appendix M).

Table 3-101. Acres that would have leasable stipulations in the decision area for ACECs, RMAs, 

District-Designated Reserve – Lands Managed for their Wilderness Characteristics, and eligible WSRs

No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Leasable stipulations 692,100* 190,389 211,638 318,915 498,525 246,747

* The No Action alternative acres include only those acres with no surface occupancy
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Acreage not included in Table 3-101 are site-specific stipulations as needed to protect ESA-listed 

threatened and endangered species and their critical habitats.

The BLM did not complete reasonably foreseeable development scenarios and Mineral Potential Reports 

for leasable minerals for this Proposed EIS/Final EIS. All estimates are based on a broad-scaled ‘trends’

review, which presents professional opinion rather than a methodological approach.

Appendix M includes a review in trends in leasable mineral developments and development guidance.

References

Ferns, M. L., and D.F. Huber. 1984. Mineral Resource Map of Oregon. Oregon Department of Geology and Mineral Industries

and U.S. Geological Survey.

Oregon Department of Geology and Mineral Industries (DOGAMI). 1982. Geothermal Resources of Oregon, 1 sheet, scale 

1:500,000.

---. 2010. Mineral Information Layer for Oregon (MILO, release 2), geospatial database.

---. 2012. Geothermal Information Layer for Oregon–Release 2 (GTILO-2). GIS and map plate. 

http://www.oregongeology.org/sub/gtilo/index.htm, http://www.oregongeology.org/sub/gtilo/data/supplemental/GTILO2_Geothermal_Information_Layer_for_Oregon_onscreen96dpi.pdf.

---. 2014. Oil & Gas Well Log Viewer. Mineral Land Regulation and Reclamation (MLRR). 

http://www.oregongeology.org/mlrr/oilgas-logs.htm#./oilgas-logs.htm?&_suid=140173381705803887908546260215. Last 

updated 12/05/2014.

Singer, D. A., N. J. Page, J. G. Smith, R. J. Blakely, and M G. Johnson. 1983 . Mineral resource assessment maps of the Medford 

1° by 2° Quadrangle, Oregon and California. Miscellaneous Field Studies Map MF-1383-C, 2 sheets, scale 1:250,000. USDI 

U.S. Geological Survey. https://pubs.er.usgs.gov/publication/mf1383C.

Smith, R. M., and J.A. Peterson. 1985. Mineral deposits and probability of exploration, Medford 1° by 2° Quadrangle, Oregon 

and California. Miscellaneous Field Studies Map MF-1383-F, 4 sheets, scale 1:250,000. USDI U.S. Geological Survey. 

https://pubs.er.usgs.gov/publication/mf1383F.

U.S. Department of Energy (DOE). 2003. Oregon Geothermal Resources, Publication No. INEEL/MIS-2002-1621 Rev. 1

November 2003, 1 sheet, scale 1:500,000. Office of Energy Efficiency and Renewable Energy, Geothermal Technologies 

Program. http://prod-http-80-800498448.us-east-1.elb.amazonaws.com/w/images/3/34/INL-geothermal-or.pdf.

---. 2010. Oregon Wind Resource Maps. National Renewable Energy Laboratory. 05-OCT-2010 1.1.1. 

http://apps2.eere.energy.gov/wind/windexchange/wind_resource_maps.asp?stateab=or.

USDI BLM. [No Date]. Well Information System. https://www.blm.gov/wispermits/wis/SP.

---. 1985. BLM Manual 3031 – Energy and Mineral Resource Management. 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_manual.Par.36483.File.dat/30

31%20-%20ENERGY%20AND%20MINERAL%20RESOURCE%20ASSESSMENT.pdf.

---. 2008. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western Oregon 

Bureau of Land Management Districts. Portland, OR. Vol. I–IV. http://www.blm.gov/or/plans/wopr/final_eis/index.php.

---. 2008. Record of Decision and Resource Management Plan Amendments for Geothermal Leasing in the Western United 

States. FES-08-44.

USDI BLM and USDA FS. 2008. Geothermal Leasing in the Western United States.

http://www.blm.gov/style/medialib/blm/wo/MINERALS__REALTY__AND_RESOURCE_PROTECTION_/energy/geothe

rmal_eis/final_programmatic.Par.95063.File.dat/Geothermal_PEIS_final.pdf.

USDI U.S. Geological Survey (USGS). 2009. USGS Fact Sheet 2009-3060. Assessment of undiscovered hydrocarbon resources 

of the western Oregon and Washington province. http://pubs.usgs.gov/fs/2009/3060/pdf/FS09-3060.pdf.
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National Trails System

Key Points

 Alternative D would provide the largest National Trail Management Corridor and would protect 

the largest number of acres within the viewshed. However, these acres would only account for 9 

percent of all viewable acres.

 Under the Proposed RMP, the BLM would administer 23 percent of the visible acres of BLMadministered lands within the viewshed as the Pacific Crest Trail’s National Trail Management 

Corridor.

Summary of Notable Changes from the Draft RMP/EIS

 The BLM conducted an updated viewshed analysis that captures the entire section of the Pacific 

Crest Trail within the planning area. This updated analysis includes acres of BLM-administered 

lands that are visible anywhere along the Pacific Crest National Scenic Trail within the planning 

area regardless of ownership.

Issue 1

How would the alternatives affect the BLM’s ability to protect National Trails?

Summary of Analytical Methods

The BLM considered how the designation of various widths of National Trail Management Corridors by 

alternative and the Proposed RMP would affect the values and uses associated with the trails. The BLM 

conducted a trail viewshed analysis for the portion of the Pacific Crest Trail that passes through BLMadministered lands in the planning area to determine the percent of BLM-administered lands within the 

trail’s viewshed.

For the purposes of this analysis, the BLM assumed that the management decisions for National Trail 

Management Corridors would adequately protect the values and uses associated with the National Trails. 

The BLM bases this assumption on the management direction applied to these corridors under all 

alternatives and the Proposed RMP. Within the corridors, the BLM will—

 Manage the trail consistent with the intended uses and designated classifications under the 

National Trails System Act of 1968;

 Designate a Special Recreation Management Area;

 Authorize special recreation permits if they do not adversely affect Pacific Crest Trail values and 

Resources;

 Manage for Visual Resource Management Class II;

 Designate as closed to public motorized access;

 Close to recreational target shooting;

 Conduct timber harvest to protect or maintain recreation setting characteristics or to achieve 

recreation objectives;

 Apply a controlled surface use stipulation on surface occupancy and surface-disturbing activities;

 Recommend for withdrawal from locatable mineral entry;

 Close to salable mineral material disposal; and
506 | P a g e

 Apply stipulations for leasable minerals, including no surface occupancy, controlled surface use, 

and timing limitations (Appendix M).

Background

Congress designated three classifications of trails for public use under separate criteria established in the 

National Trails System Act of 1968, Sec. 3(a). The following definitions provide an overview of the 

scenic and historic classification types, the allocation through which agencies manage the trails, and the 

specific trails that pass through the BLM-administered lands within the planning area. See the discussion 

for Alternatives Considered but Not Analyzed in Detail at the end of this section for discussion of 

recreation classification trails.

A National Trail Management Corridor is a designation based on Section 7(a) of the National Trails 

System Act ‘rights-of-way.’ A National Trail Management Corridor includes public land area of 

sufficient width to encompass National Trail System resources, qualities, values, and associated settings. 

For the purposes of this planning effort, a National Trail Management Corridor includes all BLMadministered lands containing resources, values, and associated settings that support purposes of a given 

National Trail.

A BLM-designated National Trail Corridor includes other Federal lands, State trust lands, private land, or 

other interests in lands, including split estates, which contain National Trail resources, qualities, values, 

and associate settings. Although these lands are included within the management corridor, they are not 

subject to BLM management. Interested landowners may voluntarily elect to participate in National Trail 

management on private or State lands through a cooperative agreement.

National Recreation Trail

The Secretary of the Interior can designate National Recreation Trails within parks, forests, and recreation 

areas; or where other lands administered by the Department of the Interior are involved. These would be 

subject to the consent of the appropriate administering agency having jurisdiction over the lands involved.

There are four designated National Recreation Trails within the planning area that overlap with BLMadministered lands within the decision area. These four trails are discussed under “Issued Considered but 

Not Analyzed in Detail” at the end of this section.

National Scenic Trail

Only Congress can establish National Scenic Trails, which are extended trails intended to provide for 

maximum outdoor recreation potential and for the conservation and enjoyment of the nationally 

significant scenic, historical, natural, or cultural qualities of the areas through which the trails pass. A 

portion the Pacific Crest National Scenic Trail is within the decision area.

Pacific Crest National Scenic Trail

The Pacific Crest National Scenic Trail (Pacific Crest Trail) is a long-distance hiking and equestrian trail 

closely aligned with the highest portion of the Sierra Nevada and Cascade mountain ranges. The Pacific 

Crest Trail was designated a National Scenic Trail in 1968. The trail’s southern terminus is on the U.S. 

border with Mexico and its northern terminus is on the U.S. border with Canada; the trail travels through 

the states of California, Oregon, and Washington. The Pacific Crest Trail is 2,663 miles long and ranges 

in elevation from just above sea level at the Oregon-Washington border to 13,153 feet in the Sierra 

Nevada mountain range.
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The Pacific Crest Trail enters BLM-administered lands in the decision area from California along the 

crest of the Siskiyou Mountains east of Mt. Ashland, proceeds east towards Soda Mountain, and then 

continues northeasterly along the western Cascades to the Rogue River-Siskiyou National Forest 

boundary. Hikers can access the Pacific Crest Trail by numerous Federal, State, and county roads. 

Although the trail is accessible from roads, the trail itself is closed to motorized and mechanized use.

Table 3-102 shows the Pacific Crest Trail mileage by ownership within the decision area.

Table 3-102. Pacific Crest Trail mileage by ownership within the decision area

Landowner Trail Length

(Approximate Mileage)

BLM 17.0*

Private 10.7

State of Oregon 0.9

U.S. Forest Service 16.6

Totals 45.2

* The BLM manages approximately 14 additional miles of the Pacific Crest Trail outside of the planning area in the CascadeSiskiyou National Monument.

The main use of the BLM-administered segment of the Pacific Crest Trail is for day hikes, primarily by 

residents of the Rogue Valley. The main recreational activity within the Pacific Crest Trail on BLMadministered lands is hiking, followed by equestrian use. In addition to these activities, sightseeing, 

wildlife observation, photography, camping, and hunting occur. Cross-country skiing occurs along the 

trail in the winter. The BLM estimates that day use along the BLM-administered segment of the Pacific 

Crest Trail is approximately 25,000 visitors annually.

The purpose of the Pacific Crest Trail is to provide a high quality hiking and horseback-riding experience, 

highlighting the scenic, natural, historic, and cultural resources along the high ridges of the Pacific 

mountains. The Pacific Crest Trail was designed and is managed to provide the most primitive 

recreational experience possible, as identified through the BLM’s Recreation Opportunity Spectrum 

(USDI BLM 2011). A National Trail Management Corridor permanently protects the Pacific Crest Trail

including side and connecting trails and facilities such as campsites, water sources, and viewpoints. 

Public lands within the trail corridor, including lands acquired and managed for the Pacific Crest Trail, 

are managed to maximize a natural appearing landscape where human development does not dominate the 

viewer’s experience, and meet a minimum visual quality retention objective. The Pacific Crest Trail

experience is managed cooperatively and seamlessly across unit and agency boundaries and with 

substantial involvement of citizen stewards.

National Historic Trail

Only Congress can establish National Historic Trails, which are extended trails that follow as closely as 

practicable to the original routes of travel of national historic significance. Their purpose is to protect 

historic routes and their historic remnants for public use and enjoyment. Portions of the California 

National Historic Trail-Applegate Trail route and the Oregon National Historic Trail route are within the 

decision area. The Oregon National Historic Trail is discussed under “Issued Considered but Not 

Analyzed in Detail” at the end of this section.
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California National Historic Trail-Applegate Trail Route 

The National Park Service is preparing a feasibility study to evaluate 41 routes as possible additions to the 

California National Historic Trail. The Applegate Trail route is one route under evaluation. Congress 

authorized this study under the Omnibus Public Land Management Act of 2009 (Pub. L. 111-11). 

Approximately 10.9 miles of the Applegate Trail route are located on BLM-administered lands within the 

planning area. Table 3-103 shows a mileage breakdown by ownership, within the planning area 

boundaries. 

Table 3-103. California National Scenic Trail-Applegate Trail route mileage breakdown by ownership 

within the planning area 

Landowner Trail Length

(Approximate Mileage)

BLM 10.9

Private 410.6

State of Oregon 5.0

Totals 426.5

The California National Historic Trail follows the route taken by farmers, settlers, gold miners, and others 

who forged their way from Missouri to the Pacific Coast during the California gold rush. The California 

National Historic Trail is approximately 2,400 miles in length spanning across the western half of North 

America. The first half of the California National Historic Trail followed the same corridor of networked 

river valley trails as the Oregon Trail and the Mormon Trail. The California National Historic Trail splits 

into the Applegate Trail route just north of the Oregon-California border. 

The purposes of the California National Historic Trail are to enable all people to envision and experience 

the heritage and effects of the western overland migration and to encourage preservation of its history and 

physical remnants. The California National Historic Trail is significant for several reasons. First, it was 

one of the major highways of the 19th century and provided a 2,400-mile path for emigrants to the West. 

The arrival of these emigrants dramatically changed the peoples, cultures, and landscapes of the 

northwest. The California National Historic Trail’s route originated through earlier use by Native 

American and western explorers and travelers. 

Affected Environment 

Pacific Crest National Scenic Trail 

The BLM’s Medford District currently manages as a Special Recreation Management Area (SRMA) the 

approximately 16 miles of the Pacific Crest Trail (Figure 3-117) that passes through the planning area. 

The current SRMA plan established a 100-foot wide (50 feet off centerline) National Trail Management 

Corridor for the trail. The BLM administers approximately 488 acres within this corridor. The Klamath 

Falls Field Office manages an additional mile of the Pacific Crest Trail. The BLM has not established a 

National Trail Management Corridor for the portion of the Pacific Crest Trail that passes through the 

Klamath Falls Field Office. 
509 | Page

Figure 3-117. Pacific Crest National Scenic Trail route on BLM-administered lands within the planning 

area 

Pacific Crest National Scenic Trail Viewshed Analysis 

A viewshed is the area of a landscape that can be directly seen under favorable atmospheric conditions 

from a viewpoint or along a corridor. Within the planning area, the Pacific Crest Trail viewshed area is 

defined as the area of the landscape within 5 miles on either side of the Pacific Crest Trail route. This 

definition is based on the assumption that the average traveler along the Pacific Crest Trail has the ability 

to see 5 miles from any point along the trail. This 5-mile viewshed is a fixed-distance measurement and 

includes areas outside of the planning area and areas that are not visible from the trail, such as back-face 

slopes or terrain blocked by trees. Thus, in addition to determining the acres of BLM-administered lands 

within the 5-mile viewshed, the BLM also determined the acres of BLM-administered lands actually 

visible from the trail. The BLM conducted the viewshed analysis based on available digital elevation data. 

The results of this analysis are displayed in Figure 3-118 and Table 3-104. 

509 | Page

Figure 3-117. Pacific Crest National Scenic Trail route on BLM-administered lands within the planning 

area 

Pacific Crest National Scenic Trail Viewshed Analysis 

A viewshed is the area of a landscape that can be directly seen under favorable atmospheric conditions 

from a viewpoint or along a corridor. Within the planning area, the Pacific Crest Trail viewshed area is 

defined as the area of the landscape within 5 miles on either side of the Pacific Crest Trail route. This 

definition is based on the assumption that the average traveler along the Pacific Crest Trail has the ability 

to see 5 miles from any point along the trail. This 5-mile viewshed is a fixed-distance measurement and 

includes areas outside of the planning area and areas that are not visible from the trail, such as back-face 

slopes or terrain blocked by trees. Thus, in addition to determining the acres of BLM-administered lands 

within the 5-mile viewshed, the BLM also determined the acres of BLM-administered lands actually 

visible from the trail. The BLM conducted the viewshed analysis based on available digital elevation data. 

The results of this analysis are displayed in Figure 3-118 and Table 3-104. 
510 | Page

Figure 3-118. BLM-administered lands visible within the 5-mile Pacific Crest Trail viewshed of trail 

portions within the planning area 

Table 3-104. Pacific Crest Trail viewshed results for BLM-administered lands within the 5-mile 

viewshed distance of trail portions 

Description All Lands

(Percent)

BLM-administered lands within the Pacific Crest Trail Viewshed 30%

BLM-administered lands within the Pacific Crest Trail Viewshed that are visible

from anywhere along the Pacific Crest Trail 60%

BLM-administered lands within the Pacific Crest Trail Viewshed that are visible 

and within the planning area (does not include lands within the Cascade-Siskiyou 

National Monument).

64% 510 | Page

Figure 3-118. BLM-administered lands visible within the 5-mile Pacific Crest Trail viewshed of trail 

portions within the planning area 

Table 3-104. Pacific Crest Trail viewshed results for BLM-administered lands within the 5-mile 

viewshed distance of trail portions 

Description All Lands

(Percent)

BLM-administered lands within the Pacific Crest Trail Viewshed 30%

BLM-administered lands within the Pacific Crest 

from anywhere along the Pacific Crest Trail

Trail Viewshed that are visible 60% 

BLM-administered lands within the Pacific Crest Trail Viewshed that are visible 

and within the planning area (does not include lands within the Cascade-Siskiyou 64% 

National Monument).
511 | Page

California National Historic Trail-Applegate Trail Route 

The BLM does not currently have an established National Trail Management Corridor for the portion of 

the Applegate Trail route that passes though BLM-administered lands within the planning area. Figure 3-

119 illustrates the portions of the Applegate Trail route under evaluation as an addition to the California 

National Historic Trail on BLM-administered lands within the planning area. 

