United States Department of the Interior 

Bureau of Land Management 

Draft Resource Management Plan/Environmental Impact Statement 

for the Resource Management Plans for Western Oregon 

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

and the Lakeview District’s Klamath Falls Field Office

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 Draft Resource Management Plan/Environmental Impact Statement addresses revision of 

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

Districts and the Lakeview District’s Klamath Falls Field Office. 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 No Action alternative of continued 

implementation of the 1995 Resource Management Plans, four alternatives, and two sub-alternatives. 

Comments on this Draft Resource Management Plan/Environmental Impact Statement must be submitted 

by July 23, 2015. 

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/ 

 




















Reader’s Guide

xx | Page

 

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 Lakeview District’s Klamath Falls Field 

Office. The planning area for this RMP revision encompasses western Oregon and includes 

approximately 2.5 million acres of public land managed by the BLM. When approved, these RMPs will 

replace the existing RMPs and guide the management of public lands in the Coos Bay, Eugene, Medford, 

Roseburg, and Salem Districts and the Lakeview District’s Klamath Falls Field Office into the future. 

The BLM has prepared this Draft Resource Management Plan/Environmental Impact Statement (Draft 

RMP/EIS) in accordance with the National Environmental Policy Act of 1969, as amended, the Federal 

Land Policy and Management Act of 1976, as amended, the BLM NEPA Handbook (H-1790-1), the 

BLM Land Use Planning Handbook (H-1601-1), and other applicable law and policy. 

Organization of the Draft Resource Management 

Plan/Environmental Impact Statement 

This Draft RMP/EIS provides a progression of information to the reviewer. 

The Summary presents a brief description of the major elements of this document. The summary is 

necessarily neither comprehensive nor complete. Therefore, the details in the four chapters of this 

document are essential to fully understanding the planning process, the alternatives, and their effects. 

Chapter 1 presents the purpose and need for this RMP revision and the guidance for the development of 

the action alternatives. Chapter 1 presents a discussion of the major authorizing laws and regulations that 

affect management of the BLM-administered lands in the planning area. 

Chapter 2 describes the No Action alternative and the action alternatives that are analyzed in detail, 

including identification of the preferred alternative. This chapter also discusses alternatives that the BLM 

considered but did not analyze in detail. Finally, this chapter presents a comparison of the alternatives, 

including summaries of key features of the alternatives and key impacts of the alternatives. 

 

Chapter 3 describes the environment that the RMPs are likely to affect and the environmental 

consequences of the alternatives. Although 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 is 

includes sections for each resource that the RMPs are likely to affect. Each section begins with a 

summary of the methods used to analyze the impacts of the alternatives on this resource. The BLM has 

then divided each section into subsections that address a particular question about how the BLM’s draft 

alternatives may 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 the environmental consequences to the 

resource of the alternatives analyzed in detail, including the No Action alternative. 

Chapter 4 describes the public involvement and collaboration that occurred during the preparation of this 

Draft RMP/EIS. That collaboration includes government-to-government relationships with tribes, formal 

cooperators in the planning process, and consultation with other agencies. This chapter also includes a list 

of staff involved in the RMPs for Western Oregon. 

Reader’s Guide 

Reader’s Guide

xxii | Page

 

Next Steps in the Planning Process 

The BLM is planning a series of public meetings after the release of the Draft RMP/EIS. The purpose of 

these meetings is to help members of the public understand the content of the Draft RMP/EIS and provide 

meaningful and constructive comments. There will likely be six “open-house” public meetings (one 

meeting per District) where people can engage with BLM employees on all resources addressed in the 

Draft RMP/EIS. The BLM will likely also be organizing issue-specific meetings on topics such as socioeconomics, forestry, aquatics, and wildlife. Information on meeting locations and dates will be available 

at 

http://www.blm.gov/or/plans/rmpswesternoregon/ 

Following the 90-day comment period for this Draft RMP/EIS, the BLM will review the comments and 

work with cooperating agencies to develop a Proposed RMP/Final EIS. In that document, the BLM will 

present the Proposed RMP, which will be either one of the alternatives analyzed in this Draft RMP/EIS or 

a newly developed alternative that is within the spectrum of the alternatives analyzed in this Draft 

RMP/EIS. In the Proposed RMP/Final EIS, the BLM will also provide copies or summaries of substantive 

comments on the Draft RMP/EIS, the BLM responses to those comments, and changes or additions to the 

text of the Draft RMP/EIS in response to comments. 

Following publication of the Proposed RMP/Final EIS, any person who participated in the planning 

process and has an interest that may be adversely affected by the approval of the Proposed RMP may 

protest to the Director of the BLM within 30 days of the publication of the Proposed RMP/Final EIS. The 

BLM will submit the Proposed RMP to the Governor of Oregon to identify any known inconsistencies 

with State or local plans, policies, or programs. 

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

Oregon, the BLM will prepare a Record of Decision/RMP (ROD/RMP) to approve the RMP revision. 

The ROD/RMP will identify the decision by the State Director on the RMP revision and the rationale for 

the decision. The ROD/RMP will also contain the RMP itself, including the land use allocations, 

management objectives, and management direction. 

The publication of the ROD/RMP will represent the completion of the RMP revision process. Following 

publication of the ROD/RMP, the BLM will take only those management actions that are specifically 

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

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

 
Summary

xxiii | Page

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 fully understanding the planning process, the alternatives, 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 Lakeview District’s Klamath Falls Field 

Office. This Draft RMP/Environmental Impact Statement (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 impacts of these alternatives. 

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 in this Draft RMP/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 

x Provide a sustained yield of timber 

x 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 

o maintaining older and more structurally complex multi-layered conifer forests 

x Provide clean water in watersheds 

x Restore fire-adapted ecosystems 

x Provide recreation opportunities 

x Coordinate management of lands surrounding the Coquille Forest with the Coquille Tribe 

Alternatives 

The BLM has designed the range of alternatives in this Draft RMP/EIS to span the full spectrum of 

alternatives that would respond to the purpose and need for the action. The BLM has developed the 

alternatives to represent a range of overall management approaches, rather than exemplify gradations in 

design features. In this Draft RMP/EIS, the BLM analyzed in detail the No Action alternative and four 

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. Table 1 summarizes key features of the alternatives that vary 

substantially among the alternatives and are easily quantified and summarized. 
Summary

xxiv | Page

 

The No Action alternative in this Draft RMP/EIS 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. 

All action alternatives include the following land use allocations: Congressionally Reserved, DistrictDesignated Reserves, Late-Successional Reserve, Riparian Reserve, Harvest Land Base, and Eastside 

Management Area (Figure 1). The location and acreage of these allocations, with the exception of 

Congressionally Reserved, vary by alternative. Within each action alternative, 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 (clear cuts). 

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 UnevenAged Timber Area is the largest of all 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 (clear cuts). Alternative C has the smallest 

acreage in the Riparian Reserve of all of the 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 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. 


Summary

xxvii | Page

Figure i. Land use allocations under the alternatives. 

No Action alternative displays modified hierarchy (see Chapter 2). 
Summary

xxviii | Page

 

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 land 

within the planning area. 

. 

Air Quality 

All action alternatives 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 consider the designation of 121 potential Areas of Critical Environmental Concern. 

Alternative A would designate the most and Alternative C the fewest areas as Areas of Critical 

Environmental Concern at 119 and 111, respectively. 

Climate Change 

Carbon storage would increase under all alternatives. Greenhouse gas emissions associated with BLMadministered lands would increase under all alternatives, but would remain less than one 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 

All alternatives would increase stand-level fire resistance and reduce wildfire hazard on BLMadministered 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 any 

alternative 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 lateseral open forest. 

Fisheries 

All of the alternatives 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 all alternatives, 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. 
Summary

xxix | Page

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) under the alternatives would range from 120 million board feet per 

year under Sub-alternative B to 486 million board feet per year under Alternative C. Non-ASQ timber 

harvest volumes in the first decade would range from 4 million board feet per year under Alternative D to 

122 million board feet per year under the No Action alternative. 

Hydrology 

Under the No Action alternative, and Alternatives A and D, less than 0.5 percent of all perennial and fishbearing 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 Reserves. 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 Reserves. 

Under all alternatives, potential sediment delivery to streams from new road construction would constitute 

less than a one 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. 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 any alternative. 

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. Sudden oak death 

infestations would occupy 100 percent of the Riparian Reserves in Infestation Zone 2 and almost 90 

percent in Infestation Zone 3 by 2033 under Alternatives A and B. 

Lands and Realty 

Under all alternatives, BLM-administered lands would generally be available for rights-of-way. 

Alternative D would most constrain the BLM’s ability to grant right-of-ways from the current conditions. 

Lands with Wilderness Characteristics 

Alternative A provides the greatest protection of identified lands with wilderness characteristics within 

the planning area. Alternatives B and C provide intermediate protection of lands with wilderness 

characteristics within the planning area. Alternative D provides no protection of lands with wilderness 

characteristics with the planning area. 

Livestock Grazing 

Under Alternatives A, B, and C, public land available for livestock grazing would decrease from 495,190 

acres to 359,049 acres. This change would occur through the BLM making currently vacant allotments 
Summary

xxx | Page

 

unavailable for grazing. Under Alternative D, the BLM would no longer authorize livestock grazing 

within the decision area, a change that would affect 495,190 acres.

Minerals 

Under the action alternatives, the BLM would petition for the withdrawal of an additional six to eight 

percent of the decision area. Approximately 90 percent of the decision area would remain open to 

locatable and salable mineral entry. 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 greatest number of acres 

within the viewshed. However, these acres only account for nine percent of all viewable acres. 

Rare Plants and Fungi 

Only two Federally-listed plant species occur within forest and woodland habitat in the decision area: 

Kincaid’s lupine and Gentner’s fritillary. Under all alternatives, the BLM would conduct pre-disturbance 

survey and apply conservation measures for these Federally-listed plant species. The BLM would manage 

Bureau Sensitive plant and fungi species under the BLM’s sensitive species program under all 

alternatives. Under all action alternatives, species that are currently Survey & Manage and not included 

on the Bureau Sensitive species list would receive no specific protections. 

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 greatest number and acres of recreation 

management areas in closest proximity to the twelve most populated communities in the planning area. 

Soil Resources 

All alternatives would increase the acreage of detrimental soil disturbance from timber harvest, road 

construction, and fuels treatments by 13 to 30 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 sound management practices that would limit initial 

compaction levels, remove existing or created compacted surfaces, and improve soil water and organic 

matter levels. 