511 | Page

California National Historic Trail-Applegate Trail Route 

The BLM does not currently have an established National Trail Management Corridor for the portion of 

the Applegate Trail route that passes though BLM-administered lands within the planning area. Figure 3-

119 illustrates the portions of the Applegate Trail route under evaluation as an addition to the California 

National Historic Trail on BLM-administered lands within the planning area. 

Figure 3-119. Applegate Trail route on BLM-administered lands in the planning area 

Environmental Consequences 

The variation in effects between alternatives and the PRMP is driven by the application of differing 

widths of the National Trail Management Corridor. As described above, the management within the 

corridor would be permanent and protective across alternatives and the Proposed RMP. 

Figure 3-119. Applegate Trail route on BLM-administered lands in the planning area 

Environmental Consequences 

The variation in effects between alternatives and the PRMP is driven by the application of differing 

widths of the National Trail Management Corridor. As described above, the management within the 

corridor would be permanent and protective across alternatives and the Proposed RMP. 
512 | P a g e

California National Historic Trail-Applegate Trail Route 

The No Action alternative does not provide protections for the Applegate Trail route portion of the 

California National Historic Trail because no National Trail Management Corridor currently exists. The 

No Action alternative would result in impacts to the Applegate Trail route of the California National 

Historic Trail’s resources, values, recreation setting, and primary uses because protective management 

direction does not exist for BLM-administered lands within the planning area. 

Under all action alternatives and the Proposed RMP, the BLM would establish a 100-foot wide National 

Trail Management Corridor (50-feet off centerline) along all portions of the Applegate Trail route of the 

California National Historic Trail study route that cross BLM-administered lands within the planning 

area. The BLM established this corridor based on the trail’s purposes, significance, and values warranting 

protection as identified through inventory assessments conducted by the National Park Service as part of 

the Comprehensive Management Plan (USDI NPS 1999) analysis, local knowledge of the route’s terrain 

and vegetation within the planning area, and based on professional judgment. Application of this 100-foot 

buffer under all action alternatives and the Proposed RMP would result in adequate protection of National 

Historic Trail’s resources, values, setting characteristics, and primary uses for which the Applegate Trail 

route of the California National Historic Trail is currently being studied. 

Pacific Crest National Scenic Trail 

The BLM would establish a National Trail Management Corridor on the 17 miles of the Pacific Crest 

Trail that crosses BLM-administered lands within the planning area. This corridor width would vary 

across the alternatives and the Proposed RMP. In this analysis, the BLM considers the effects of these 

widths on Pacific Crest Trail resources, values, recreation settings, and primary uses. 

Despite the differing National Trail Corridor widths, all alternatives and the Proposed RMP would 

provide for outdoor recreation potential and for the conservation and enjoyment of the nationally 

significant scenic, historical, natural, or cultural qualities of the areas through which the trail passes. The 

smallest width, under the No Action alternative, would still meet the minimum requirement for protection 

of these resources. The management of the Trail Management Corridor would provide beneficial 

recreational outcomes for users and protect the trail setting characteristics. 

The variance of the National Trail Corridor widths under the alternatives and the Proposed RMP would 

influence the acres managed within the Pacific Crest Trail viewshed under differing Visual Resource 

Management Classes. Table 3-105 shows the BLM acres, percentage, and percentage of visible acres 

present in the Pacific Crest Trail corridor by alternative and the Proposed RMP. This table also shows the 

total acres of BLM-administered lands visible from the BLM portion of the Pacific Crest Trail. 
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Table 3-105. Acres of BLM-administered lands in the planning area within Pacific Crest Trail National 

Trail Management Corridor 

Areas No Action Alt. A Alt. B Alt. C Alt. D PRMP

Trail corridor width 100 feet 500 feet 0.25 mile 1 mile 2 miles 1 mile

BLM-administered lands within 

the corridor (Acres) 210 987 2,338 6,891 10,928 6,891

BLM-administered lands within 

the corridor (Percent of all lands) 30% 29% 27% 22% 19% 22%

Percent of BLM-administered 

lands within the 5-mile viewshed 

and within the corridor (Percent

of all lands)

< 1% 2.5% 6% 17.8% 28.2% 17.8%

Percent of BLM-administered 

lands visible within 5 mile

viewshed and within the corridor 

(Percent of all visible lands)

< 1% 3.7% 8.5% 23.2% 34.4% 23.2%

Under the most protective management (Alternative D), the BLM would administer 34 percent of the total 

visible acres of BLM-administered lands within the viewshed as the Pacific Crest Trail’s National Trail 

Management Corridor. The BLM would administer less than 1 percent of these acres for these purposes 

under the least protective management (No Action alternative). The Proposed RMP would administer 23 

percent of the visible acres of BLM-administered lands within the viewshed as the Pacific Crest Trail’s 

National Trail Management Corridor. Within the 1-mile corridor under Proposed RMP, 77 percent of 

lands within the corridor on either side of the Pacific Crest Trail are not BLM-administered lands and 

would be subject to landscape changes outside of the BLM’s control.

Under all alternatives and the Proposed RMP, the BLM would manage BLM-administered lands outside 

of the relevant National Trail Management Corridor width, but visible within the 5-mile viewshed, under 

the Visual Resource Management class assigned to those acres. Visual Resource Management Class IV 

and, to some extent, Class III lands exist within the viewshed, therefore, the BLM could implement 

management activities that result in visible changes to the landscape. 

No Action Alternative 

Under the No Action alternative, the BLM would continue to provide a 100-foot National Trail 

Management Corridor off centerline (50 feet on each side) on the Pacific Crest Trail. This would result in 

the protection of 210 acres of BLM-administered lands along the 17-mile segment of the Pacific Crest 

Trail within the planning area. Compared to the acres of visible BLM-administered lands from the Pacific 

Crest Trail (24,765 acres), the No Action alternative would preserve less than 1 percent of the visible 

BLM-administered lands within the planning area from the Pacific Crest Trail for the enjoyment of the 

nationally significant, scenic, historic, natural, or cultural qualities of the areas through which the trail 

passes. The No Action alternative provides the least amount of protection to the Pacific Crest Trail’s 

resources when compared with all alternatives and the Proposed RMP. Visible changes to the natural 

landscape within the majority of the viewshed of the Pacific Crest Trail would be possible based on 

ownerships and Visual Resource Management classes, including more than 99 percent of visible BLMmanaged lands. 
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Alternative A

Under Alternative A, the BLM would establish a 500-foot National Trail Management Corridor off the 

centerline (250 feet on each side) on the Pacific Crest Trail. This would result in the protection of 987 

acres of BLM-administered lands along the 17-mile segment of the Pacific Crest Trail within the planning 

area. Alternative A would protect 4 percent of the 24,765 acres of BLM-administered lands within the 

planning area that are visible from the Pacific Crest Trail using the protective management direction 

described in the Analytical Methods section above.

Alternative A provides greater protection to the Pacific Crest Trail’s resources when compared with the 

No Action alternative and less protection when compared to the remaining action alternatives and the 

Proposed RMP. Visible changes to the natural landscape within the majority of the viewshed of the 

Pacific Crest Trail would be possible based on ownerships and Visual Resource Management classes, 

including approximately 96 percent of visible BLM-managed lands.

Alternative B

In Alternative B, the BLM would establish a 0.25-mile National Trail Management Corridor off the 

centerline on the Pacific Crest Trail (660 feet on each side). This would result in the protection of 2,338 

acres of BLM-administered lands along the 17-mile segment of the Pacific Crest Trail within the planning 

area. Alternative B would protect 9 percent of the 24,765 acres of BLM-administered lands within the 

planning area that are visible from the Pacific Crest Trail using the protective management direction 

described in the Analytical Methods section above.

Alternative B provides greater protection to the Pacific Crest Trail’s resources than the No Action 

alternative and Alternative A, and less protection than Alternatives C and D, and the Proposed RMP.

Visible changes to the natural landscape within the majority of the viewshed of the Pacific Crest Trail 

would be possible based on ownerships and Visual Resource Management classes, including 

approximately 91 percent of visible BLM-managed lands.

Alternative C and the Proposed RMP

In Alternative C and the Proposed RMP, the BLM would establish a 1-mile National Trail Management 

Corridor off the centerline (1/2 mile on each side) on the Pacific Crest Trail. This would result in the 

protection of 6,891 acres of BLM-administered lands along the 17-mile segment of the Pacific Crest Trail

within the planning area. Alternative C and the Proposed RMP would protect 23 percent of the 24,765 

acres of BLM-administered lands within the planning area that are visible from the Pacific Crest Trail

using the protective management direction described in the Analytical Methods section above.

Alternative C and the Proposed RMP provides greater protection to the Pacific Crest Trail’s resources 

than the No Action alternative and Alternatives A and B, and less protection than Alternative D. Visible 

changes to the natural landscape within the majority of the viewshed of the Pacific Crest Trail would be 

possible based on ownerships and Visual Resource Management classes, including approximately 77 

percent of visible BLM-managed lands.

Users of the Pacific Crest Trail would be able to see variation in the landscape, including the forested 

landscapes of both BLM-administered lands beyond 1-mile and privately owned forested lands within all 

distances, along the trail route. Within the 1-mile National Trail Management Corridor, the BLM would 

protect BLM-administered lands within the corridor from visible change through land management 

actions. However, due to the checkerboard nature of the BLM-administered lands within the planning 

area, users on the trail would still experience changes within the 1-mile corridor on non-BLMadministered lands not managed for the Pacific Crest Trail’s scenic values. Additionally, the visibility of
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changes to the landscape, both within the National Trail Management Corridor and in the visible area 

outside the corridor, would not be visible from all sections of the trail, as many portions traverse through 

densely forested stands, which prevent opportunities for long-distance views and scenic vistas. Users of 

the Pacific Crest Trail typically seek opportunities for the scenic values offered by both forested stands 

and opportunities for scenic vistas over valley floors. Because of the intermixed ownership, the 

designation of a 1-mile National Trail Management Corridor would continue to provide both these 

opportunities along the trail route within the planning area.

Alternative D

In Alternative D, the BLM would establish a 2-mile National Trail Management Corridor off the 

centerline (1 mile on each side) on the Pacific Crest Trail. This would result in the protection of 10,928 

acres of BLM-administered lands along the 17-mile segment of the Pacific Crest Trail within the planning 

area. Alternative D would protect 34 percent of the 24,765 acres of BLM-administered lands within the 

planning area that are visible from the Pacific Crest Trail using the protective management direction 

described in the Analytical Methods section above.

Alternative D provides the largest level of protection to the Pacific Crest Trail’s resources compared to 

the other alternatives and the Proposed RMP. Alternative D provides protection on five times the acres as 

the No Action alternative. Visible changes to the natural landscape within the majority of the viewshed of 

the Pacific Crest Trail would be possible based on ownerships and Visual Resource Management classes, 

including approximately 66 percent of visible BLM-managed lands.

Issues Considered but Not Analyzed in Detail

How would the alternatives affect the management of designated National Recreation Trails within the 

decision area?

The Secretary of the Interior can designate National Recreation Trails within parks, forests, and recreation 

areas; or where other lands administered by the Department of the Interior are involved. The National 

Trails System Act of 1968 authorizes the National Recreation Trail designations, which are given to 

existing trails that have been nominated and meet the requirements for connecting people to local 

resources and improving their quality of life. To be designated, a trail must be open to public use and be 

designed, constructed, and maintained according to best management practices, in keeping with the use 

anticipated. Designation must be supported by the appropriate administering agency or by the landowner 

having jurisdiction over the lands involved. The Secretary of Interior or the Secretary of Agriculture may 

designate National Recreation Trails to recognize exemplary trails of local and regional significance in 

response to an application from the trail’s managing agency or organization.

Unlike National Historic Trails or National Scenic Trails, National Recreation Trails are managed solely 

for the recreational use of the designated trail. No additional management beyond the trail management 

(i.e., for scenic or historical values) are needed. There are four designated National Recreation Trails 

within the decision area (Table 3-106).
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Table 3-106. National Recreation Trails within the planning area

Trail Name District Year Designated Total Trail Length

(Miles)

BLM Trail Ownership

(Miles)

North Umpqua Medford 1992 15.7 8.6

Old Growth Ridge Eugene 1994 1.5 1.5

Row River Eugene 2005 15.5 15.5

Rogue River Medford 1981 40.0 21.5

Effects to these trails would occur as analyzed in detail for Recreation Management Areas in the 

Recreation and Visitor Services section of this chapter. In summary, each of these trails would receive 

management of the recreational values consistent with the designed uses through designation as 

Recreation Management Areas under all alternatives and the Proposed RMP, except the No Action 

alternative and Alternative A. Under the No Action alternative, these trails would continue to receive 

management consistent with the BLM’s 1981 recreation management policy, which could allow other 

land management actions to result in undesired changes to managed recreation sites. Under Alternative A, 

trailheads for these trails would be managed recreation sites, but the trails themselves would not be 

designated for recreation management. These existing trails would deteriorate over time and could be 

removed from the landscape in favor of other resource uses.

How would the alternatives affect the management of the Oregon National Historic Trail?

Approximately 2.5 miles of the Oregon National Historic Trail occurs within the decision area, but is 

managed by the National Park Service throughout this length. The cultural resources program inventories 

the trail. The portions of the trail within the decision area are established, paved roads, and the roads are 

largely not under the management and ownership of the BLM. Established BLM-managed roads would 

be designated to the District-Designated Reserve land use allocation under all alternatives, which directs 

for the management of roads for the purposes for which the BLM constructed them, and would result in 

the maintenance of the BLM-managed sections of the trail route. BLM-managed lands that occur along 

the trail route include Congressionally Reserved Lands along the Sandy River (approximately 2 miles) 

and lands designated as Late-Successional Reserve (approximately 0.5 miles). The management of these 

land use allocations would retain the existing character of the Oregon National Historic Trail route.

References

USDI NPS. 1999. Comprehensive Management and Use Plan/Final Environmental Impact Statement: California National 

Historic Trail, Pony Express National Historic Trail; Management and Use Plan Update/Final Environmental Impact 

Statement: Oregon National Historic Trail, Mormon Pioneer National Historic Trail. USDI National Park Service, Salt Lake 

City, UT. 339 pp. http://www.nps.gov/cali/learn/management/upload/CALI-CMP-SM-updated.pdf.
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Rare Plants and Fungi

Key Points

 Only two ESA-listed plant species potentially occur within the Harvest Land Base under all 

alternatives and the Proposed RMP: Kincaid’s lupine and Gentner’s fritillary. The BLM would 

conduct pre-disturbance surveys and apply conservation measures for these two species under all 

alternatives and the Proposed RMP.

 The six ESA-listed plant species within the decision area are shade-intolerant.

 The BLM would manage Bureau Sensitive plant and fungi species under the Bureau’s Special 

Status Species program under all alternatives and the Proposed RMP. However, under Alternative 

D, the BLM would manage these species on O&C lands only in such a way that would not 

conflict with sustained-yield timber production.

 None of the action alternatives or the Proposed RMP would include the Survey and Manage

Measures; therefore, species that are Survey and Manage and not included on the Bureau 

Sensitive species list would receive no specific protections.

 All action alternatives and the Proposed RMP allocate more acres to the Late-Successional 

Reserve than the No Action alternative, which would benefit rare plants and fungi associated with 

Mature and Structurally-complex forest.

Summary of Notable Changes from Draft RMP/EIS

In this Proposed RMP/Final EIS, the BLM has made the following major changes from the Draft 

RMP/EIS:

 Updated information to reflect that the Siskiyou mariposa lily is no longer a candidate for ESAlisting

 Updated and revised numbers of Bureau Special Status and Survey and Manage species based 

upon the most recent lists

 Corrected the table on Survey and Manage species sites to reflect only current rather than historic 

sites

 Expanded the analysis of Survey and Manage species to address specifically the species that a 

prior analysis determined would have insufficient habitat or for which there was insufficient data 

to make a determination of outcomes if the Survey and Manage mitigation measure were 

removed under the Northwest Forest Plan.

 Added specific analysis of effects of designation of reserves on Bureau Special Status vascular 

plant sites

 Expanded analysis of effects of livestock grazing on Bureau Sensitive plant and fungi species 

within active livestock grazing allotments

 Expanded the discussion of the effect of management activities on oak communities as a separate 

issue

Issue 1

How would management activities (such as timber harvest, livestock grazing, and mineral development) 

affect Bureau Special Status plant and fungi species and Survey and Manage species?
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Summary of Analytical Methods

Bureau Special Status Species include ESA-listed, proposed, candidate species, and Bureau Sensitive

species. There are 258 Bureau Special Status plant and fungi species within the planning area: 163

vascular plants, 40 bryophytes (mosses and liverworts), 17 lichens, and 26 fungi. BLM State Directors 

can designate rare and threatened species known or suspected to occur on BLM-administered lands within 

their respective states as Bureau Sensitive. The BLM State Director of Oregon and Washington can also

designate species as Bureau Strategic, a tracking or ‘watch list’ category that is not part of the Bureau 

Special Status Species program. These are species that botanists currently know little about and are 

known or suspected to occur on BLM-administered lands.

Of the 258 plant and fungi Bureau Special Status Species within the planning area, there are 169

documented species on BLM-administered lands. The remaining 89 species are suspected or likely to 

occur on BLM-administered lands. These suspected species are included on the Bureau Special Status 

Species list because known sites occur nearby, their range coincides with the decision area, or suitable 

habitat exists on BLM-administered lands.