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; 

from $37 million under Alternative D to $135 million under Alternative C. Using non-market valuation 

techniques the analysis estimates the 2012 value of recreation on BLM-administered lands at $223 million 

and the annual value of carbon storage at $99 million. Under all alternatives, the annual value of 

recreation would increase to $250 million. The annual value of net carbon storage would increase under 

all alternatives except Alternative C, under which it would fall to $55 million. 
Summary

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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 alternatives, these contributions would 

range from a low of 6,900 jobs and $304 million in earnings (Alternative D) to a high of 12,419 jobs and 

$584 million in earnings (Alternative C). Employment effects to low-income populations in Coos, Curry, 

Douglas, and Klamath Counties would be disproportionately negative under Alternatives A and D. Lowincome communities and tribes in these counties would also be vulnerable to these disproportionately 

negatively effects. Under Alternative B, employment effects would be disproportionately negative for 

Coos and Curry Counties. 

There is uncertainty regarding the source and amounts of future payments to counties from activities on 

BLM-administered lands. Secure Rural Schools and Community Self-Determination Act 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 alternatives, payments in 2018 would range from a low of $19 

million under Alternative D to a high of $67 million under Alternative C. 

Sustainable Energy 

Under all alternatives, 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, all action alternatives would be less constraining to geothermal 

development than the current condition. 

Trails and Travel Management 

All action alternatives would increase the acreage closed to off-highway vehicle use and decrease the 

acreage open to off-highway vehicle use 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, socio-economics, 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 all alternatives, visual resource quality would decline to some extent over time, because the BLM 

would manage a substantial acreage of land at a higher Visual Resource Management class than the 

Visual Resource Inventory class at which it inventoried. Alternative D would provide the greatest 

protection, and Alternatives A, B, and C would provide the least protection of visual resources. 

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 35 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 in the Coast 
Summary

xxxii | Page

 

Range to reduce risks to the northern spotted owl during the next 50 years, and there are no substantive 

differences among the alternatives in their potential effects 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 all alternatives. 

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 96, 12, and 210 

future marbled murrelet sites, respectively, as a result 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 within the appropriate 

management level of 30 to 50 horses. Alternative D, which would eliminate livestock grazing, would 

reduce competition for forage and provide the potential for increased growth of the Pokegema herd. 

Otherwise, the alternatives would not differ in their effects on the Pokegama herd. 

Wild and Scenic Rivers 

Under Alternative A, the BLM would not designate any of the 51 eligible Wild and Scenic River 

segments as suitable, resulting in impacts to all eligible river segments and their associated values. Under 

Alternatives B and C, the BLM would designate six eligible Wild and Scenic River segments as suitable. 

Under Alternative D, the BLM would designate all 51 eligible Wild and Scenic River segments as 

suitable, resulting in the greatest protection for all segments and their associated river values. 

Consultation and Coordination 

The preparation of this Draft RMP/EIS has 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. 

The BLM is planning a series of public meetings after the release of the Draft RMP/EIS. The purpose of 

these meetings is to help members of the public understand the content of the Draft RMP/EIS and provide 

meaningful and constructive comments. There will likely be six “open-house” public meetings (one 

meeting per District) where people can engage with BLM employees on all resources addressed in the 

Draft RMP/EIS. The BLM will likely also be organizing issue-specific meetings on topics such as socioeconomics, forestry, aquatics, and wildlife. Information on meeting locations and dates will be available 

at http://www.blm.gov/or/plans/rmpswesternoregon/ 

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 this Draft RMP/EIS by a Cooperating Agency Advisory 

Group, including 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, the Cooperating 
Summary

xxxiii | Page

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 Draft RMP/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 draft alternatives. They 

have provided oral and written feedback and ideas throughout the process of developing the Draft 

RMP/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. 

Before signing a Record of Decision on the RMP revisions, the BLM will consult 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). The BLM, U.S. Fish and Wildlife 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. 

1 | Page

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 Lakeview District’s Klamath Falls Field 

Office (1995 RMPs; USDI BLM 1995 a, b, c, d, e, f). This Draft RMP/Environmental Impact Statement 

(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 these alternatives. The 

BLM will consider public comments on the alternatives and analysis as it develops a Proposed RMP/Final 

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. 

The Planning Area 

The planning area includes approximately 2.5 million acres of BLM-administered land in western Oregon 

managed by the BLM’s Coos Bay, Eugene, Medford, Roseburg, and Salem Districts and the Lakeview 

District’s Klamath Falls Field Office (Map 1-1). 

 

Chapter 1 - Introduction 

3 | Page

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 subsurface minerals). 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 BLMadministered lands (surface and subsurface) and over subsurface minerals in areas of split estate (i.e., 

areas where the BLM administers Federal subsurface minerals, 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). The first two 

areas have independent RMPs, while the BLM is currently developing an RMP for the West Eugene 

Wetlands. 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 Draft RMP 

integrated with the Draft Environmental Impact Statement as a single document (Draft RMP/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 is preparing a single Draft RMP/EIS and a single Proposed RMP/Final EIS for the revision of 

the RMPs for the Coos Bay, Eugene, Medford, Roseburg, and Salem Districts and the Lakeview District’s 

Klamath Falls Field Office. At this time, the BLM anticipates eventually issuing two Records of 

Decision/Approved RMPs: a Northwest Oregon Record of Decision/Approved RMP that would apply to 

the Salem District, the Eugene District, the Coos Bay District, and the Swiftwater Field Office of the 

Roseburg District, and a Southwest Oregon Record of Decision/Approved RMP that would apply to the 

South River Field Office of the Roseburg District, the Medford District, and the Klamath Falls Field 

Office of the Lakeview District. The Proposed RMP/Final EIS will more fully address the structure of the 

eventual Records of Decision/RMPs. 
Chapter 1 - Introduction 

4 | Page

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 

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–

x Objectives for the management of BLM-administered lands and resources; 

x Land use allocations relative to future uses for the purposes of achieving the various objectives; 

and 

x 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. 