Separate from the Bureau Special Status Species program, little-known species thought to be associated 

with late-successional or old-growth forests currently receive special management attention under the 

Survey and Manage measures (USDA FS and USDI BLM 1994). Some of the Survey and Manage 

species qualify for inclusion on the Bureau Sensitive species list. Of the 247 Survey and Manage plant 

and fungi species within the planning area, 39 are also on the Bureau Sensitive list and 59 are on the 

Bureau Strategic list.

Rare plant and fungi species are not evenly distributed across the landscape. Many rare plant and fungi 

species are difficult to detect through surveys. Distribution data is incomplete for rare plant and fungi 

species and special habitats within the decision area. Additionally, the BLM cannot accurately identify at 

this planning scale the location and timing of future management activities that might affect these species

and their habitats. These compounding uncertainties complicate the analysis of effects on rare plant and 

fungi species.

The BLM used species occurrence data where it was available to evaluate the effects of management 

actions on rare plants and fungi. Botanists have surveyed only a portion the decision area, generally as a 

pre-disturbance survey for an individual project (e.g., timber harvest). For vascular species, site data in 

the BLM regional database (GeoBOB) is likely to overstate the actual number of sites and individuals per 

population due to the historical age of the data and lack of revisits to the sites. Conversely, this database 

may under-represent sites of non-vascular and fungi species, because these organisms are difficult to 

count and map. Despite these limitations, the BLM used this incomplete survey data to describe the 

relative differences among the alternatives and the Proposed RMP.

Because there is generally little existing information about the habitat needs and distribution of most of 

the rare plants and fungi to assess effects at the site level, this analysis assumed that the BLM will survey

for rare plants and fungi prior to habitat-disturbing activities except within the Harvest Land Base under 

Alternative D. Surveys are considered ‘likely,’ as BLM botanists currently conduct surveys for habitatdisturbing projects, the surveys are considered practical to conduct, and yield good results to use in 

assessing project effects to rare botanical species. However, in some cases, other tools may be utilized to 

determine the effect of a project, particularly if the projects is small in size or timing is critical. Those 

tools may include the following:

 Evaluation of species-habitat associations and presence of suitable or potential habitat

 Application of conservation strategies, plans, and other formalized conservation mechanisms

 Review of existing survey records, inventories, and spatial data
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 Utilization of professional research, literature, and other technology transfer sources 

 Use of expertise, both internal and external, that is based on documented, substantiated 

professional rationale

For the analytical methods used in the assessment of impacts to rare plants and fungi, the BLM assumes 

project surveys to be the likely method used to assess project effects, but other tools may be utilized, as 

appropriate. As discussed in the background section, fungi are especially difficult to detect even with 

repeated visits. The BLM assumed that the surveys for rare fungi would be incidental to surveys for rare 

plants and that botanists would record all Bureau Special Status plant and fungi species encountered 

during surveys. However, targeted and repeated surveys for fungi would only occur under the No Action 

alternative where equivalent-effort fungi surveys are required for Survey and Manage fungi for projects in 

old-growth forests.

A variety of management actions can affect rare plants and fungi directly through the potential removal of 

sites or habitat and indirectly through increased risk of spread of non-native competing vegetation or risk 

of soil erosion. Some management actions may have both positive and negative impacts upon rare plants 

and fungi. Some individual management actions may favor one rare species over another. Because there 

are many rare plant and fungi species, survey and species data is incomplete, and effects from 

management actions are often variable, it is not feasible to quantify effects from each management 

activity and even less feasible to combine the effects of different actions on rare plants and fungi. For this 

analysis, the BLM analyzed the effects of management actions by alternative and the Proposed RMP on 

rare plants and fungi, but did not attempt to summarize quantitatively the overall effect on rare plants and 

fungi. Instead, the BLM provides a qualitative and comparative summary of the cumulative effect of 

different actions on rare plants and fungi.

Timber Harvest and other Vegetation Management

The BLM evaluated the effect of timber harvest and fertilization on rare plants and fungi. Other 

vegetation management treatments have the potential to affect rare plants and fungi, but it is not possible 

to identify differences in effects among the alternatives and the Proposed RMP at this scale of analysis 

with the data available.

Timber harvest methods (clearcuts, regeneration harvest with retention, selection harvest, and thinning) 

influence the magnitude of the effect of timber harvest on rare plants and fungi and the extent to which 

habitat and sites are within the Harvest Land Base. At this planning scale, it is not possible to identify 

accurately the location and timing of specific future timber harvests that would affect plant and fungi 

habitat. However, in this analysis the BLM evaluated the relative magnitude of the effect of timber 

harvest on rare plants and fungi based on some broad analytical assumptions.

In this analysis, the BLM evaluated effects of timber harvest on rare plant and fungi habitat based on the 

difference in the acreage of timber harvest among alternatives and the Proposed RMP. The BLM assumed 

that clearcut harvest would have a greater magnitude of effects on rare plant and fungi habitat than other 

harvest methods, because it would not retain any structural legacies within the harvested area. Although 

there would be differences in intensity of harvest among the other harvest methods, it is not possible at 

this scale of analysis with the data available to distinguish the potential differences in effects on rare plant 

and fungi habitat among the harvest methods other than clearcuts.

While rare fungi may be found in younger stands, Mature Multi-layered Canopy, and StructurallyComplex stands provide habitat for the majority of the rare fungi on the Bureau Sensitive and the Survey 

and Manage lists (USDA FS and USDI BLM 2000, p. 8; USDA FS and USDI BLM 2004, p. 30). The 

BLM specifically evaluated effects on rare fungi based on the acreage of Mature Multi-layered Canopy,
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and Structurally-Complex stands within the Harvest Land Base under each alternative and the Proposed 

RMP.

The BLM evaluated how the Harvest Land Base overlaps with rare plant and fungi habitat and known 

sites under each alternative and the Proposed RMP. The BLM assumed that timber harvest activities 

would not affect Survey and Manage plant and fungi sites directly in the No Action alternative because of 

Survey and Manage program requirements for pre-disturbance surveys and site protection. The BLM 

assumed that Bureau Sensitive plant sites and known Bureau Sensitive fungi sites would not be directly 

affected by timber harvest activities except under Alternative D, because of pre-disturbance surveys for 

plant species and site protection for all Bureau Sensitive plant and fungi species. Under Alternative D, 

some sites within the Harvest Land Base would be directly affected by timber harvest, because the BLM 

would only protect known sites on O&C lands where protection would not conflict with sustained-yield 

timber production. The BLM assumed that under Alternative D, there would be no additional predisturbance surveys for timber harvest and the BLM would rely on existing information and habitat 

evaluations to assess the site-specific effects of timber management activities on Bureau Sensitive 

species. For the purposes of this analysis, the BLM assumed that sites within the Harvest Land Base of 

Survey and Manage plant and fungi species that are not Bureau Sensitive would eventually be lost 

because of timber harvest under the action alternatives and the Proposed RMP. The BLM assumed that 

loss of host trees from timber harvest could directly affect rare plants and fungi. The BLM assumed that 

changes to their habitat from timber harvest under all alternatives and the Proposed RMP could indirectly 

affect rare plant and fungi species, such as through the introduction or spread of invasive species.

In this analysis, the BLM assumed that fertilization would reduce habitat quality for rare plants and fungi. 

Although fertilization would promote growth of all vascular species, many rare plant species are adapted 

to low nitrogen soils and cannot utilize added nitrogen as readily as conifer species. Non-native species 

also benefit from added nitrogen, giving them a competitive advantage over many rare plant species. 

Nitrogen fertilization reduces ectomycorrhizal fungi species richness, the higher the rate of added 

nitrogen, the greater the decrease in ectomycorrhizal fungi (Ryden et al. 1997, Berch et al. 2006).

Site preparation and fuel reduction treatments, including prescribed burning and biomass treatments, 

would reduce slash from timber harvest and silviculture activities would remove hazard fuels in the 

Wildland Urban Interface (see the Fire and Fuels and Forest Management sections of this chapter). These 

treatments would affect rare plant and fungi species in the conifer and mixed evergreen forests, shrub 

communities, serpentine areas, and oak and hardwood woodlands habitat groups. Site preparation and fuel 

reduction treatments associated with timber harvest would primarily affect the conifer forest habitat group 

and oak and hardwood woodlands habitat groups. These treatments could adversely affect rare species by 

removing the substrate, host species, or modifying the microenvironment upon which the rare plant and 

fungi species depend. The effects of prescribed fire vary due to many factors including method (e.g., pile 

burning, under burning, and broadcast burning), type of fuels present, and topography. Effects range from 

low, where the litter and duff are charred or partially consumed, and the there is little change to the 

vegetative cover, to high, where litter and duff are completely consumed and there is considerable 

vegetation mortality. An indirect effect of prescribed burning is the potential increase in non-native 

species due to removal of competing vegetation, soil disturbance, increased sunlight, and nitrogen 

availability. Site preparation and fuel reduction treatments may provide beneficial effects on some rare 

plants and fungi, such as by reducing competition and shade. Vascular plant species not in the conifer 

habitat group are generally shade-intolerant and respond to increased light and reduction in plant 

competition with increased growth, flowering, and fruiting (USDA USDI 2003, USDI FWS 2006 and 

2010, Giles-Johnson et al. 2010). However, any such potential effects, either adverse or beneficial, are 

highly dependent on site-specific and project-specific factors that cannot be identified at this scale of 

analysis.
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Designation of Late-Successional Reserve and Riparian Reserve

In the Late-Successional Reserve, management objectives include maintaining and promoting habitat for 

the northern spotted owl and marbled murrelet. In the Riparian Reserve, management objectives include 

providing for the conservation of Bureau Special Status fish and protecting water quality. Habitat 

conditions favorable for northern spotted owls, marbled murrelets, and Special Status fish species are also 

favorable for many of the Bureau Special Status plants and fungi, particularly for the bryophytes, lichens, 

and fungi. Most of the Bureau Special Status vascular plants, however, are sun loving and require open 

canopy conditions. The BLM assumed in this analysis that vascular plant sites that require full or partial 

sun for growth and reproduction would eventually disappear in the reserve allocations without 

management to reduce canopy cover.

Livestock Grazing

In this analysis, the BLM assumed that livestock grazing would have both positive and negative effects on 

rare plants and the plant communities in which they occur.

On the positive side, some rare plant species benefit directly from periodic livestock grazing through 

increased vigor and growth. In areas with a large component of non-native annual grasses, livestock 

grazing may reduce the biomass of these grasses, allowing native species, especially annual species, to 

persist (Rilla and Bush 2009). Livestock grazing may also reduce fire fuels and help maintain grasslands 

that are at risk from shrub or tree invasion.

On the negative side, livestock may directly eat rare plants, reducing the plant’s ability to recover and 

reproduce. Livestock also trample vegetation and may introduce and spread noxious and invasive weed 

species. Trampling impacts, however, are typically concentrated. In summer, the presence of water is 

much more important than in the winter, and livestock do not stray far from water. Heavy trampling 

disturbance occurs around holding pens, water sources, salt blocks, and trails between favored livestock

grazing areas; livestock may completely denude these areas. Away from these resources, effects from 

trampling are usually dispersed.

The BLM evaluated the effects of livestock grazing on rare plants by comparing the acreage open to 

livestock grazing in each alternative and the Proposed RMP. Additionally, the BLM considered the 

presence of ESA-listed threatened and endangered plant species in active allotments.

ACEC Designation

The BLM designates ACECs where special management attention is required to maintain and protect 

relevant and important values. In this analysis, the BLM assumed that management for these relevant and 

important values would also be protective of rare plants and fungi. The BLM compared the acreage of 

ACECs to evaluate the protection for rare plants and fungi under each alternative and the Proposed RMP. 

Although rare plant and fungi species are not evenly distributed across the landscape, the BLM assumed 

in this analysis that all acres designated as ACECs would provide equivalent protection for rare plants and 

fungi. At this scale of analysis, the BLM does not have sufficient information to identify specific effects 

of specific ACEC designations on rare plant and fungi species.

Road Construction

In this analysis, the BLM evaluated the effects of road construction on rare plants and fungi based on the 

miles of new road construction during the first decade under each alternative and the Proposed RMP. The 

BLM assumed that new road construction would adversely affect rare plants and fungi because of direct 

disturbance and removal plants and fungi and from disturbance and removal of habitat. Road construction 
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directly removes all vegetation in the construction zone, increases water runoff on the compacted or 

hardened surface (which can result in increased soil erosion immediately adjacent to the road), fragments 

habitat, creates a conduit for the introduction of noxious and non-native invasive plants, and increases 

access routes for public motorized vehicle use and camping. In this analysis, the BLM assumed that road 

construction would cause habitat disturbance and removal across a 45-foot width (see the Soil Resources

section of this chapter).

Public Motorized Access Designations

In this analysis, the BLM assumed that areas designated as open for public motorized access would 

experience habitat removal and disturbance for rare plants and fungi. Where cross-country travel would 

occur, vehicles would crush vegetation, displace soils, and create trails that could potentially degrade 

occupied habitat and damage sites of rare plant and fungi species that may be scattered throughout the 

area. These conditions would allow for the introduction and dispersal of noxious and non-native weed 

species.

Although the BLM has some site-specific and anecdotal information about illegal public motorized travel 

activities, the BLM does not have a basis for predicting the location or effects of any widespread or 

systematic illegal public motorized travel activities. In addition, much of the decision area has physical 

limitations to potential illegal public motorized travel activities, including dense vegetation, steep slopes, 

and locked gates. Terrain, vegetation, and a greater amount of open spaces in most of the interior/south 

can lead to degradation and erosion in a greater proportion than the coastal/north where vegetation is 

denser and terrain is steeper. However, the BLM lacks a basis for characterizing current illegal public 

motorized travel activities or forecasting potential illegal public motorized travel activities in the future 

under any of the alternatives and the Proposed RMP at this scale of analysis. In this analysis, the BLM 

assumed that members of the public participating in motorized travel recreation would operate vehicles 

consistent with BLM decisions about public motorized travel opportunities (see the Trails and Travel 

Management section of this chapter).

Areas designated as closed for public motorized access would not experience habitat disturbance for rare 

plants and fungi, because the BLM would not permit public motorized vehicle activities. Areas designated 

as limited would not experience measurable additional habitat disturbance for rare plants and fungi, 

because the BLM would limit public motorized vehicle use to existing or designated roads and trails, 

which have already experienced disturbance through the original construction of the roads or trails. Until 

the BLM completes route designations through implementation-level travel management planning, the 

BLM cannot identify which routes the BLM would designate under a particular alternative or the 

Proposed RMP. Therefore, the BLM cannot quantify more site-specific effects in this analysis, and would 

address effects in implementation-level analysis.

Mineral Development

Within the decision area, the BLM’s primary salable mineral material is quarry rock. The majority of this 

quarry rock is crushed aggregate used by the BLM, private companies, and local governments for road 

surfacing (see the Minerals section of this chapter). Quarry activities could have a detrimental effect on a 

small amount of habitat associated with rare plants and fungi in the rocky areas/outcrops, scree, 

serpentine, and conifer groups. The BLM also considered the effects of quarry activities on rare plants 

and fungi based on the acreage closed to salable mineral material disposal under each alternative and the 

Proposed RMP.
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In this analysis, the BLM assumed that leasable mineral development would have no foreseeable effect on 

rare plants and fungi, because the BLM can impose site-specific stipulations, such as no surface 

occupancy, on each lease as needed to protect rare plant and fungi sites and habitat.

The BLM assumed that locatable mineral entry would adversely affect rare plants and fungi because of 

habitat removal and disturbance. The BLM evaluated this habitat removal and disturbance based on the 

acres that the BLM would recommend for withdrawal from locatable mineral development by alternative

and the Proposed RMP. The BLM assumed in this analysis that areas recommended for withdrawal would 

protect rare plant and fungi sites and habitats from effects from locatable mineral entry. Locatable mining 

operations occur primarily in areas occupied by species in the rocky areas/outcrops/scree, serpentine, 

conifer, and riparian and aquatic habitat groups. While the number of sites of rare plants and fungi that 

intersect with mining operations would be few, where they do occur, the BLM assumed that these sites 

would be lost. The mining laws (see the Minerals section of this chapter) explicitly allow for 

consideration of ESA-listed or proposed species, but not for other BLM Special Status Species; therefore, 

the BLM assumed that sites of Special Status Species other than ESA-listed or proposed species would 

likely be extirpated and occupied habitat would be destroyed because of equipment operations and ground 

disturbance.

Background

The planning area is vegetatively diverse due to the physical geography of the area. The planning area

falls within five of the Level III ecoregions82 mapped by the Environmental Protection Agency: 

Willamette Valley, Coast Range, Cascades, Klamath Mountains, and Eastern Cascades Slopes and 

Foothills (Omernik and Griffith 2012).

Within Oregon, there are more than 4,677 recognized taxa of vascular plants (Oregon Flora Project 2013). 

There is a substantial diversity of non-vascular plants (bryophytes and lichens) and fungi within the 

planning area; however, there is not a single comprehensive list of these organisms, because scientists 

have not studied and catalogued these species as well as vascular plants. The majority of the plants and 

fungi found in Oregon are common, and the current threat of extinction is slight. Some species are 

naturally rare or uncommon due to many biological and physical factors. For example, some rare plant 

species are strictly associated with serpentine soils that occur in the planning area within the Klamath 

Mountains ecoregion (e.g., crinite mariposa lily (Calochortus coxii); Oregon Biodiversity Information 

Center 2014). Rare species may occur in very small numbers or may be abundant within a narrow 

distribution. Other rare species may have a broad distribution, but occur in small numbers where found 

(e.g., clustered lady’s-slipper (Cypripedium fasciculatum); Oregon Flora Project 2014). Some species are 

rare because of changes to their habitat (e.g., farming, urban and rural development, mining, and road 

construction).

The distribution of rare plant species is not even across the landscape. Mapping of species sites provides 

distribution and density patterns. ‘Hot spots’ are areas of high Bureau Special Status Species richness and 

density. Hot spots can occur at fine spatial scales, such as special habitat features (meadows, wetlands, 

rock outcrops, and other non-forested areas), and at larger geographic scales, where high levels of 

endemism occurs on the broader landscape level (Appendix N). The figure in Appendix N is based upon 

data in the BLM’s Geographic Biologic Observations (GeoBOB) database. Because the BLM does not 

have complete botanical surveys, that figure shows the relative density of Bureau Special Status Species 

sites based upon current data. Both Table 3-107 and Table 3-108 indicate that the largest abundance and 

density of Bureau Sensitive/Strategic plant sites within the planning area is within the Medford District. 

 

82 Ecoregions are areas within which ecosystems are generally similar based upon geology, vegetation, climate, and 

hydrology. These are different from the physiographic provinces described in Figure 3-187.
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This is because the Medford District lies primarily within the Klamath Province, which has the highest 

total species richness of any province within the planning area. The complex geology of the Klamath 

Province supports diverse plant communities.

Table 3-107. Bureau Sensitive and Strategic plant and fungi sites by status and taxonomic group

District/

Field Office

Bureau Sensitive Bureau Strategic Totals

(Number 

of Sites)

Bryophytes

(Sites)

Lichens

(Sites)

Vascular 

Plants

(Sites)

Fungi

(Sites)

Bryophytes

(Sites)

Lichens

(Sites)

Vascular 

Plants

(Sites)

Fungi

(Sites)

Coos Bay 14 128 195 19 57 10 11 57 491

Eugene 8 23 92 8 7 19 1 24 182

Klamath Falls - - 53 6 - - 2 4 65

Medford 9 - 2,918 11 35 165 48 38 3,224

Roseburg 1 40 103 9 5 18 - 18 194

Salem 16 171 29 102 3 14 - 73 408

Totals 48 362 3,390 155 107 226 62 214 4,564

Table 3-108. Bureau Special Status, Strategic, and Survey and Manage plant and fungi sites documented 

between January 2009 and July 2013 in the decision area

District/

Field Office

Special Status

(Number of Sites)

Strategic

(Number of Sites)

Survey and Manage

(Number of Sites)

Surveyed

(Acres)

Coos Bay 9 2 15 8,217

Eugene 8 5 16 36,197

Klamath Falls - - - 234

Medford 207 74 94 47,917

Roseburg 7 6 45 19,117

Salem 3 1 10 9,615

Totals 226 88 180 121,297

Field surveys are the best method to confirm presence or absence of rare species and to increase 

knowledge of range, distribution, and habitat characteristics. Based upon data available in the GeoBOB 

database as of November 2014, the BLM surveyed approximately 121,297 acres within the decision area 

from January 2009 to July 2013 and found a total of 226 new Bureau Special Status Species sites, 88 new 

Bureau Strategic species sites, and 180 new Survey and Manage species sites. These were typical preproject surveys, not the Survey and Manage ‘equivalent-effort’ surveys. Thus, the BLM found 1 new 

Bureau Special Status, Bureau Strategic, or Survey and Manage plant or fungi site for every 246 acres 

surveyed on average over this time period. However, BLM found the majority of the new sites within the 

Medford District, which has 92 percent of the Special Status sites, 84 percent of the Bureau Strategic 

sites, and 52 percent of the Survey and Manage sites. The detection rate for the Medford District was 1

new site for every 128 acres surveyed, while the detection rate for the Eugene District was much less, 

with 1 new site found for every 1,248 acres surveyed. During this period, surveyors did not document any 

new sites of Bureau Special Status, Bureau Strategic, or Survey and Manage plant or fungi species within 

the Klamath Falls Field Office while conducting typical pre-project surveys.

83

 

83 ‘Equivalent-effort’ surveys conducted between 2011 and 2013 in the Klamath Falls Field Office did yield 

numerous sites of Survey and Manage fungi.
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Certain species, especially fungi, are difficult to detect during much of the year (USDA FS and USDI 

BLM 2004, pp. 148–149). Many fungi grow below the soil surface or within down woody debris and 

surveyors can only detect them when their fruiting bodies are present. Most of the structure (mycelium) of 

fungi species is not visible, because it is within whatever substrate the fungus lives (e.g., logs, tree 

stumps, duff, and soil). Generally, botanists consider fungi impractical to survey for, because they do not 

produce sporocarps (fruiting bodies) every year, or do not produce sporocarps everywhere that they may 

occur, and the sporocarps are usually present for a short time. Most of the Bureau Special Status and 

Survey and Manage fungi are mycorrhizal and associated with conifer trees. Other species are 

decomposers or are parasites on other fungi. Even when sporocarps are present, they are an unreliable 

indicator of location and activity of mycelia (Dahlberg and Stenlid 1995). The presence of sporocarps 

demonstrates that the species is present, but visual observation cannot determine the extent of a fungi

population. The plant community composition gives an indication of the fungi community under the 

surface. The plant community influences the development of mycorrhizal populations (i.e., when the 

aboveground vegetation changes, the fungi community also changes).

Likewise, many vascular plant species may germinate only when growing conditions are favorable for the 

species, and the presence of flowers may be required for positive identification. To optimize detection, 

botanists must conduct surveys during the appropriate season and when local field conditions are 

favorable for the species. The numbers of Special Status Species sites listed in Table 3-108 represent a 

snapshot in time and give an indication of relative abundance and diversity of rare plant and fungi species 

among the BLM administrative units in the planning area. The BLM conducted the majority of the

surveys for pre-disturbance surveys for individual projects (e.g., timber sales, culvert replacements, and 

noxious weed treatments). Survey efforts for these species have been biased in their location based on 

proposed land management projects.

Many rare plants are associated with distinct and narrow habitat types within larger vegetative 

communities shaped by geologic features and substrate, climate, and hydrologic influences. These 

habitats range from rock substrates and outcrops of different origins with variable soil types and 

conditions (including sand dunes) to seasonal and permanent wetlands, vernal pools, fens, bogs, and 

marshes. Because they have persisted over time, these habitats have become refugia for unusual plant 

communities and rare species adapted to specialized environments. However, even within these habitats, 

rare species occur very infrequently.

Rare vascular plant species occur in a broad range of plant communities, habitat types, and substrates. 

Since vascular plants are generally large and botanists have studied them extensively, botanists have a 

good understanding of the habitats associated with each of the rare vascular plants. Bryophytes and 

lichens also occur in a variety of habitats. Many of these species are closely associated with a particular 

substrate (e.g., conifer tree boles), habitat condition (e.g., moist forest), and environment (e.g., near the 

coast); however, because they are smaller and often more difficult to identify than vascular species, 

botanists do not know as much about their habitats and range than they do about vascular species. Fungi 

occur in a number of forms. Most are mycorrhizal and usually associated with host species in conifer and 

hardwood forest communities. Because the fruiting body (e.g., mushroom) of a fungus is often the only 

part of the fungus visible, biologists often know little about the distribution, range, and habitat needs of 

rare fungi species.

Mycorrhizal fungi grow in a symbiotic relationship with vascular plant species. One or both organisms 

are dependent upon the other for food or resources. Mycorrhizal fungi depend upon actively growing root 

tips of the vascular plant with which it is associated. Mycorrhizal fungi populations change when the 

vascular plant community changes. Tree removal results in a decline in fine root activity and a similar 

reduction in the diversity of mycorrhizal fungi (Hagerman et al. 1999). Clear-cutting results in the loss of 
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fungi species richness, (i.e., the larger the clearcut, the greater the impact to the mycorrhizal fungi 

community; Dural et al. 1999, Hagerman et al. 1999, Kranabetter and Kroeger 2001). Green tree retention 

and smaller clearcuts allow fungi to continue to persist in the harvested area and allow for early 

recolonization of mycorrhizal species post-harvest (Miller et al. 1998, Wiensczyk et al. 2002, Kranabetter 

and Kroeger 2001, Luoma and Eberhart 2005).

Biological factors play important roles in determining the distribution and abundance of a species. These 

factors include reproductive strategies, inbreeding depression, pollinators and pollination, consumption by 

herbivores, weed invasion, habitat connectivity, disease, predation, habitat change, and global climate 

change. Often the biological factors that affect a species’ rarity are difficult to isolate or are interrelated, 

creating uncertainty as to the real cause of rarity. Some rare Oregon species appear to be remnant 

populations from historic plant communities that have shifted since the last ice age. Other rare species in 

Oregon are narrow endemics adapted over long periods to specific habitats or substrates, such as the 

serpentine endemic group. Some rare species may have evolved as isolated populations that are diverging 

morphologically from the greater population, or may be the result of hybridization (e.g., Gentner’s 

fritillary). Certain rare species of lichens and bryophytes, while geographically widespread, appear to be 

locally adapted to narrow environmental conditions along the Pacific Northwest coast. A number of 

species in Oregon are rare due to loss of habitat and the introduction and spread of invasive plants.

Natural disturbances, such as wildfires, windstorms, and floods, change plant communities and habitat 

conditions for rare plants and fungi. Many factors determine whether a population will survive a 

disturbance, including the following:

 Type, extent, duration, and intensity of the disturbance

 Frequency and season of the disturbance

 Habitat and life cycle requirements of a species

 Adaptability of a species to a changed environment

Some rare plant species are adapted to frequent, low-intensity fires and respond positively in most cases 

(e.g., Bradshaw’s desert-parsley; Kaye et al. 2001). Species such as Gentner’s fritillary and Kincaid’s 

lupine can respond positively to the increased light and moisture from the loss of overtopping and 

competing vegetation and the increase in nutrients available after a fire. Although certain species respond 

positively to disturbance, they remain rare because of infrequent disturbances, loss of habitat, and rapid 

invasion by annual weeds. Alternatively, fire consumes many rare lichen, bryophytes, and fungi, along 

with some vascular plants without fire-adaptive mechanisms. These sites, as well as their habitat and 

hosts, would be lost unless protected in a niche or island where the fire was absent or less severe.

Floods and debris flows alter riparian and aquatic plant communities and can alter the rare plant 

populations that occur in disturbed areas. These types of events are very dynamic, with some rare plant 

sites benefiting whereas others are lost. Although floods may appear to destroy the existing riparian and 

aquatic vegetation initially, they also deposit sediment, distribute seed, and reduce native and invasive 

vegetation. This facilitates vigorous re-sprouting and reseeding of riparian-associated shrubs, perennial 

and annual grasses, and forbs. For example, many rare rush and sedge species associated with streams and 

wetlands are adapted to periodic floods by prolific seed production.

ESA-listed Species

Twelve ESA-listed plant species occur or have occurred historically within the planning area. The BLM 

has documented six of these species within the decision area: Gentner’s fritillary, western lily, Cook’s 

lomatium, rough popcorn flower, Kincaid’s lupine, and Nelson’s checker-mallow. The U.S. Fish and 

Wildlife Service has designated critical habitat for four of the ESA-listed plants: Willamette Valley daisy, 
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large-flowered wooly meadow-foam, Cook’s lomatium, and Kincaid’s lupine. The U.S. Fish and Wildlife 

has completed recovery plans for all of the ESA-listed plants within the planning area.

Gentner’s fritillary is a member of the lily family (Liliaceae) and has showy deep red to maroon flowers 

on a single erect flowering stem arising from an underground bulb. The bulbs produce small bulblets that 

are loosely attached to the parent individual. These asexually produced bulblets are the primary means of 

reproduction for the species (Amsberry and Meinke 2007). Many Gentner’s fritillary plants do not flower 

or flower only in some years, making positive identification of newly discovered sites difficult, because 

leaves are indistinguishable from other co-occurring fritillary species. Gentner’s fritillary occurs in 

scattered locations throughout the Rogue and Illinois River watersheds within the Medford District. 

Habitat is diverse, ranging from Oregon white oak woodlands, moist riparian areas, Douglas-fir forests, 

and serpentine areas. The Medford District has surveyed an average of 40,000 acres per year for the years 

2008–2013. On average, the surveyors found 1 new Gentner’s fritillary site for every 4,400 acres 

surveyed in suitable habitat. Most sites are very small (i.e., less than 12 individuals). However, a few sites 

contain several hundred flowering plants with many more bulbs producing only vegetative leaves. There 

are currently 162 sites within the decision area. There are an additional 36 sites on BLM-administered 

lands within the Cascade-Siskiyou National Monument, which is outside of the decision area. Gentner’s 

fritillary occurs within eight active livestock grazing allotments. The Medford District has surveyed all 

suitable habitats within livestock grazing allotments, and populations generally occur on steeper slopes 

outside of riparian areas, where livestock use is light. Botanists monitor the effects of livestock grazing on 

Gentner’s fritillary, and there is little evidence of direct livestock grazing or trampling by livestock (M. 

Wineteer, BLM, personal communication, 2014). The Medford District has worked to augment sites by 

outplanting bulblets since 2002.

Western lily is a perennial in the lily family (Liliaceae) and occurs in a narrow strip along the immediate 

Pacific coast between Coos Bay, Oregon, and Eureka, California, in a variety of early successional 

habitats: freshwater wetlands, coastal prairie and scrub, and the edges of Sitka spruce forest. The single 

natural BLM site occurs within the New River ACEC in the Coos Bay District. An experimental 

introduction of Western lily within the New River ACEC in 1996 produced its first flowering plant in 

2011, but the researcher has not noted any natural reproduction as of 2014 (Guerrant 2015). Suitable 

habitat for additional introductions within the New River ACEC is limited (T. Rodenkirk, BLM Botanist, 

personal communication, 2014).

Cook’s lomatium is a perennial forb in the carrot family (Apiaceae). The species occurs in the Medford 

District in the Agate Desert of Jackson County on the edge of vernal pools and in the Illinois Valley in 

seasonally wet grassy meadows, oak woodlands, and serpentine meadow and shrub habitats. The largest 

populations on BLM-administered lands are in and adjacent to the French Flat ACEC. Rural development 

and recreational use threaten Cook’s lomatium habitat in the Illinois Valley as illegal uses such as public 

motorized vehicle trespass and refuse dumping occasionally damage sites on BLM-administered lands, 

although the use of barricades and law enforcement efforts have successfully reduced effects in recent 

years (R. Showalter, BLM, personal communication, 2014). The BLM does not authorize livestock 

grazing of any habitats containing Cook’s lomatium.

Rough popcorn flower is an annual to perennial herb in the borage family (Boraginaceae) that occurs in 

seasonally wet meadows or Oregon ash-swale openings in northern Douglas County in the Roseburg 

District. There are no naturally occurring populations of rough popcorn flower on BLM-administered 

lands. The Oregon Department of Agriculture, in cooperation with the BLM, planted three sites within the 

North Bank Habitat Management Area ACEC starting in 1998. One of these populations is thriving and 

has expanded to fill the potential habitat within the area. The second site is still extant; however, the 

number of plants has declined drastically over the years, likely due to a change in the site’s hydrology. 

The BLM planted additional suitable habitat adjacent to the original planted location in 2006. The third 
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population occurs in marginal habitat that is too dry for the species, and it is unlikely that the species still 

occurs there.

Kincaid’s lupine is a long-lived herbaceous perennial species in the pea family (Fabaceae). It ranges from 

Lewis County, Washington, to Douglas County, Oregon. Botanists first described the species from the 

Willamette Valley, where most of the known and historic populations occur. The habitat for Kincaid’s 

lupine in the Willamette Valley consists primarily of upland prairie remnants. Within the decision area, 

the primary habitat is open woodland and meadow edges, often near roadsides, associated with Pacific 

madrone, incense cedar, and Douglas-fir trees with a relatively open canopy cover. There are currently ten

Kincaid’s lupine sites known to occur in the decision area. In addition, there are five sites on BLMadministered lands within the West Eugene Wetlands, which is outside of the decision area. In 2006, the 

U.S. Fish and Wildlife Service designated critical habitat for Kincaid’s lupine in the Willamette Valley 

and Washington State, but not in the southern portion of its range in Douglas County. The only

designated critical habitat for Kincaid’s lupine on BLM-administered lands is within the West Eugene 

Wetlands. In April 2006, the Roseburg District, U.S. Fish and Wildlife Service, and the Umpqua National 

Forest completed a programmatic conservation agreement for Kincaid’s lupine in Douglas County (USDI 

BLM, USDI FWS, and USDA FS 2006). The three cooperating agencies completed the “Management 

Plan for Kincaid’s Lupine in Douglas County, Oregon” in March 2008 (USDI BLM, USDI FWS, and 

USDA FS 2008). The management actions specified in the management plan tier to the management 

goals and objectives for the recovery of Kincaid’s lupine (USDI FWS 2010). The primary threats to 

Kincaid’s lupine in the planning area are forest succession and resulting canopy shading, noxious weed 

invasions, and road maintenance. In addition, the populations in the decision area are generally small and 

isolated from each other. This isolation limits the likelihood of cross-pollination between populations, 

which could result in inbreeding depression.

Nelson’s checker-mallow is a long-lived perennial in the mallow family (Malvaceae) that occurs in the 

Willamette Valley from Benton County, Oregon, and north into Cowlitz and Lewis Counties, 

Washington. In the Willamette Valley, Nelson’s checker-mallow occurs in wet prairies, stream sides, and 

occasionally in Oregon ash woodlands or among woody shrubs. On BLM-administered lands, the species 

occurs at one site in the Walker Flat ACEC on the Salem District. Most of the plants in this population 

occur on adjacent City of McMinnville property. Nelson’s checker-mallow requires open habitats; 

succession and canopy closure is a threat to the species (USDI FWS 2012).