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. 

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. 

At this time, the BLM does not anticipate including any implementation decisions in the eventual Records 

of Decision/RMPs.2

 That is, the BLM anticipates that all of the decisions in the Records of 

Decision/RMPs will be land use plan decisions. If the BLM elects to include some implementation 

decisions later in the planning process, any implementation decisions will be clearly distinguished from 

 

1 The terms “annual productive capacity,” “annual sustained yield capacity,” and “allowable sale quantity” are 

synonymous. 

2

 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 

out only after completion of further appropriate NEPA analysis or documentation, consultation, and decisionmaking processes. 
Chapter 1 - Introduction 

5 | Page

the land use plan decisions in the Proposed RMP/Final EIS, and the Proposed RMP/Final EIS will 

describe the administrative remedies for both. 

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/USDI 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 

agencies, as discussed below. Harvesting timber on a sustained-yield basis for the Oregon and California 
Chapter 1 - Introduction 

6 | Page

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]). 
Chapter 1 - Introduction 

7 | Page

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 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/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 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 Forest 

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/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: 

x Alternative A in the 1994 RMP/EIS, which would have reserved no late-successional 

forest outside of special areas and sites occupied by listed species 

x Alternative B in the 1994 RMP/EIS, which would have reserved small blocks of latesuccessional forest 

x Alternative 3 in the 2008 RMP/EIS, which would have allocated the majority of the 

landscape to a General Landscape Area that directed timber harvest on long rotations 
Chapter 1 - Introduction 

8 | Page

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 

blocks of forest. Notably, Alternative 3 in the 2008 RMP/EIS 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—

x Alternative A in the 1994 RMP/EIS, which would have reserved no late-successional 

forest outside of special areas and sites occupied by listed species; 

x The 1995 RMP, which reserved approximately 83 percent of old-growth forest; 

x The Proposed RMP in the 2008 RMP/EIS, which would have reserved 81 percent of oldgrowth forest and would have deferred harvest of any forest older than 160-years-old for 

15 years; 

x Alternative E in the 1994 RMP/EIS, which would have reserved all old-growth forest; 

x A sub-alternative for Alternative 1 in the 2008 RMP/EIS, which would have reserved all 

forests older than 200 years old; and 

x A sub-alternative for Alternative 1 in the 2008 RMP/EIS, which would have reserved all 

forests older than 80 years old. 
Chapter 1 - Introduction 

9 | Page

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 

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 marbled 

murrelets. 

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 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]). 
Chapter 1 - Introduction 

10 | Page

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).

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 

RMP/EIS). 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 U.S.C. 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 (Public Law 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 

The BLM will develop all action alternatives to meet the purposes for the action, described above under 

‘Purpose and Need for Action.’ To be considered reasonable, action alternatives would have to make a 
Chapter 1 - Introduction 

11 | Page

substantial and meaningful contribution to meeting each of the purposes, rather than a minimal

contribution. The alternatives will explore various ways of contributing to these purposes and meeting the 

requirements of the management guidance provided in this document. 

In developing all action alternatives, the BLM will: 

x Review existing Areas of Critical Environmental Concern (ACECs) and nominations for new 

ACECs. In this review, the BLM will do the following: 

o Determine if they meet the Relevance and Importance criteria. 

o Determine, 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 Eliminate from further consideration those areas that do not meet criteria for designation 

as ACECs. 

o Determine if the relevant and important resource values of the remaining nominations can 

be protected and maintained through other features of the alternatives or if special 

management attention is needed. 

o Include in development of alternatives those nominations that meet criteria for 

designation as ACECs. 

x Designate areas as Special Recreation Management Areas or Extensive Recreation Management 

Areas; lands not designated under one of these two categories are Public Lands not Designated 

for Recreation. Develop 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. 

x Designate Visual Resource Management classifications for areas. Develop 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. 

x Evaluate all eligible Wild and Scenic River segments and determine which are suitable or nonsuitable 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). 

x Designate areas as open, limited, or closed to off-highway vehicle use in accordance with 43 CFR 

8342.1. Develop a range of travel management area scenarios in relationship to various land use 

allocations and management objectives among the alternatives. Defer implementation level travel 

and transportation management planning until after completion of the RMP revision process. For 

those areas designated as limited in the RMP, define interim management objectives and clearly 

identify 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). 

x Consider a range of management alternatives for addressing lands with wilderness characteristics, 

consistent with the discussion of lands will wilderness characteristics below under The O&C Act 

and the FLPMA. 
Chapter 1 - Introduction 

12 | Page

x Designate areas that are available and have the capacity for planned, sustained-yield timber 

harvest, and declare an Allowable Sale Quantity of timber that represents the annual productive 

capacity for sustained-yield timber production. 

x Designate lands that are available or not available for livestock grazing. For lands available for 

livestock grazing, identify the amount of forage available for livestock. 

x Designate land tenure zones identifying lands for retention, disposal, or acquisition. 

x Designate lands as open or closed to the several forms of mineral entry location, leasing, or sale 

as appropriate to the type of commodity and land status. Identify areas, if any, recommended for 

closure to the mining laws for locatable exploration or development (and which the BLM would 

recommend for withdrawal). 