Siskiyou mariposa lily, a former candidate for ESA-listing, also occurs within the planning area. The U.S. 

Fish and Wildlife Service determined that the species did not warrant listing at this time (80 FR 60834), 

and this analysis addresses the species as a Bureau Sensitive species. Siskiyou mariposa lily is a perennial 

in the lily family (Liliaceae). It is endemic to three disjunct ridge tops in the Klamath-Siskiyou Range on 

the California-Oregon border. The habitat for the species is rocky openings within a montane shrub plant 

community. The one site on BLM-administered lands consists of 1–5 plants within a 54-square-foot area 

(USDI BLM, USDI FWS, and USDA FS 2013).

The following six species occur or occurred historically within the planning area, but are unlikely to occur 

in the decision area: Applegate’s milk-vetch, Willamette Valley daisy, large-flowered wooly meadowfoam, Bradshaw’s desert parsley, golden paintbrush, and water howellia.

Applegate’s milk-vetch in the pea family (Fabaceae) is a narrowly distributed endemic, known to occur 

only in southern Klamath County, Oregon. It occurs within interior alkali grassland with rabbitbrush and 

greasewood in areas with periodic flooding and drying. Very little of this habitat is present on BLMadministered and is unlikely to occur in the Klamath Falls Field Office (R. Currin, U.S. Fish and Wildlife 

Service, personal communication, 2014, and J. Blanchard, personal communication, 2014).
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Willamette Valley daisy in the sunflower family (Asteraceae) occurs in both wet and dry prairie 

grasslands within the Willamette Valley where woody cover is nearly absent and where herbaceous

vegetation is low in stature. Five sites occur on BLM-administered lands within the West Eugene 

Wetlands, which is outside of the decision area. The only designated critical habitat on BLMadministered lands within the planning area is also within the West Eugene Wetlands.

Large-flowered wooly meadowfoam in the meadowfoam family (Limnanthaceae) is associated 

exclusively with the margins around shallow vernal pools in the Agate Desert of the Rogue Valley in 

Jackson County, Oregon. There are 18 extant sites within the Agate Desert on private, State, and Federal 

land managed by the Bureau of Reclamation (USDI FWS 2012b). There is no designated critical habitat 

on BLM-administered lands.

Bradshaw’s desert parsley in the carrot family (Apiaceae) is restricted to wet prairie habitats with heavy 

clay soils. The majority of the known sites occur between Salem and Creswell, Oregon; however, two 

sites are known in Clark County, Washington (USDI FWS 2010). Seven sites occur on BLMadministered lands within the West Eugene Wetlands, which is outside of the decision area.

Golden paintbrush in the broomrape family (Orobanchaceae) historically occurred in the grasslands and 

prairies of the Willamette Valley, but agricultural, residential, and commercial development has 

extirpated all sites in Oregon. The species is currently known from 11 populations in Washington and 

British Columbia (USDI FWS 2010). Golden paintbrush was last seen growing wild in Oregon in 1938 in 

Linn County. Researchers began planting small numbers of golden paintbrush within the Finley and 

Basket Butte Wildlife Refuges in 2005 from seed collected in Washington to test restoration methods for 

the species (USDI FWS 2010).

Water howellia in the bellflower family (Campanulaceae) no longer exists in Oregon, but there are 

herbarium records showing that the species used to occur in at least four locations within the Willamette 

Valley and Columbia River floodplain. The species currently occurs in a few sites in Washington, Idaho, 

Montana, and California. The species appears to be restricted to small, vernal, freshwater wetlands, 

glacial pothole ponds, or former river oxbows that have an annual cycle of filling with water over the fall, 

winter, and early spring, followed by drying during the summer months (USDI FWS 1994).

Bureau Sensitive and Strategic Species

Based on BLM Manual 6840 – Special Status Species Management, the BLM would address Bureau 

Sensitive species and their habitats in land use plans and would implement measures to conserve these 

species and their habitats, to promote their conservation, and reduce the likelihood and need for these 

species to be listed under the Endangered Species Act. While the Special Status Species policy applies to 

all lands managed by the BLM: “The application of the Special Status Species policy to provide specific 

protection to species that are listed by the BLM as sensitive on lands governed by the O&C Act must be 

consistent with timber production as the dominant use of those lands” (BLM Manual 6840 – Special 

Status Species Management; USDI BLM 2008).

Bureau Strategic species are not Bureau Special Status for management purposes (IM-OR-2015-028). The 

only requirement for this group of species is that information for species sites located during any survey 

efforts would be entered into the BLM corporate database (GeoBOB). This analysis includes discussion 

of Bureau Strategic species to provide a more comprehensive analysis of rare plants and fungi in the 

decision area; effects to these species are typically not analyzed in project-level analyses. 

In Oregon, the Sensitive and Strategic lists are tied to the Oregon Biodiversity Information Center 

(ORBIC) rankings. ORBIC is part of the Institute for Natural Resources that was created by the Oregon 
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Legislature with the Oregon Sustainability Act of 2001 (ORS 184.421). The ranks that ORBIC produces 

are shared through a network of natural heritage programs and conservation centers, allowing information 

sharing among several countries in the western hemisphere. The BLM updates the Sensitive and Strategic 

Species lists approximately every three years.

In 2004, the BLM and Forest Service established an interagency program for the conservation and 

management of rare species in Oregon and Washington known as the Interagency Special Status/Sensitive 

Species Program (ISSSSP). The ISSSSP has funded a number of inventories, monitoring projects, and the 

development of species fact sheets and conservation assessments that aid in the management of Bureau 

Special Status Species. The Affected Environment section contains a summary of the results of these 

surveys.

Survey and Manage

The Northwest Forest Plan and the 1995 RMPs include the Survey and Manage measures, which require 

special management attention for little known species thought to be associated with late-successional or 

old-growth forests. Some species require pre-project surveys and have prescribed management actions if 

found.

The 2000 Final Supplemental EIS for Amendment to the Survey and Manage, Protection Buffer, and 

other Mitigation Measures Standards and Guidelines and the 2004 Final Supplemental EIS to Remove of 

Modify the Survey and Manage Mitigation Measure Standards and Guidelines discussed the origin and 

implementation of the Survey and Manage measures and the need for changes to the measures (USDA FS 

and USDI BLM 2000, pp. 3–10, 16–24; USDA FS and USDI BLM 2004, pp. 3–9, 15–21), and those 

discussions are incorporated here by reference.

Those two Supplemental EISs and the 2007 Final Supplement to the 2004 Supplemental EIS also 

described the Survey and Manage species and their habitat, distribution, and occurrence (USDA FS and 

USDI BLM 2000, pp. 213–319; USDA FS and USDI BLM 2004, pp. 141–183; USDA FS and USDI 

BLM 2007, pp. 181–244), and those descriptions are incorporated here by reference.

The 2012 Resource Management Plan Evaluation Report (USDI BLM 2012, pp. 12–13) summarized the 

history of proposed changes to the Survey and Manage measures and that summary is incorporated here 

by reference. The Wildlife section of this chapter contains additional information on the history of 

proposed changes to the Survey and Manage measures.

There are six categories of Survey and Manage species that are found in the planning area (Table 3-109). 

The categories consider species relative rarity, their level of association with late-successional/old-growth 

forests, and if pre-disturbance surveys are practical (Table 3-110). Strategic surveys are landscape-scale 

surveys designed to collect information about a species, including its presence and habitat, and are 

required for all Survey and Manage species. For Category A and C species, pre-disturbance surveys are 

required. The Survey and Manage measures specified that if strategic surveys were not completed for 

Category B species in fiscal year 2006 (fiscal year 2011 for fungi), then surveys equivalent to predisturbance surveys would be required prior to management disturbance in old-growth habitat. Twelve 

years of strategic surveys for fungi have increased the total known sites of Survey and Manage fungi from 

approximately 3,500 to 14,400 sites within the decision area. Over the course of the program, surveyors 

found enough sites of 39 fungi species that these fungi are no longer considered rare (Molina 2008). 
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“Equivalent effort” surveys are required for two lichens, four bryophytes,

84 and all Category B fungi 

species prior to disturbance in old-growth forest, defined by the Northwest Forest Plan as a forest stand, 

usually at least 180 to 220 years old, with moderate-to-high canopy closure, a multi-layered, multi-species 

canopy dominated by large overstory trees, a high incidence of large trees, some with broken tops and 

other indications of old and decaying wood, numerous large snags, and heavy accumulations of wood, 

including large logs on the ground (USDA FS and USDI BLM 1994a). The Survey and Manage Category 

B Fungi Equivalent-Effort Survey Protocol generally requires two years of surveys with visits scheduled 

in the autumn and spring when sporocarps are more likely present (USDA FS and USDI BLM 2011).

Table 3-109. Number of Survey and Manage plant and fungi species by taxonomic group and category 

found within the planning area using the current (2003) Survey and Manage species list

Taxa Group

Survey and Manage Categories Total

Species

(Number)

A

(Number)

C

(Number)

B

(Number)

D

(Number)

E

(Number)

F

(Number)

Bryophytes 2 - 8 - 3 - 13

Fungi 1 - 163 13 4 3 184

Lichens 10 2 6 - 20 2 40

Vascular Plants 7 3 - - - - 10

Totals 20 5 177 13 27 5 247

Source: USDI BLM 2014

Table 3-110. Survey and Manage categories and associated survey status by rarity

Relative Rarity Pre-Disturbance Surveys

Practical

Pre-Disturbance Surveys

Not Practical

Survey Status

Undetermined

Rare Category A Category B Category E

Uncommon Category C Category D Category F

Affected Environment

There are 213 known sites of ESA-listed plants on the decision area (Table 3-111). Most occupied sites 

of the ESA-listed species are very small: approximately 74 percent of all sites occupy 0.10 acre or less or 

comprise less than 10 individuals. All but two of these species occur in habitats uncommon in the 

planning area: wetlands, meadows, oak woodlands, or rocky areas. The two remaining species—

Gentner’s fritillary and Kincaid’s lupine—occur in mixed woodlands and hardwood/conifer habitat.

While the U.S. Fish and Wildlife Service has designated critical habitat for the large-flowered wooly 

meadow-foam, Cook’s lomatium, and Kincaid’s lupine, only 3,125 acres of Cook’s lomatium critical 

habitat occurs within the decision area.

 

84 BLM Instruction Memorandum No. OR-2006-038. Lichens: Bryoria subcana and Thorlurna dissimilis; 

Bryophytes: Kurzia makinoana, Marsupella emarginata var. aquatica, Orthodontium gracile, and Tritomaria 

exsectiformis.
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Table 3-111. ESA-listed plants within the decision area

Common Name Scientific Name Known 

Sites

District/Field 

Office within 

Range of 

Species

Notes

Endangered

Gentner’s fritillary Fritillaria gentneri 162

Klamath 

Falls, 

Medford

All BLM sites are on Medford 

District with an additional 36 

sites within Cascade-Siskiyou 

National Monument; potential 

habitat in Klamath Falls Field 

Office

Western lily Lillium occidentale 1 Coos Bay An additional introduced site 

is not yet established

Large-flowered wooly 

meadow-foam

Limnanthes pumila 

ssp. grandiflora - Medford Potential habitat in Medford District

Bradshaw’s desert 

parsley

Lomatium 

bradshawii -

Eugene,

Salem

No potential habitat on BLM 

within decision area; there are 

7 sites within the West 

Eugene Wetlands.

Cook’s lomatium Lomatium cookii 35 Medford

Largest BLM populations in 

and adjacent to French Flat 

ACEC

Rough popcorn flower Plagiobothrys 

hirtus 3 Roseburg

BLM populations are 

introduced within the North 

Bank Habitat Management 

Area

Threatened

Golden paintbrush Castilleja levisecta -

Eugene, 

Salem No potential habitat on BLM

Water howellia Howellia aquatilis -

Eugene, 

Salem No potential habitat on BLM

Kincaid’s lupine Lupinus oreganus 10 Eugene, 

Roseburg

5 additional sites within West 

Eugene Wetlands

Nelson’s checkermallow Sidalcea nelsoniana 1 Salem Within the Walker Flat ACEC

Total 212

There are 4,564 known sites of Bureau Sensitive and Strategic plant and fungi species within the decision

area (Table 3-107). Sites range in size from just one or a few individuals that occupy much less than 0.10

of an acre to thousands of individuals that comprise several acres. Nearly 90 percent of the known 

Sensitive and Strategic plant and fungi sites are less than 1 acre.

The BLM has conducted Survey and Manage fungi equivalent-effort surveys on 5,356 acres in the 

Medford District and 686 acres in the Klamath Falls Field Office from 2011 to 2013. Surveyors found 

619 sites during this period, an average of 1 new site for every 9.8 acres surveyed within potential habitat. 

The Salem District conducted equivalent-effort fungi surveys on 2 acres and did not find any fungi.
533 | P a g e

There are currently 862,408 acres of Mature Multi-layered Canopy or Structurally-complex stands, which 

provides potential habitat for rare plants and fungi that are associated with late-successional and old 

growth habitat.

Environmental Consequences

Under all alternatives and the Proposed RMP, the BLM would—

 Manage ESA-listed species consistent with recovery plans and designated critical habitat, 

including: the protection and restoration of habitat; altering the type, timing, and intensity of 

actions; and other strategies designed to recover populations of species;

 Conduct surveys for ESA-listed and candidate plant species on BLM-administered lands with 

suitable habitat;

 Maintain or restore natural processes, native species composition, and vegetation structure in 

natural communities outside of the Harvest Land Base through conducting prescribed fires, 

thinning, removal of encroaching vegetation, retention of legacy components (e.g., large 

trees, snags, and down logs), and planting or seeding native species;

 Use only species native to the plant community when re-vegetating degraded or disturbed 

areas; and

 Retain or reconnect the hydrologic flows to wetlands (see Appendix B).

The alternatives and the Proposed RMP vary in the approach to pre-disturbance surveys for and 

management of known sites of Bureau Sensitive and Survey and Manage species. The BLM would 

conduct pre-disturbance surveys for Bureau Sensitive species under the No Action alternative and 

Alternatives A, B, and C, and the Proposed RMP and would manage the species and their habitat so that 

BLM actions would not contribute to the need to list these species. Alternative D does not include any 

requirement for pre-disturbance surveys for Bureau Sensitive species, and the BLM would protect known 

Bureau Sensitive species sites in the Harvest Land Base on O&C lands only where protection would not 

conflict with sustained-yield timber production. The No Action alternative would also require predisturbance surveys for Survey and Manage species where appropriate and would manage known Survey 

and Manage sites through implementation of the Survey and Manage measures. None of the action 

alternatives or the Proposed RMP would require pre-disturbance surveys or site management for Survey 

and Manage species that are not included on the Bureau Sensitive species list.

Under Alternatives A and C, and the Proposed RMP, the BLM would take actions to contribute toward 

the recovery of ESA-listed and Special Status plants. This would involve active management to augment 

existing populations and create new populations within suitable habitat to meet recovery plan goals for 

ESA-listed species and to increase the overall resiliency of other Special Status Species to reduce the risk 

of extirpation. Under the action alternatives and the PRMP, the BLM would allocate all 3,125 acres of 

Cook’s lomatium critical habitat in the action area to District-Designated Reserves and manage those 

reserves for the species and its critical habitat. Under the No Action alternative, Cook’s lomatium critical 

habitat would occur within the Riparian Reserve and other allocations with no timber harvest. Since the 

BLM would manage Cook’s lomatium critical habitat for the primary constituent elements under the

alternatives and the Proposed RMP, there would be no management impacts to critical habitat.

Under the action alternatives and the Proposed RMP, within the dry forests outside of the Harvest Land 

Base, the BLM would apply management treatments to maintain or promote desired species composition 

within oak woodland, meadows, grasslands, and shrublands. In addition, within the Uneven-aged Timber 

Area, the BLM would retain oaks established prior to 1850. Under Alternative B, the BLM would manage 

mixed hardwood/conifer communities outside of the Harvest Land Base to maintain and enhance oak 

persistence and structure. Since oak species may be a minor component of mixed hardwood/conifer 
534 | P a g e

communities, they are likely to die off over time without management to prevent conifers from shading 

them out. Under Alternative B, the BLM would actively manage forest stands for the persistence of these 

species. Under the Proposed RMP across all land use allocations, the BLM would manage mixed 

hardwood/conifer communities to maintain and enhance oak consistent with other management direction 

for the land use allocation. The BLM would also retain oaks greater than 24” DBH, except for safety or 

operational reasons in the dry Late-Successional Reserve and the Uneven-aged Timber Area suballocation of the Harvest Land Base.

Timber Harvest and other Vegetation Management

The two ESA-listed species that occur within forest and woodland habitat, Kincaid’s lupine and Gentner’s 

fritillary, have known sites within the Harvest Land Base under the alternatives and the Proposed RMP. 

More sites of these species occur within the Harvest Land Base under all of the action alternatives and the 

Proposed RMP than under the No Action alternative. However, the BLM would conduct pre-disturbance 

surveys and apply the same conservation measures for these ESA-listed species under all alternatives and 

the Proposed RMP, regardless of land use allocation. Therefore, the species-specific protections for these 

species would avoid adverse effects from timber harvest.

Under the No Action alternative and Alternatives A, B, and C, and the Proposed RMP, timber harvest 

would not directly affect sites of Bureau Sensitive plants, including lichens and bryophytes, and their 

occupied habitat within the Harvest Land Base, because the BLM would conduct pre-disturbance surveys 

and apply conservation measures. These conservation measures would be sufficient to protect sites based 

on past implementation of these measures. The known Bureau Special Status and Bureau Strategic plant 

and fungi sites that would occur within the Harvest Land Base under each alternative and the Proposed 

RMP are listed in Table 3-112. The BLM and U.S. Forest Service have not reviewed the status of any 

species under the adaptive management process of the Survey and Manage measure since 2003. Some of 

the Survey and Manage species have had a very large increase in the number of known sites, as reflected 

in this table, and would likely be removed from Survey and Manage list under a current review.

Since fungi are difficult to detect even with multiple visits and the BLM cannot delineate their occupied 

habitat, it is possible that timber activities could affect some Bureau Sensitive fungi sites under all 

alternatives and the Proposed RMP. However, there is no basis for predicting a difference in effects 

between the No Action alternative and Alternatives A, B, and C, and the Proposed RMP. Under 

Alternative D, Bureau Sensitive plant and fungi known sites would receive protection within the Harvest 

Land Base on O&C lands only when protection measures do not conflict with sustained-yield timber 

production. In addition, since there is no provision for pre-disturbance surveys within the Harvest Land 

Base under Alternative D, potential habitat would be disturbed and previously unknown sites would be 

affected and potentially lost, contributing to the loss of genetic diversity. However, the majority of the 

decision area is allocated to reserves under Alternative D, which would limit this potential effect to the 

population as a whole.
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Table 3-112. Bureau Special Status and Bureau Strategic plant and fungi sites within the Harvest Land 

Base

Alternative

/Proposed 

RMP

Taxa Group ESA

Endangered

ESA 

Threatened

Bureau 

Sensitive

Bureau 

Strategic

Total

Species

No Action

Bryophytes - - 10 22 32

Lichens - - 110 300 410

Vascular Plants 15 1 1,287 9 1,312

Fungi - - 99 219 318

No Action Totals 15 1 1,506 550 2,072

Alt. A

Bryophytes - - 8 6 14

Lichens - - 95 80 175

Vascular Plants 25 7 490 6 528

Fungi - - 92 44 136

Alt. A Totals 25 7 687 136 853

Alt. B

Bryophytes - - 4 16 20

Lichens - - 75 184 259

Vascular Plants 54 7 904 6 971

Fungi - - 112 166 278

Alt. B Totals 54 7 1,095 372 1,528

Alt. C

Bryophytes - - 8 20 28

Lichens - - 115 201 316

Vascular Plants 57 8 893 8 966

Fungi - - 117 172 289

Alt. C Totals 57 8 1,133 401 1,599

Alt. D

Bryophytes - - 10 25 35

Lichens - - 122 224 346

Vascular Plants 46 8 1,066 7 1,127

Fungi - - 101 102 203

Alt. D Totals 46 8 1,299 358 1,711

PRMP

Bryophytes - - 6 9 15

Lichens - - 85 15 100

Vascular Plants 50 12 824 18 904

Fungi - - 98 219 317

PRMP Totals 50 12 1,013 261 1,336

There are 2,719 known Bureau Sensitive, Bureau Strategic, and Survey and Manage fungi sites within the 

decision area. Under all alternatives and the Proposed RMP, the majority of known sites of rare fungi 

would be within reserve land use allocations.

Under the No Action alternative, the BLM would continue to implement the Survey and Manage

measures to conduct pre-disturbance surveys and protect known sites for the Survey and Manage species. 

Most Survey and Manage plant and fungi species would have sufficient habitat to maintain stable 

populations under the No Action alternative (USDA FS and USDI BLM 2000). In addition, Mature and 

Structurally-complex forest habitats for Survey and Manage plant and fungi species would increase under 

the No Action alternative in the decision area.
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Under all action alternatives and the Proposed RMP, species that are Survey and Manage and not 

included on the Bureau Sensitive species list would receive no specific protections. The number of 

unprotected sites would vary: Alternative A would have the fewest sites within the Harvest Land Base, 

and Alternative C would have the most (Table 3-113). Unless these sites co-occur with Bureau Sensitive 

species, timber harvest would affect these sites.

Table 3-113. Survey and Manage plant and fungi species sites within the Harvest Land Base that are not 

also Bureau Sensitive/Bureau Strategic

Alternative/

Proposed 

RMP

Taxa Group

Survey and Manage

Species That Are

Not Also Sensitive 

or Strategic

(Number of Sites)

Known 

BLM Sites

Within

HLB

(Percent)

No Action

Bryophytes 3 3%

Lichens 1,133 40%

Vascular Plants 277 39%

Fungi 2,006 47%

No Action Totals 3,419 43%

Alt. A

Bryophytes 1 1%

Lichens 401 14%

Vascular Plants 60 9%

Fungi 596 14%

Alt. A Totals 1,058 13%

Alt. B

Bryophytes 3 3%

Lichens 709 25%

Vascular Plants 249 35%

Fungi 1,079 25%

Alt. B Totals 2,040 26%

Alt. C

Bryophytes 9 8%

Lichens 1,026 37%

Vascular Plants 220 31%

Fungi 1,434 34%

Alt. C Totals 2,689 34%

Alt. D

Bryophytes 6 5%

Lichens 826 30%

Vascular Plants 228 32%

Fungi 929 22%

Alt. D Totals 1,989 25%

PRMP

Bryophytes 3 3%

Lichens 717 26%

Vascular Plants 203 29%

Fungi 1,228 29%

PRMP Totals 2,151 27%

There is incomplete and unavailable information relevant to the effects of the action alternatives and the 

Proposed RMP on Survey and Manage species. With complete and species-specific survey information on 

the location of habitat and species sites for all Survey and Manage species, the BLM would be able to 

analyze the effects of all alternatives and the Proposed RMP on Survey and Manage species and compare 
537 | P a g e

those effects to the No Action alternative, which would continue to implement the Survey and Manage

measure. However, the BLM lacks complete and species-specific survey information for most Survey and 

Manage species (USDA FS and USDI BLM 2004, pp. 108–109). It would be exorbitantly expensive and 

time-consuming to conduct random surveys across the decision area for all Survey and Manage species. 

Consistent with Council on Environmental NEPA regulations at 43 CFR 1502.22, this analysis 

summarizes the information that is currently available on the effects of the alternatives and the Proposed 

RMP on Survey and Manage species. The 2004 Final SEIS to Remove or Modify the Survey and Manage

Mitigation Measure Standards and Guidelines (USDA FS and USDI BLM 2004, pp. 141–183) and the 

2007 Final Supplement to the 2004 SEIS (USDA FS and USDI BLM 2007, pp. 162–244) analyzed the 

removal of Survey and Manage measures for known site management and pre-disturbance surveys. The 

species descriptions and discussions of known site management and pre-disturbance surveys from those 

analyses are incorporated here by reference. The U.S. District Court in Conservation Northwest et al. v. 

Rey et al. (Case No. C08-1067-JCC) found that the analysis of effects to species in the 2004 Final SEIS

and the 2007 Final SEIS was insufficient to support the conclusion that the Survey and Manage measure 

was no longer necessary to meet the goals of the Northwest Forest Plan. The discussions of the 2004 SEIS 

and 2007 SEIS are incorporated by reference here only to the extent those portions of the analyses were 

not found invalid by the court. Nevertheless, the information in the 2004 SEIS and 2007 SEIS does 

present analysis based on the incomplete survey information available that concludes that most Survey 

and Manage species would have sufficient habitat to support stable populations under the No Action 

alternative without the Survey and Manage measure.

Even in the absence of the Survey and Manage measure, habitat and sites of species that fall within the 

reserve system would receive some protection. Not all sites within reserve land use allocations would 

necessarily be protected by buffers comparable to the No Action alternative. However, management 

actions in reserves could occur within these sites, but there would be a minimal effect to the species based 

on the type and intensity of allowable treatments. Under all action alternatives and the Proposed RMP, 

management direction in reserves would largely limit stand treatments to thinning to improve habitat 

conditions and fuels treatments to reduce the risk of uncharacteristic wildfire, and would generally 

preclude stand treatments that would remove or degrade Mature and Structurally-complex habitat 

(Appendix B). Compared to the No Action alternative, all action alternatives and the Proposed RMP

allocate more acres to the Late-Successional Reserve, which the Northwest Forest Plan expected to 

contribute to meeting the needs of late-successional and old-growth related species (USDA Forest Service 

and USDI BLM 2000, pp. 201–202). To the extent that the No Action alternative without the Survey and 

Manage measure would provide sufficient habitat for Survey and Manage species, as analyzed in the 2004 

SEIS, the action alternatives and the Proposed RMP would provide more habitat within the LateSuccessional Reserve.

The Survey and Manage species are species associated with “late-successional and old-growth forests”

(USDA FS and USDI BLM 2000, p. 8; USDA FS and USDI BLM 2004, p. 30). To the extent that older 

and more structurally-complex multi-layered conifer forests as defined in the action alternatives and the 

Proposed RMP encompass the ‘late-successional and old-growth forests’ that provide habitat for Survey 

and Manage species, all action alternatives and the Proposed RMP reserve such forests from timber 

harvest within the Late-Successional Reserve. Under all action alternatives and the Proposed RMP, there 

would be no timber harvest of older and more structurally-complex multi-layered conifer forests, although 

each alternative and the Proposed RMP use a different definition to identify older and more structurallycomplex multi-layered conifer stands. Therefore, all of the action alternatives and the Proposed RMP, in 

contrast to the No Action alternative, would protect from timber harvest the forest conditions with which 

the Survey and Manage species are most closely associated.

In addition to reserving existing older and more structurally-complex multi-layered conifer forests, the 

acreage of Mature and Structurally-Complex forest (which is a broader category) in the decision area 
538 | P a g e

would increase under all alternatives and the Proposed RMP. Therefore, the amount of habitat for Survey 

and Manage plant and fungi species would increase under all alternatives and the Proposed RMP.

The current Survey and Manage list (USDI BLM 2014) includes 247 plant and fungi species. However, 

only 143 of these species have documented occurrences in the decision area. Many of the remaining 104 

species are unlikely to occur on BLM-administered lands because suitable habitat is not present. Table N3 in Appendix N includes all 247 Survey and Manage plant and fungi species, whether they are 

documented on BLM-administered lands, and whether they are also on the Bureau Sensitive or Bureau 

Strategic lists.

In the 2007 SEIS, the BLM evaluated whether there would be sufficient habitat available for each Survey 

and Manage species to maintain the species if the Survey and Manage mitigation measure was removed 

from the existing Resource Management Plans (USDA Forest Service and USDI BLM, 2007). Table N-3

in Appendix N indicates the plant and fungi species that the BLM determined in the 2007 analysis would 

have either insufficient habitat due to management or there was insufficient information to determine an 

outcome. These include 46 species – 28 fungi, 6 bryophytes, and 12 lichens. Only 35 of these species 

occur in the decision area, of which 5 are Bureau Sensitive and 30 are Bureau Strategic. For the 35 

species that occur on the decision area, the BLM evaluated the percentage of known sites that would 

occur within a reserve allocation under each alternative and the Proposed RMP. Except for Sowerbyella 

rhenana in Alternative C and Stenocybe clavata in Alternative D, all of the 35 species would have an 

equal number or more known sites in a reserve allocation than under the No Action alternative (Table 3-

114). As described above, habitat and sites of species that fall within the reserve system under the action 

alternatives and Proposed RMP would generally be protected. Overall, 45 percent of known sites of these 

35 species would fall within reserve allocations under the No Action alternative, the fewest of any 

alternative and the Proposed RMP.85 Under the Proposed RMP, 88 percent of known sites of these species 

would fall within reserve allocations, more than any alternative. One species, Tholurna dissimilis, is 

known from only two sites on BLM-administered lands, both of which would occur within the Harvest 

Land Base under all alternatives and the Proposed RMP. Given the difficulties of comparing directly the 

effects of the alternatives and the Proposed RMP to the outcomes described in the 2007 SEIS and the very 

few sites of Tholurna dissimilis in the decision area, it is not possible to make any conclusion about effect 

of allocating two known sites on BLM-administered lands to the Harvest Land Base. More generally, as 

with all Survey and Manage species, all action alternatives and the Proposed RMP, would protect from 

timber harvest the forest conditions with which the Survey and Manage species are most closely 

associated.

 

85 Under the No Action alternative, sites not in reserve allocations would be protected consistent with the Survey and 

Manage measure. To the extent that the percentage of sites in reserve allocations indicates the extent of habitat for 

these species in reserve allocations, the No Action alternative would provide less habitat within reserve allocations 

than the action alternatives or the Proposed RMP.
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Table 3-114. Percent of known BLM sites within reserve allocations under the alternatives and the 

Proposed RMP for Survey and Manage species found to have uncertain outcomes in the 2004 FSEIS

Species No Action

(Percent)

Alt. A

(Percent)

Alt. B

(Percent)

Alt. C

(Percent)

Alt. D

(Percent)

PRMP

(Percent)

Albatrellus ellisii 38% 100% 48% 50% 86% 49%

Calicium adaequatum 100% 100% 100% 100% 100% 100%

Calicium adspersum 100% 100% 100% 100% 100% 100%

Clavariadelphus ligula 16% 65% 38% 41% 48% 43%

Clavariadelphus sachalinensis 26% 94% 78% 88% 92% 82%

Collema nigrescens 75% 96% 86% 84% 82% 90%

Cudonia monticola 50% 77% 98% 98% 77% 98%

Gomphus kauffmanii 59% 100% 67% 63% 82% 80%

Gyromitra californica 18% 45% 27% 18% 36% 27%

Kurzia makinoana 100% 100% 100% 100% 100% 100%

Microcalicium arenarium 33% 67% 100% 100% 100% 100%

Nephroma occultum 37% 100% 98% 98% 98% 98%

Phaeocollybia californica 50% 82% 74% 66% 72% 77%

Phaeocollybia dissiliens 38% 81% 86% 48% 76% 90%

Phaeocollybia fallax 48% 79% 86% 70% 73% 86%

Phaeocollybia piceae 41% 79% 84% 65% 69% 89%

Phaeocollybia pseudofestiva 36% 89% 88% 66% 83% 91%

Phaeocollybia scatesiae 68% 81% 81% 65% 84% 83%

Phaeocollybia sipei 50% 82% 89% 52% 72% 91%

Phaeocollybia spadicea 50% 80% 81% 62% 67% 84%

Polyozellus multiplex 100% 100% 100% 100% 100% 100%

Pseudocyphellaria rainierensis 90% 100% 100% 98% 100% 100%

Ramaria amyloidea 100% 100% 100% 100% 100% 100%

Ramaria araiospora 42% 80% 76% 60% 83% 84%

Ramaria aurantiisiccescens 31% 74% 68% 57% 86% 84%

Ramaria cyaneigranosa 34% 72% 65% 55% 80% 80%

Ramaria largentii 50% 100% 100% 100% 100% 100%

Ramaria rubrievanescens 36% 78% 76% 71% 84% 87%

Ramaria stuntzii 40% 76% 71% 53% 75% 79%

Sarcodon fuscoindicus 33% 67% 43% 43% 71% 43%

Sowerbyella rhenana 48% 63% 48% 36% 58% 54%

Sparassis crispa 47% 84% 98% 84% 79% 99%

Stenocybe clavata 96% 97% 98% 98% 78% 98%

Tholurna dissimilis - - - - - -

Overall 45% 82% 83% 69% 78% 88%

In summary, all action alternatives and the Proposed RMP would remove the Survey and Manage

measure that requires pre-disturbance surveys and protection of known sites. There is incomplete and 

unavailable information relevant to the effects of the action alternatives and the Proposed RMP on Survey 
540 | P a g e

and Manage species. The 2007 SEIS provides an incomplete analysis, in that survey and species data for 

Survey and Manage species was (and remains) incomplete, and in that the 2007 SEIS did not include 

information on species and sites that has since been identified over the past decade. Nevertheless, the 

analysis in the 2007 SEIS supports the conclusion that most Survey and Manage species would have 

sufficient habitat to support stable populations under the No Action alternative without the Survey and 

Manage measure. 

It is not possible to compare directly the effects of the alternatives and the Proposed RMP to the outcomes 

described in the 2007 SEIS. The determinations about species outcomes in the 2007 SEIS were based on 

the evaluation of experts and were more qualitative than quantitative in nature. These qualitative expert 

opinions were based on assumptions of continuing application of the land use allocations of the 

Northwest Forest Plan, and are therefore only directly applicable to the No Action alternative. Finally, the 

conclusion in the 2007 SEIS of “insufficient habitat to support stable populations in a portion of the 

Northwest Forest Plan area” did not specify the areas of “insufficient habitat” beyond broad geographic 

areas. Thus, these general and qualitative conclusions are difficult to re-evaluate in light of these 

alternatives and the Proposed RMP, which would alter only management on BLM-administered lands in 

Oregon (USDA FS and USDI BLM 2007, pp. 118–119). 

Furthermore, the threshold determination of whether there is sufficient habitat to support stable 

populations of the Survey and Manage species is not necessary to provide a “hard look” in this Proposed 

RMP/Final EIS at the environmental effects of the alternatives and the Proposed RMP. The determination 

related to stable populations is tied to the species viability goal of the Northwest Forest Plan, which is not 

part of the purpose for this RMP revision. The Survey and Manage measures were identified in the Final 

Supplemental EIS for the Northwest Forest Plan as a potential mitigation measure to increase the 

likelihood of achieving “viable populations, well-distributed across their current range, of species known 

(or reasonably expected) to be associated with old-growth forest conditions” (USDA FS and USDI BLM, 

1994, p. 3&4-129) – a goal which was founded on a U.S. Forest Service planning regulation which, as 

explained above, did not and does not apply to the BLM. Finally, to the extent that the Survey and 

Manage measures were intended to prevent disruptions to sustained-yield timber production that would 

result from future listing of species under the ESA, the Survey and Manage measures are unnecessary 

under the action alternatives and the Proposed RMP (see the Relationship of the RMPs to Other Plans and 

Programs section of Chapter 1).