In developing the action alternatives, the BLM will consider 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). 

The BLM will not constrain the development of alternatives by current or projected BLM budget or staff 

levels. As long as alternatives are economically feasible, the analysis of the alternatives will assume that 

BLM budget and staff will be sufficient to implement all alternatives. The analysis of alternatives will 

include 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 will develop action alternatives 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 will develop action alternatives and provide cumulative effects analysis to provide a framework 

to simplify and facilitate project-level NEPA analysis for management actions implementing the RMP. 

The BLM will develop 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 will develop the action alternatives to provide sufficient detail in the analysis to facilitate RMPlevel Endangered Species Act consultation, as well as eventual project-level consultation for management 

actions implementing the RMP. 
Chapter 1 - Introduction 

13 | Page

Working closely with the Oregon Department of Environmental Quality, in coordination with the 

Environmental Protection Agency, the BLM will develop the action alternatives to satisfy State and 

Federal water quality rules and regulations at the RMP level. 

Major Authorizing Laws and Regulations 

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. 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 concurrently 

implement all these laws, in a manner that harmonizes any seeming conflict between them, unless 

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 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 
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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 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 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 ...”
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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, 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 

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. 

 

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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: 

x Areas of Critical Environmental Concern 

x Lands with wilderness characteristics 

x Visual resources 

x Recreation management areas 

x 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 Classification3

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, 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 sustained-yield timber production in the following circumstances: on 

non-forested lands; on lands that would otherwise be allocated to a land use allocation that would 

 

3

 Timber Productivity Capability Classification is the process of partitioning forest land into major classes indicating 

relative suitability to produce timber. See Chapter 2. 
Chapter 1 - Introduction 

18 | Page

preclude sustained-yield timber production; or on lands for which the Timber Productivity Capability 

Classification category is ‘not included in the harvest land base.’

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 to the extent that the protection of scenic values is compatible with sustained-yield 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 2011), 

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 
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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 

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. About half of those public domain lands are small parcels that are widely 

scattered and intermingled with the O&C lands. While the FLPMA requires that the public domain lands 
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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, including the sustained yield of forest resources in connection with the 

intermingled O&C lands. 

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, required the BLM to 

incorporate the Northwest Forest Plan’s land use allocations and its standards and guidelines into the 

district RMPs for western Oregon. The Northwest Forest Plan was implemented on the BLMadministered lands in western Oregon in 1995 through the completion of its RMPs in the six western 

Oregon Districts. 

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/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. 

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/USDI BLM 2001) amended all of the 1995 RMPs.4

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 

 

4

 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. 
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Southwest Oregon, Coos Bay, Medford, and Roseburg District (USDI BLM 2004), which was based on 

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. 

In addition, the BLM has amended individual RMPs with amendments of more limited scope than the 

above amendments, and has periodically maintained individual RMPs.5

 Individual 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 in this Draft 

RMP/EIS 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 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 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 none of the action alternatives 

in this Draft RMP/EIS therefore includes the Survey and Manage measures, Survey and Manage is 

reflected in the Draft RMP/EIS’s No Action alternative described in Chapter 2.6

 As such, the BLM retains 

the discretion to consider this component in whole or part for inclusion in the eventual development of the 

Proposed RMP, along with any of the components of the alternatives and sub-alternatives, which are 

described in Chapter 2. 

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” (USDA et al. 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).7

 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 

 

5

 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. 

6

 As further explained in Chapter 2, the No Action alternative in this Draft RMP/EIS is implementation of the 1995 

RMPs as written (in contrast to the BLM’s current implementation practices under the 1995 RMPs). 7

 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. 
Chapter 1 - Introduction 

22 | Page

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 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 therefore allocate a LateSuccessional 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 “old-growth forests.” Each 

alternative 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 forest 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. 

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 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 in its entirety as constituted in the Northwest Forest Plan. 

Because of these differences, none of the action alternatives in this Draft RMP/EIS includes the Aquatic 

Conservation Strategy in its entirety as constituted in the Northwest Forest Plan. The Aquatic 

Conservation Strategy in its entirety as constituted in the Northwest Forest Plan is reflected in the Draft 

RMP/EIS’s No Action alternative described in Chapter 2. As such, the BLM retains the discretion to 

consider this component in whole or part for inclusion in the Proposed RMP, along with any of the 

components of the alternatives and sub-alternatives, which are 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 Aquatic Conservation Strategy (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 ripariandependent species. These objectives were based on the Forest Service organic statute and implementing 
Chapter 1 - Introduction 

23 | Page

regulations. The Aquatic Conservation Strategy consists of four components: riparian reserves, key 

watersheds, watershed analysis, and watershed restoration. 