Although it is not possible to compare directly the effects of the alternatives and the Proposed RMP on 

Survey and Manage species to the outcomes described in the 2007 SEIS, it is possible to evaluate where 

known sites occur and how habitat would change over time under the alternatives and the Proposed RMP. 

For the 35 species that occur within the decision area and that the 2007 SEIS concluded would have either 

insufficient habitat due to management or there was insufficient information to determine an outcome, 88 

percent of known sites would fall within the reserve land use allocations under the Proposed RMP, and all 

action alternatives would have a higher percentage of known sites in the reserve land use allocations than 

the No Action alternative. All action alternatives and the Proposed RMP allocate more acres to the LateSuccessional Reserve than the No Action alternative, protect older and more structurally-complex multilayered conifer forests, and result in an increase in Mature and Structurally-complex forest. As a result (as 

can best be determined given the incomplete information available to the BLM), all action alternatives 

and the Proposed RMP would protect most existing habitat for Survey and Manage species, would protect 

most known sites within the reserve allocations, and would result in an increase in the amount of habitat 

for Survey and Manage species.

A sub-group of more than 25 lichen, bryophyte, and fungi species (including Bureau Special Status 

Species and Survey and Manage species that are not Bureau Special Status Species) is associated with 

habitat conditions and biological legacies (e.g., green trees, coarse wood, and snags) of mature and 
541 | P a g e

structurally-complex forests. Important habitat components include coarse wood, snags, and specific host 

species. In general, the risk to these species would increase as the level of timber harvest activities would 

increase, biological legacies would be lost during harvest, and timber harvest would reduce interior 

habitat conditions in the Harvest Land Base over time.

The overall acreage of timber harvest during the first decade would be largest under Alternative C, with 

178,429 acres of total timber harvest, and only slightly lower under Alternative B, with 173,633 acres of 

timber harvest (Table 3-115). Alternative D, the No Action alternative, and the Proposed RMP would 

have substantially lower acreage of total timber harvest, with 139,557 acres, 157,041 acres, and 155,635 

acres, respectively. Alternative A would have the lowest acreage of total timber harvest, with 98,113

acres in the first decade. Included in the totals for Alternative A and the Proposed RMP are acres of 

thinning without timber removal, which would be much less likely to have adverse effects on rare plant 

and fungi habitat than other timber harvest methods, although it is not possible to quantify that difference 

in this analysis. Thinning without timber removal would include 12,957 acres under Alternative A and 

2,215 acres under the Proposed RMP.

Table 3-115. Total acres of timber harvest in the first decade (2013–2023).

Harvest Type No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

PRMP 

(Acres)

Clearcut - 42,200 - 83,691 - -

Salvage 2,539 884 2,642 3,587 1,640 2,258

Selection - 26,757 68,580 45,403 103,059 58,641

Thinning 110,570 15,315 71,700 45,748 14,901 61,406

Thinning without 

Timber Removal - 12,957 - - - 2,215

Variable Retention 

Harvest 43,932 - 30,711 - 19,957 31,115

Timber Harvest Totals 157,041 98,113 173,633 178,429 139,557 155,635

Under Alternatives A and C, forest management would include clearcuts (i.e., regeneration harvest with 

no retention) in the High Intensity Timber Area, and comprise 1.7 percent and 3.4 percent, respectively, 

of the decision area. Within the first decade, almost twice as many acres would be clearcut in Alternative 

C than in Alternative A (Table 3-115). Early successional Bureau Special Status species (e.g., wayside 

aster and tall bugbane) would benefit from the disturbance if they occur within colonization distance of 

the clearcut. However, the BLM would reforest these clearcuts after harvest, typically within five years of 

harvest, limiting the duration of any habitat benefit to early successional species on each harvest unit.

The impacts from salvage harvest would generally be the same as harvest of live trees. However, since 

the BLM would likely not be able to conduct pre-disturbance surveys for salvage harvest following 

disturbances such as wildfire, undiscovered sites would likely be affected, making the effects of salvage 

similar among all alternatives and the Proposed RMP. Salvage harvest could remove or damage live trees 

that are a refuge for rare plant and fungi species. Salvage harvest would primarily affect plant and fungi 

species in conifer and mixed evergreen forests, riparian and aquatic, serpentine areas, and oak and 

hardwood habitats. In all alternatives and the Proposed RMP, salvage would take place in the Harvest 

Land Base after a high- or moderate-severity wildfire event. In Alternatives A, B, and D, and the 

Proposed RMP, salvage would not take place in the Late-Successional Reserve, except for resource 

protection and safety objectives. Only in Alternative C would timber salvage occur in the LateSuccessional Reserve for economic objectives. While it is not possible to predict the locations and amount 

of salvage harvest that would occur over the next 10 years, the BLM forecasts that salvage harvest would 
542 | P a g e

occur on a relatively small acreage under all alternatives and the Proposed RMP, approximately 1–2 

percent of the total acres of timber harvest.

The No Action alternative and Alternative C would reduce habitat quality for rare plants and fungi 

because of fertilization. The No Action alternative would include almost twice the acreage of fertilization 

as Alternative C. The No Action alternative would reduce habitat quality for rare plants and fungi on 

12,052 acres in the first decade, and Alternative C would reduce habitat quality on 6,854 acres. Most of 

the fertilization acres would occur within very young stands that are within Early Successional or Stand 

Establishment structural stages. However, the No Action alternative would include a small acreage of 

fertilization within Mature and Structurally-complex stands in the first decade, increasing the likelihood 

of reducing habitat quality for rare plants and fungi associated with that habitat. Alternatives A, B, and D

would not include any fertilization and thus would not reduce habitat quality for rare plants and fungi.

The Proposed RMP would allow for the manual application of fertilizers where necessary to enhance 

vigor and growth of desired vegetation within the Harvest Land Base; however, any fertilization would 

have to be compatible with management direction in the Proposed RMP to manage Bureau Special Status 

Species to maintain and enhance their persistence and to maintain natural species composition. As a 

result, it is unlikely that fertilization would reduce habitat quality for rare plants and fungi under the 

Proposed RMP, especially since manual application would limit the acreage involved.

Under all alternatives and the Proposed RMP, a majority of the BLM-administered lands would be 

allocated to reserves, where Mature and Structurally-complex stands would be retained and additional 

habitat would develop. All action alternatives and the Proposed RMP allocate more acres to LateSuccessional Reserve than the No Action alternative, which would benefit rare plants and fungi 

associated with Mature and Structurally-complex stands. The acreage of Structurally-complex stands

would increase under all alternatives and the Proposed RMP, as would the acreage of stands older than 

120 years. Within the Harvest Land Base, the abundance of Structurally-complex stands would increase 

substantially under the No Action alternative, Alternatives B and D, and the Proposed RMP, with the 

largest proportional increase in Alternative D. Additionally, a substantial amount of forest stands with 

biological legacies would remain on BLM-administered lands in the Harvest Land Base, except for the 

High Intensity Timber Areas under Alternatives A and C. The abundance of Structurally-complex stands

would not increase within the Harvest Land Base under Alternatives A and C.

The acreage of potential fungi habitat (i.e., Mature Multi-layered Canopy and Structurally-complex 

stands) within the Harvest Land Base would vary (Table 3-116). Alternative A would have the fewest 

potential fungi habitat acres within the Harvest Land Base because most of this habitat would be allocated 

to reserves. The Proposed RMP would have the second lowest acreage of potential fungi habitat within 

the Harvest Land Base. The No Action alternative would have the largest acreage of potential fungi 

habitat within the Harvest Land Base; however, most of this habitat would be subject to the Survey and 

Manage equivalent-effort survey requirement, and the BLM would protect new sites. All of the Sensitive 

and Strategic fungi sites within the Harvest Land Base are also Survey and Manage species. Of the action 

alternatives and the Proposed RMP, Alternative C would have the largest number of potential fungi 

habitat acres within the Harvest Land Base, followed by Alternatives D and B. The BLM would conduct 

pre-disturbance surveys under Alternatives A, B, and C, and the Proposed RMP for Special Status 

Species, and the BLM would provide conservation measures for new sites found. As noted above, the 

effectiveness of fungi surveys is limited, because fungi are difficult to detect even with multiple visits.

The BLM would not conduct surveys under Alternative D, and undetected sites would be affected by 

timber harvest.
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Table 3-116. Bureau Special Status fungi potential habitat within the Harvest Land Base

Alternative/

Proposed RMP

Fungi Habitat

within the Harvest Land Base

(Acres)

No Action 255,125

Alt. A 40,140

Alt. B 145,081

Alt. C 156,219

Alt. D 150,103

PRMP 91,428

Designation of Reserve Allocations

As noted earlier, all of the action alternatives and the Proposed RMP would designate more acres of land 

to reserve allocations (e.g., Late-Successional Reserve and Riparian Reserve). For comparison, Table 3-

117 lists the number of known Bureau Special Status vascular plant sites within the Late-Successional 

Reserve and Riparian Reserve. The fewest number of sites in reserves would be in the No Action 

alternative, and the largest number would be in Alternative A. The Proposed RMP and Alternatives C and 

D would have similar numbers of sites in reserves.

Where Gentner’s fritillary and Kincaid’s lupine occur within forested communities, they are generally on 

the edge or in openings. Alternative A would include the largest number of sites for Gentner’s fritillary 

and Alternatives B, C, and D, and the Proposed RMP for the largest number of sites for Kincaid’s lupine.

Table 3-117. Bureau Special Status vascular plant sites within reserve allocations

Alternative/

Proposed RMP

Bureau Special Status

Vascular Plants

(Known Sites in 

Reserves)

Gentner’s Fritillary

(Known Sites in 

Reserves)

Kincaid’s Lupine

(Known Sites in 

Reserves)

No Action 1,679 40 7

Alt. A 2,758 95 8

Alt. B 1960 41 10

Alt. C 2,138 50 10

Alt. D 2,108 65 10

PRMP 2,128 46 10

While the overall management objectives for reserves are consistent across action alternatives and the 

Proposed RMP, the management direction varies. The No Action alternative would allow for 

management activities within reserves to promote recovery of ESA-listed species. The Proposed RMP 

would conduct integrated vegetation management to restore and maintain habitat for Bureau Special 

Status Species. The action alternatives would not conduct integrated vegetation management to restore 

and maintain habitat for Bureau Special Status Species within reserve allocations. Plant species that 

require open growing conditions would likely decline in the reserve allocations under the action 

alternatives. Under the No Action alternative, the BLM would only manage habitat for ESA-listed species 

within reserves, and Bureau Sensitive plant species would decline in the reserve allocations. The 
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Proposed RMP would maintain and enhance habitat for Bureau Special Status plant species within reserve 

allocations.

Livestock Grazing

Under the No Action alternative, livestock grazing would be available on 495,190 acres in the Coos Bay 

District, the Klamath Falls Field Office, and the Medford District. However, 140,380 acres are currently 

vacant and have not been subject to livestock grazing for several years. The vacant allotments would 

remain available for livestock grazing under the No Action alternative, and livestock grazing could occur 

in these areas in the future.

Alternatives A, B, and C, and the Proposed RMP would close the vacant allotments to livestock grazing, 

but keep all active allotments open to livestock grazing. Since these vacant allotments are not currently 

grazed, there would be no immediate difference in effects from the No Action alternative. However, 

closing the vacant allotments would preclude potential future livestock grazing impacts to rare plants and 

fungi.

Under the No Action alternative, Alternatives A, B, and C, and the Proposed RMP, livestock grazing

would continue in active allotments. There are 571 Bureau Special Status plant and fungi sites within 

active livestock grazing allotments, including Gentner’s fritillary, 35 Bureau Sensitive vascular plants, 2 

Bureau Sensitive bryophytes, and 3 Bureau Sensitive fungi. The large majority of these sites (98 percent) 

are vascular plants. As described in the Background section, livestock grazing can have both positive and 

negative effects to vascular plants. As described in the Livestock Grazing section of this chapter, the 

BLM conducts periodic rangeland health assessments. The BLM has found that 12 allotments in the 

decision area are not meeting rangeland health standards due to livestock grazing. Of the 12 allotments, 

there are 5 that contain Bureau Sensitive vascular plant sites, as shown in Table 3-118.

Table 3-118. Bureau Sensitive plants within allotments not meeting rangeland health standards due to 

livestock grazing

District/

Field Office Allotment Sensitive Plants within Allotment

Klamath Falls Dixie Limnanthes floccosa ssp. bellingeriana

Medford

Brownsboro Park Plagiobothrys greenei, Plagiobothrys austiniae, Ranunculus 

austrooreganus

Canal Ranunculus austrooreganus

Conde Creek Scirpus pendulus, Nemocladus capillaris, Hackelia bella

Cove Creek Limnanthes floccosa ssp. bellingeriana, Poa rhizomata

BLM botanists have observed livestock directly uprooting and trampling individuals of Limnanthes 

floccosa ssp. Bellingeriana and wallowing in their vernal pool habitat (J. Blanchard, 2015, personal 

communication). Conversely, botanists have noted an increase in invasive competitive plants, such as 

yellow starthistle and North Africa grass, in habitat for Limnanthes floccosa ssp. bellingeriana in 

response to the removal of livestock. Due to a wildfire in 2014, the Dixie allotment is unavailable to 

livestock grazing for one to two years. There are fences within the allotment to protect meadows and 

springs from livestock grazing. Under the No Action alternative, Alternatives A, B, and C, and the 

Proposed RMP, the BLM would adjust the grazing season of use to minimize direct impacts to the species 

from livestock.
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As is true for most allotments, the livestock grazing effects on plants are highly variable across the 

Brownsboro Park allotment. Botanists have periodically monitored the allotment and found that, while the 

grasslands are dominated by nonnative grasses, particularly medusahead and yellow starthistle, the three 

Bureau Sensitive plant species within the allotment have not been directly impacted by livestock (M. 

Wineteer, 2015, personal communication). Botanists have not observed any livestock grazing impacts on 

the Bureau Sensitive plant species within the Canal, Conde Creek, or Cove Creek allotments (B. Wender, 

2015, personal communication).

Currently, 62 sites of Gentner’s fritillary, ranging in size from 1 plant to approximately 30 plants, occur in 

8 active allotments. Another 55 Gentner’s fritillary sites occur within 8 vacant allotments. Despite the 

presence of this species within active allotments in the No Action alternative, Alternatives A, B, and C,

and the Proposed RMP, there would be no direct negative impacts to this species from livestock grazing

because there has been no evidence that livestock eat Gentner’s fritillary or cause measurable trampling 

impacts (M. Wineteer, BLM, personal communication, 2014). Livestock tend to concentrate in areas with 

water, while Gentner’s fritillary generally occurs on steeper slopes outside of riparian areas.

There is little research on the effects of livestock grazing on fungi in the planning area. It is likely that 

livestock may trample and even consume sporophytes, but these impacts would generally be minor and 

would not affect the long-term viability of fungi since most of the hyphal mat is underground. Livestock 

may trample bryophytes that grow on the soil surface. One of the Bureau Sensitive bryophytes that occurs 

within an active grazing allotment, Meesia uliginosa, grows on the soil surface in wetland habitat. The 

BLM has not observed any livestock grazing impacts to this species.

Alternative D would close all current active and vacant allotments. Elimination of livestock grazing under 

Alternative D would have both positive and negative effects for the known Bureau Special Status plant 

and fungi species that occur within active allotments. Elimination of livestock grazing would reduce 

direct consumption of these species and trampling, but would also result in increased competition for 

resources from non-native plant species, including noxious weeds, and have an increased accumulation of 

fuels, increasing the risk of wildfire. The specific effects of the elimination of livestock grazing under 

Alternative D on each of the Special Status plant and fungi species would depend on species-specific and 

site-specific factors. For example, almost 99 percent of the currently active allotments with Gentner’s 

fritillary locations are in the Improve management category, meaning that the current resource condition 

does not meet Rangeland Standards and Guidelines. While livestock do not directly affect Gentner’s 

fritillary, removing livestock might improve adjacent habitat for the species and allow for potential 

expansion. Nevertheless, given the absence of evidence that livestock grazing is affecting Gentner’s 

fritillary, there are no reasonably foreseeable differences in effects on Gentner’s fritillary of eliminating 

livestock grazing under Alternative D.

ACEC Designation

Under the No Action alternative, the BLM would maintain the designation of 50,073 acres of ACECs. In 

addition, under the No Action alternative, the BLM would continue to provide interim management to 

protect relevant and important values on 54,310 acres of potential ACECs. As a result, the No Action 

alternative would effectively manage 104,383 acres to maintain relevant and important values and thereby 

protect rare plant and fungi species. Alternatives A and D would designate the most acres of ACECs,

94,545 and 94,376 acres, respectively. The Proposed RMP would designate 93,515 acres. Alternatives B 

and C would designate the fewest acres: 88,448 and 87,044 acres, respectively (see the ACEC section in 

this chapter).

Within the 104,383 acres of existing designated and potential ACECs, there are approximately 650 known 

sites of Bureau Special Status plants and fungi within these areas and 284 sites of Survey and Manage
546 | P a g e

species. However, not all acres of ACECs contain Bureau Special Status plants and fungi or botanical 

Survey and Manage species. Additionally, management direction for land use allocations other than the 

Harvest Land Base would effectively protect these existing sites whether or not the ACEC designation 

were applied under any alternative or the Proposed RMP. As such, potential loss of sites for Bureau

Special Status plants and fungi or botanical Survey and Manage species would only occur where an 

ACEC designation was not applied due to conflicts with sustained-yield timber harvest on O&C lands. 