Consistent with the purpose and need for this revision, all of the action alternatives include some, but not 

all, components of the Aquatic Conservation Strategy of the Northwest Forest Plan. For example, all of 

the action alternatives in the Draft RMP/EIS include Riparian Reserves, with widths and management 

direction that vary among the alternatives and differ from the No Action alternative. In addition, all of the 

action alternatives include management direction for watershed restoration similar to the watershed 

restoration described in the Northwest Forest Plan and included in the No Action alternative. Although 

none of the action alternatives delineates a network of key watersheds as did the Northwest Forest Plan, 

the range of Riparian Reserve designs and management direction among the action alternatives would 

allow the BLM to protect watersheds in the development of the Proposed RMP. Further, while none of 

the action alternatives includes a watershed analysis process as that included in the Northwest Forest Plan, 

under all of the action alternatives the BLM will generate the equivalent of watershed analysis by 

providing watershed scale information, including identifying resource conditions, watershed processes, 

risks to resources, and restoration opportunities, as needed for NEPA analysis or ESA consultation for 

implementation actions taken in the future consistent with the plan. 

Existing Decisions 

The following existing decisions, which are valid for continued implementation and are supported by an 

EIS, will be carried forward into the RMPs. The BLM will restate or summarize these decisions to 

incorporate them into the RMPs without additional analysis. These decisions will be common to all 

alternatives and include the following: 

x Management plans for congressionally-designated areas such as Wilderness Areas, Wilderness 

Study Areas, and Wild and Scenic Rivers 

x Pokegama Wild Horse Herd Management Area Plan (Klamath Falls Field Office, USDI BLM 

2002) 

x Record of Decision for Management of Port-Orford-cedar in Southwest Oregon (Coos Bay, 

Medford, and Roseburg Districts; USDI BLM 2004) 

x Record of Decision for Implementation of a Wind Energy Development Program and Associated 

Land Use Plan Amendments (USDI BLM 2005b) 

x Record of Decision and Resource Management Plan Amendments for Geothermal Leasing in the 

Western United States (USDA FS/USDI BLM 2008) 

x 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) 

x Vegetation Treatments Using Herbicides on BLM Lands in Oregon Record of Decision (USDI 

BLM 2010) 

x Seed Orchard Records of Decision for Integrated Pest Management (Salem, Eugene, Medford 

Districts; USDI BLM 2005c, 2005d, 2006) 

x Jordan Cove Energy and Pacific Connector Pipeline Project (in process) 

x Greater Sage Grouse Plan Amendments (in process) 

The Cascade Siskiyou National Monument (Medford District), and the Upper Klamath Basin and Wood 

River Wetland (Klamath Falls Field Office), and the West Eugene Wetlands (Eugene District) are not 

included in the decision area for this RMP revision. This RMP revision will not alter these independent 

RMP decisions. 
Chapter 1 - Introduction 

24 | Page

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, 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. 

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 USDI BLM. 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. 

---. 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. 

USDI BLM. 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. 

---. 2002. Pokegama Wild Horse Herd Management Area Plan. Lakeview District, Klamath Falls, OR. 

---. 2004. Final - Supplemental Environmental Impact Statement Management of Port-Orford-cedar in Southwest Oregon. SEIS. 

Portland, OR. 

---. 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 Walter H. Horning Tree Seed Orchard, Salem, OR. 

Salem District. 

---. 2005d. Record of Decision: Integrated Pest Management Program, BLM Travis Tyrell Seed Orchard, Lorane, Lane County, 

OR. Eugene District. 56 pp. 

---. 2006. Record of Decision: Integrated Pest Management. Provolt Seed Orchard, Grants Pass, OR, and Charles A. Sprague 

Seed Orchard, Merlin, OR. Medford District. 82 pp. http://www.blm.gov/or/districts/medford/plans/files/ProvoltSprague_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. 
Chapter 1 - Introduction 

25 | Page

---. 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, 12 December 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. 

---. 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. 

---. 2011. 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. 

---. 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. 

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. 
26 | Page
27 | Page

Chapter 2 – Alternatives

Introduction 

This chapter describes the alternatives considered in this 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 has designed the range of alternatives in this Draft RMP/EIS to span the full 

spectrum of alternatives that would respond to the purpose and need for the action. The BLM has 

developed the alternatives to represent a range of overall management approaches, rather than exemplify 

gradations in design features. Nevertheless, the alternatives do not provide all possible combinations of 

plan components. There are components of the alternatives that are somewhat separable, and the BLM 

may combine management objectives and management direction from several of these alternatives in 

developing the eventual Proposed RMP. In addition, the BLM could consider components of the No 

Action alternative, which is analyzed in detail in this Draft RMP/EIS, for inclusion in the eventual 

Proposed RMP, along with any of the components of the alternatives and sub-alternatives. 

This chapter describes the No Action alternative and the action alternatives that are analyzed in detail in 

this RMP/EIS, including identification of the preferred alternative. This chapter also discusses alternatives 

that the BLM considered but did not analyze in detail. Finally, this chapter presents a comparison of the 

alternatives, including a summary of the environmental effects of the alternatives. 

No Action Alternative 

The Council on Environmental Quality NEPA regulations require that an EIS analyzes a No Action 

alternative (40 CFR 1502.14(d)). The Council on Environmental Quality guidance explains that, for plans 

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 in this Draft RMP/EIS is 

implementation of the 1995 RMPs as written (in contrast to the BLM’s current implementation practices 

under the 1995 RMPs). 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. 