The action alternatives would present potential loss of sites ranging from none under Alternative D, one 

under Alternative A, six under Alternative B, and nine under Alternative C. Under the Proposed RMP, no 

sites occur within ACECs that are not designated due to conflict with sustained-yield timber production, 

and no sites would potentially be lost from any ACECs not being designated.

As a result, Alternative D and the Proposed RMP would have similar effects and provide the most benefit 

to rare plant and fungi species through ACEC designation. Alternative A would designate more acres as 

ACECs than the Proposed RMP, but one site would be at risk for potential s and benefits to rare plant and 

fungi species would be somewhat less than Alternative D and the Proposed RMP. Alternatives B and C 

would have similar effects in the amount of acres not designated as ACECs and provide the least benefit 

to rare plant and fungi species through ACEC designation, with Alternative B providing slightly more 

protection than Alternative C. Even though the No Action alternative would designate the fewest acres of 

ACECs, it would provide the greatest benefit to rare plant and fungi species because of the protection 

provided by interim management of potential ACECs.

Road Construction

As described earlier, road construction directly removes vegetation, fragments habitat, increases water 

runoff and erosion immediately adjacent to the road, provides a conduit for noxious and invasive plants to 

spread, and provides increased access by humans and wildlife that may further affect habitat for rare 

plants and fungi. New road construction would generally avoid directly affecting rare plant and fungi 

sites, because the BLM would conduct surveys prior to construction and would avoid or minimize any 

site found if alternate routes are available. However, road construction could directly affect some sites 

and indirectly affect sites in proximity to roads by increased access and spread of noxious and invasive 

vegetation. Although it is not possible at this scale of analysis with the data available to determine 

whether the estimated new road construction under each alternative and the Proposed RMP would occur 

within potential or occupied habitat for rare plants and fungi, the acreage of estimated habitat removed or 

disturbed by road construction provides a relative evaluation of the effects of road construction on rare 

plants and fungi. Alternative C would result in the largest mileage of new road construction in the first 

decade (Table 3-119). This mileage of new road construction would result in the removal or disturbance 

of 3,819 acres of habitat. Alternative D would result in the least mileage of new road construction in the 

first decade and 1,318 acres of habitat removed or disturbed. The Proposed RMP would potentially 

remove or disturb more habitat acres than Alternatives D and A, but less than the No Action alternative 

and Alternatives B and C.
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Table 3-119. Road construction miles for the first 10 years of implementation

Alternative/

Proposed RMP

Total New

Road Construction

(Miles)

Habitat

Removed or Disturbed

(Acres)

No Action 637 3,481

Alt. A 299 1,642

Alt. B 531 2,897

Alt. C 699 3,819

Alt. D 240 1,318

PRMP 437 2,391

Public Motorized Access Designations

Under the No Action alternative, approximately 85,000 acres (3.3 percent) of the decision area would 

remain designated as closed for public motorized access, and approximately 330,400 acres (12.8 percent) 

would remain designated as open for public motorized access. On the remaining 83.9 percent, public 

motorized vehicle use would continue to be limited to existing or designated roads and trails. On some 

portion of the 330,400 acres designated as open for public motorized access, habitat removal and 

disturbance has been occurring and would continue to occur. It is not possible for the BLM to determine 

at this scale of analysis with the data available how much of the 330,400 acres designated as open for 

public motorized access are actually experiencing habitat removal or disturbance or would in the future. 

However, within areas designated as open for public motorized access, such effects could occur 

throughout the open area without future analysis or decision-making by the BLM.

Under all action alternatives and the Proposed RMP, no areas would be designated as open for public 

motorized access. The BLM would designate the entirety of the decision area as either closed or limited 

for public motorized access. As such, there would be no additional habitat removal or disturbance from 

public motorized vehicle use measurable at this scale of analysis with the data available under any of the 

action alternatives or the Proposed RMP.

Mineral Development

The No Action alternative would maintain the closure of the largest acreage to salable mineral material 

disposal, at 319,430 acres closed. The action alternatives and the Proposed RMP would close from 

232,408 acres under Alternative A to 249,241 acres under the Proposed RMP. Although there is no basis 

for evaluating whether closed areas would have been developed if not closed and whether such areas 

would have included rare plants and fungi, these acreages provide an approximate evaluation of the level 

of protection for rare plants from the effects of salable mineral material disposal under the alternatives

and the Proposed RMP.

Under the No Action alternative, 98,400 acres would remain withdrawn from locatable mineral entry. All 

of the action alternatives and the Proposed RMP would recommend for withdrawal more than double the 

acreage of the existing withdrawals, totaling 266,472 acres under Alternative B, 306,878 acres under 

Alternative D, and 307,312 acres under the Proposed RMP. Although there is no basis for evaluating 

whether these areas recommended for withdrawal would have been developed if not withdrawn and 

whether such areas would have included rare plants and fungi, these acreages provide an approximate 

evaluation of the level of protection for rare plants from the effects of locatable mineral development 

under the alternatives and the Proposed RMP.
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There are 1,292 active mining claims in the decision area, the majority of which occur within the Medford 

District, which has a disproportionate percentage of rare plant and fungi sites. There is one pending Plan 

of Operation in the French Flat ACEC in the Medford District that would provide protection for Cook’s 

lomatium. The BLM does not have information on whether there are mining claims on areas that include 

Bureau Sensitive plant sites. 

Summary

The No Action alternative would allocate the smallest Late-Successional Reserve, not reserve all 

Structurally-complex forest, result in the second-largest acreage of timber harvest, result in the secondlargest mileage of new road construction, and designate areas as open for public motorized access. 

However, the No Action alternative would require surveys and protection of sites of Survey and Manage

species. In total, the No Action alternative would provide specific species protections and would result in 

an increase in habitat for most rare plant and fungi species, but would provide less benefit overall than 

most of the action alternatives and the Proposed RMP.

Alternative A would allocate the largest Late-Successional Reserve and would result in the fewest overall 

acres of habitat disturbance. However, timber harvest in the moist forest would include clear-cutting, 

which would not provide habitat benefits for rare plant and fungi species associated with Mature and 

Structurally-complex stands.

Alternative B would allocate the second-largest Late-Successional Reserve and would result in the thirdlargest amount of habitat disturbance.

Alternative C would result in the most acres of habitat disturbance, and timber harvest in the moist forest 

would include clear-cutting, which would not provide habitat benefits for rare plant and fungi species 

associated with Mature and Structurally-complex stands. Alternative C would result in the least increase 

in Mature and Structurally-complex stands over time.

Alternative D would result in the second-fewest overall acres of habitat disturbance and would result in 

the largest increase in Mature and Structurally-complex stands over time. However, Alternative D would 

provide less site protection for rare plants and fungi in the Harvest Land Base than the other alternatives 

and the Proposed RMP.

The Proposed RMP would result in the third-fewest overall acres of habitat disturbance. The Proposed 

RMP would provide specifically for the maintenance and enhancement of Bureau Special Status plant 

species habitat within reserve allocations.

It is not possible to compare directly the cumulative effects of different actions on rare plants and fungi 

under the alternatives and the Proposed RMP. However, the No Action alternative and Alternative C 

would generally provide less benefit to rare plants and fungi. Alternatives A, B, and D, and the Proposed 

RMP would generally provide more benefit to rare plants and fungi.
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Issue 2

How would timber harvest and other vegetation management affect oak communities?

Summary of Analytical Methods

The BLM calculated the acres of oak-dominant communities within the planning and decision areas using 

Gradient Nearest Neighbor (GNN) data (2012). The BLM defined oak-dominant communities as forest 

types where an oak species is the primary or secondary species. For example, the forest type could consist 

of Oregon white oak, or of ponderosa pine and California black oak.

The BLM evaluated the effect of timber harvest on oak woodlands based on the percent change in oak 

basal area in the Harvest Land Base and the entire decision area among the alternatives and the Proposed 

RMP over 50 years.

Background

Oak communities, including oak woodlands and oak savanna, represent a special habitat within the 

decision area. While oak species in Oregon are not Bureau Special Status species, their habitat is rare and 

vulnerable to destruction from development, conversion to conifer forest, and high-intensity wildfire. 

Oregon white oak (Quercus garryana) occurs from Vancouver Island through western Washington, 

Oregon, and northwest California and in the Sierra Nevada foothills. California black oak (Quercus 

kelloggii) ranges from southern Oregon and throughout California and occurs within the Eugene, 

Medford, and Roseburg Districts, and the Klamath Falls Field Office. Both Oregon white oak and 

California black oak may occur within forested stands as a minor component and are often examples of 

the legacy vegetative community. Oregon white oak is intolerant to shade and relies on the most recent 

two years of ring growth for water transport. Therefore, it is vulnerable to competition (Gould et al.

2011). Prior to European settlement, wildfire and frequent, low-intensity burning by Native Americans 

limited the extent of coniferous forests and sustained fire-tolerant oak savannah and woodlands (Tveten 

and Fonda 1999, Devine and Harrington 2006, Gould et al. 2011, Klamath Bird Observatory and 

Lomakatsi Restoration Project 2014). Lack of fire in oak communities has resulted in the encroachment of 

conifers that rapidly overtop, shade, and crowd out the oaks. In addition, lack of frequent fire has often 

resulted in the accumulation of heavy fuels, making the reintroduction of fire difficult (see the Fire and 

Fuels section in this chapter). Releasing Oregon white oaks from overtopping Douglas-fir increases the 

available soil water content, extending the growing season for the oaks and understory vegetation (Devine 

and Harrington 2007). Even oaks suppressed for many years respond favorably after release with 

increased stem diameter growth and the growth of epicormic branches (Devine and Harrington 2006). 

These changes are most substantial during the first five years after release.

Affected Environment

Oak woodlands and savannas are limited within the planning area. Within the decision area, Oregon white 

oak woodlands and savannas occur primarily in the Roseburg and Medford Districts and the Klamath 

Falls Field Office; however, oaks occur in all districts within the decision area. Table 3-120 lists the acres 

of oak-dominant communities in the planning area and the decision area within each district.
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Table 3-120. Acres of oak-dominant plant communities within the planning and decision areas

District/

Field Office

Oak – All Ownerships

(Acres)

Oak –

BLM-administered lands

(Acres)

Oak Acres on BLM

(Percent of Total)

Coos Bay 33,475 1,062 3.17%

Eugene 35,256 1,045 2.96%

Klamath Falls 11,147 3,654 32.78%

Medford 447,900 117,405 26.21%

Roseburg 135,804 12,490 9.20%

Salem 107,882 550 0.51%

Totals 771,464 136,207 17.66%

Environmental Consequences

Under the action alternatives and the Proposed RMP, within the dry forests outside of the Harvest Land 

Base, the BLM would apply management treatments to maintain or promote desired species composition 

within oak woodlands, meadows, grasslands, and shrublands. In addition, within the Uneven-aged Timber 

Area sub-allocation, the BLM would retain oaks established prior to 1850. Under Alternative B, the BLM 

would manage mixed hardwood/conifer communities outside of the Harvest Land Base to maintain and 

enhance oak persistence and structure. Since oak species may be a minor component of mixed 

hardwood/conifer communities, they are likely to die off over time without management to prevent 

conifers from shading them out. Under Alternative B, the BLM would actively manage forest stands for 

the persistence of these species. Under the Proposed RMP across all land use allocations, the BLM would 

manage mixed hardwood/conifer communities to maintain and enhance oak consistent with other 

management direction for the land use allocation. The BLM would also retain oaks greater than 24” DBH, 

except for safety or operational reasons in the dry Late-Successional Reserve and the Uneven-aged 

Timber Area sub-allocation.

Although vegetative communities where oak species currently predominate are generally outside of the 

Harvest Land Base in all alternatives and the Proposed RMP, oak species do occur within the Harvest 

Land Base. Oaks represent an immeasurable small percentage of the basal area of the stands in the 

Harvest Land Base in the moist forests of Salem and Eugene. However, oaks represent more than 60 

percent of the basal area of some individual dry forest stands in the Klamath Falls Field Office and the 

Medford and Roseburg Districts. In general, all alternatives and the Proposed RMP would result in a 

decrease of oak basal area of 1 percent or less across the decision area over 50 years. Canopy cover of all 

hardwoods (e.g., oaks, madrone, maple, and chinquapin) would decrease by 3–4 percent in 50 years. It is 

likely that the vegetation modeling overestimates any decline in hardwood abundance in general and 

specifically oaks, because the tree growth model is designed primarily for fast-growing conifer species 

such as Douglas-fir, and the model did not account for all management directions that would help to 

maintain oaks within stands.

In general, oak communities would eventually decline in abundance within the Late-Successional Reserve 

and the Riparian Reserve as stands would continue to grow, and conifers would overtop and shade out 

oaks under the No Action alternative and Alternatives A, B, C, and D. Oak communities would fare best 

within the Late-Successional Reserve under the Proposed RMP as the BLM would utilize integrated 

vegetation management to increase or maintain vegetative species diversity and to create and maintain 

areas of hardwood dominance. Within the Harvest Land Base, the different harvest methods would have 

varying effects on oak species. Alternatives A and C would both include clearcuts, and all oaks present 
551 | P a g e

within the stand would be removed. Forest stands with an oak component require natural or management 

disturbance to prevent oaks from dying out of the stand. Intermediate harvest methods, such as 

regeneration harvest with retention and uneven-aged management would provide more opportunities for 

maintaining oaks within stands.

The management direction for the action alternatives and the Proposed RMP would mitigate effects of 

timber harvest on oaks. Management direction common to all alternatives and the Proposed RMP

designed to meet objectives for fire and fuels would maintain and promote oaks on lands outside of the 

Harvest Land Base. Within the Harvest Land Base, the BLM would favor patches dominated by 

hardwood trees and areas containing unique habitats or high diversity for retention, except in the High 

Intensity Timber Area under Alternatives A and C. In the dry Late-Successional Reserve under all action 

alternatives and the Proposed RMP, the BLM would apply vegetation management to increase species 

diversity and allow for hardwood persistence. Under the Proposed RMP, oaks would be maintained 

within forest and woodland communities across all land use allocations. The quality and quantity of 

existing oak habitat would improve under the Proposed RMP. The No Action alternative and the action 

alternatives would likely result in the decline of oaks within forest communities, as conifer species would 

eventually overtop and suppress oaks.

Issues Considered but not Analyzed in Detail

How would recreation management affect Special Status plant and fungi species, Survey and Manage

species, and special habitats?

The BLM assumed that human use concentrated at recreation sites, such as campgrounds and trails, 

would adversely affect rare plants and fungi because of trampling, firewood collection, introduction and 

spread of noxious and non-native species, and soil disturbance. Recreation sites would not differ among 

the alternatives or the Proposed RMP. Changes to recreation sites in the decision area, such as the

development of new sites or elimination of existing sites, would be speculative. As such, there is no basis 

for describing a difference in effect on rare plant and fungi species from recreation sites among the 

alternatives and the Proposed RMP.

While dispersed recreation could potentially affect rare plants and fungi, such recreation use would be 

less concentrated than at recreation sites, and effects would be speculative. It is not possible at this scale 

of analysis with the data available to describe any foreseeable effects on rare plants and fungi of the 

recreation allocations at the RMP level, such as Special Recreation Management Areas and Extensive 

Recreation Management Areas or issuance of special use permits.

How would invasive plant introduction and spread affect Bureau Special Status plant and fungi species, 

Survey and Manage species, and special habitats?

Invasive plants alter the existing native plant community and reduce rare vascular plant growth and vigor, 

flowering, and fruiting. There is very little information about the adverse effects of invasive plant species 

to fungi, terrestrial lichens, and bryophytes. Invasive species effects to rare plant and fungi sites would 

vary depending on many factors, but primarily the invasive species and its biology, site characteristics, 

and the affected rare plant species and its biology. There is not a reliable way to predict actual location of 

invasive species introductions relative to sites of rare species because of activities. Actions to control

invasive plant species that eradicate or reduce competition would benefit rare plant sites. Generally, larger 

rare plant and fungi sites would be more resilient to invasive species invasion and persist longer than 

small sites that are less robust. The Invasive Species section of this chapter analyzed the risk of invasive 
552 | P a g e

plant introduction and spread associated with management actions under each alternative and the 

Proposed RMP. It is not possible to describe that risk of invasive plant introduction and spread in terms of 

effects on rare plant and fungi species given the incomplete information on rare plant and fungi 

distribution, the uncertainty associated with forecasting future invasive plant introduction and spread, and 

the highly species-specific and site-specific interactions between rare plants and fungi and invasive plants.

How would wildfire response affect Special Status plant and fungi species, Survey and Manage species, 

and special habitats?

Wildfire response activities, such as bulldozing for the construction of fire lines, safety zones, and staging 

areas, can cause direct effects to rare plant and fungi sites from habitat disturbance. Wildfire response 

efforts that prevent or reduce habitat loss from uncharacteristic wildfire can preserve rare plant and fungi 

sites that would otherwise be lost. Because of uncertainties with regard to wildfire response activities on 

BLM-administered lands, such as location and extent, specific environmental effects of these actions to 

rare plant and fungi sites from habitat disturbance would be speculative. The full range of wildfire 

response tactics would be available under all alternatives and the Proposed RMP, and maintenance of fire 

suppression-related infrastructure would not change among alternatives or the Proposed RMP (see the 

Fire and Fuels section in this chapter). Because these factors would not differ among the alternatives or 

the Proposed RMP, there is no reasonable basis on which to identify a difference in the effects of wildfire 

response on rare plants and fungi.
553 | P a g e

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