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 
Chapter 2 - Alternatives 

28 | Page

Map 2-1) and are incorporated here by reference. The No Action alternative, as analyzed in this Draft 

EIS/RMP, includes Survey and Manage standards and guidelines, consistent with—

x 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; 

x 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 

x The Pechman exemptions.8

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 2014. 

Figure 2-1. No Action alternative land use allocations. 

 

8

 The District Court for the Western District of Washington issued a remedy order on Feb. 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: 

x 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, Jan. 9, 2006), and this ruling incorporated the 

2001, 2002, and 2003 Annual Species Reviews; 

x The Ninth Circuit Court of Appeals in KSWC et al. v. Boody et al., 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 

x Judge Pechman ordered four categories of projects exempt from compliance with the Survey and Manage 

standards and guidelines (CV-04-00844-MJP, Oct. 11, 2006, “Pechman exemptions”): thinnings in forest 

stands younger than 80 years of age, culvert replacement/removal, riparian and stream improvement 

projects, and hazardous fuel treatments applying prescribed fire for noncommercial projects. 

LateSuccessional 

Reserves 

36% 

Other Reserves 

9% 

Matrix 

28% 

Eastside 

Management 

Area 

6% 

Riparian 

Reserves in 

Matrix 

21% 
Chapter 2 - Alternatives 

29 | Page

Table 2-1. No Action alternative land use allocations. 

Allocation Acres Percentage of Total Acres 

Late-Successional Reserves9 879,031 36% 

Riparian Reserves in Matrix 527,550 21% 

Other Reserves10 233,410 9% 

Matrix11 691,998 28% 

Eastside Management Area 146,867 6% 

 

 

9

 Late-Successional Reserves include Adaptive Management Areas within the Late-Successional Reserves and 

predictions of the acreage of newly discovered marbled murrelet sites. 

10 Other Reserves in the No Action alternative include Congressionally Reserved lands, District-Designated 

Reserves, and lands reserved within the Matrix. 

11 Matrix includes Adaptive Management Areas. 


Chapter 2 - Alternatives 

32 | Page

For comparing the acreage by land use allocation for the No Action alternative to the action alternatives, 

the Matrix land use allocation in the No Action alternative is comparable to the Harvest Land Base land 

use allocation in the action alternatives. 

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, 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. 

The Riparian Reserves acreage for the No Action alternative in Figure 2-1 and Table 2-1, presents only 

the Riparian Reserves within the Matrix, which is how the 1995 RMPs presented the hierarchy of land 

use allocations. The Late-Successional Reserves acreage for the No Action alternative do not account for 

Riparian Reserves within the Late-Successional Reserves. In the No Action alternative, the Riparian 

Reserves would overlay the Late-Successional Reserves, and implementation in those overlapping areas 

would apply the management objectives and management direction for both land use allocations 

(USDA/USDI 1994, pp. A-5–A-6). As a result, the 1995 RMPs only accounted for the Riparian Reserves 

acreage in the Late-Successional Reserves as Late-Successional Reserves; the only Riparian Reserve 

acreage calculated were those in the Matrix. Thus, the acreage of Riparian Reserves and LateSuccessional Reserves presented in the 1995 RMPs cannot be directly compared to the acreages presented 

in this analysis. 

To facilitate more direct comparison of these acreages by land use allocation for the No Action alternative 

to the action alternatives, Figure 2-2, and Table 2-2, present a modified hierarchy of land use allocations 

in the No Action alternative to display the Riparian Reserves acreage regardless of the underlying land 

use allocation (Figure 2-1 and Table 2-1). The results are a reduction in acreage identified as LateSuccessional Reserves and a corresponding increase in acreage identified as Riparian Reserves that 

allows for direct comparative analysis in this Draft EIS/RMP. 

Figure 2-2. No Action alternative land use allocations with modified hierarchy. 

Late-Successional 

Reserves 

19% 

Other Reserves 

9% 

Matrix 

28% 

Eastside 

Management 

Area 

6% 

Riparian Reserves 

38% 
Chapter 2 - Alternatives 

33 | Page

Table 2-2. No Action alternative land use allocations with modified hierarchy. 

Allocation Acres Percentage of Total Acres 

Late-Successional Reserves 478,860 19% 

Riparian Reserves 927,721 38% 

Other Reserves12 233,410 9% 

Matrix 691,998 28% 

Eastside Management Area 146,867 6% 

 

 

12 Other Reserves in the No Action alternative include Congressionally Reserved lands, District-Designated 

Reserves, and lands reserved within the Matrix. 
Chapter 2 - Alternatives 

34 | Page

Action Alternatives 

The four action alternatives with two sub-alternatives comprise a range of management strategies that the 

BLM has designed to meet the purpose and need discussed in Chapter 1. In addition, the BLM has 

developed the action alternatives to be consistent with the guidance for the formulation of alternatives 

discussed in Chapter 1. These action alternatives 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 some vary 

by action alternative, as described below. 

The BLM has developed the action alternatives in response to input received during external and internal 

scoping. Each of the action alternatives 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 

threatened and endangered species. 

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 eventual 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 and the four action alternatives, which explores the effects of the 

alternatives on all resources. The sub-alternatives are variations on the action alternatives and, as such, 

could be carried forward as the eventual Proposed RMP; their individual components could also be 

incorporated into the eventual Proposed RMP. 

The BLM has developed two sub-alternatives in this 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 focuses 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 subalternatives 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 All Action Alternatives 

This section contains a summary of those features that are common to all action alternatives. The 

subsequent section contains a description of the features that differ among the action alternatives. 

All action alternatives include the following land use allocations: Congressionally Reserved, DistrictDesignated Reserves, Late-Successional Reserve, Riparian Reserve, Harvest Land Base, and Eastside 

Management Area. The location and acreage of these allocations, with the exception of Congressionally 

Reserved, vary by alternative. Within each action alternative, the Harvest Land Base, Late-Successional 

Reserve, and Riparian Reserve have specific, mapped sub-allocations with differing management 
Chapter 2 - Alternatives 

35 | Page

direction. The Harvest Land Base has multiple sub-allocations with differing management direction for 

forest management summarized in Table 2-3. Appendix B contains detailed descriptions of the 

management direction for the sub-allocations of the Harvest Land Base.

Table 2-3. Forest management practices by Harvest Land Base sub-allocation. 

Sub-allocation 

Alternatives That 

Include SubAllocation Forest Management Practices 

High Intensity Timber 

Area (HITA) 

Alt. A 

Alt. C Thinning and regeneration harvest with no retention 

Moderate Intensity 

Timber Area (MITA) 

Alt. B 

Alt. D 

Thinning and regeneration harvest with retention of 5-15 

percent of the pre-harvest basal area of the stand 

Low Intensity Timber 

Area (LITA) Alt. B Thinning and regeneration harvest with retention of 15-30 percent of the pre-harvest basal area of the stand 

Uneven-aged Timber 

Area (UTA) 

All action 

alternatives 

Prescribed fire, thinning, single tree selection harvest, and 

group selection harvest 

Owl Habitat Timber 

Area (OHTA) 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, 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, each action alternative includes management 

direction to conduct the management actions necessary to achieve the management objectives for these 

allocations. 

Congressionally Reserved Lands 

Congressionally Reserved lands are those lands that Congress has designated and defined management 

through law, such as designated Wilderness and 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, including 

the No Action alternative. 

District-Designated Reserves 

District-Designated Reserves13 include lands that are reserved from sustained-yield timber production for 

a variety of reasons, including—

x Areas that the BLM has constructed for specific purposes (such as roads, buildings, maintenance 

yards, and other facilities and infrastructure); 

 

13 These areas have been termed Administratively Withdrawn in previous planning efforts. This RMP/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. 
Chapter 2 - Alternatives 

36 | Page

x Areas that the BLM has identified through the Timber Production Capability Classification14

system as unsuitable for sustained-yield timber production (e.g., rock outcrops); 

x Areas of Critical Environmental Concern, including Research Natural Areas; and 

x Other reserves (e.g., special recreation management areas and areas protected for Bureau 

sensitive species). 

Under all alternatives, the BLM would manage roads, maintenance yards, buildings, and other facilities 

for the purpose for which they were constructed. The BLM may manage areas identified as unsuitable for 

sustained-yield timber production through the Timber Production Capability Classification system 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 sustain-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 would reserve Areas of Critical Environmental 

Concern and other District-Designated Reserves 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 All 

Action Alternatives 

Late-Successional Reserve 

The Late-Successional Reserve in all action alternatives has management objectives to—

x Protect stands of older, structurally-complex, conifer forest; 

x Maintain habitat for the northern spotted owl and marbled murrelet; 

x Promote development of habitat for the northern spotted owl in stands that do not currently meet 

suitable habitat criteria; and 

x Promote development of nesting habitat for the marbled murrelet in stands that do not currently 

meet nesting habitat criteria. 

Riparian Reserve 

The Riparian Reserve in all action alternatives has management objectives to—

x Contribute to the conservation and recovery of listed fish species and their habitats and provide 

for conservation of special status fish and other special status riparian associated species; 

x 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; 

 

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. 
Chapter 2 - Alternatives 

37 | Page

x 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; 

x Meet ODEQ water quality targets for 303(d) water bodies with approved Total Maximum Daily 

Loads (TMDLs); 

x Maintain high quality water and contribute to the restoration of degraded water quality 

downstream of BLM-administered lands; and 

x Maintain high quality waters within ODEQ designated Source Water Protection watersheds. 

Harvest Land Base 

The Harvest Land Base in all action alternatives has management objectives to— 

x Manage forests to achieve continual timber production that can be sustained through a balance of 

growth and harvest; 

x Offer for sale the declared annual productive capacity of timber; 

x Recover economic value from timber harvested after a stand-replacement disturbance, such as a 

fire, windstorm, disease, or insect infestation; 

x Ensure the establishment and survival of desirable trees appropriate to the site and enhance their 

growth in harvested or disturbed areas; and 

x Enhance the economic value of timber in forest stands. 

Eastside Management Area 

All action alternatives include an Eastside Management Area land use allocation, which applies to BLMadministered lands in the Klamath Falls Field Office east of Highway 97. This allocation includes 

management objectives to—

x Manage forest and non-forest lands with the intent of maintaining or improving wildlife habitat 

and rangeland conditions based on ecological site parameters; 

x Manage forest and non-forest lands for multiple uses in addition to those listed above including: 

recreational needs, community stability, and commodity production; 

x Promote development of fire-resilient forests; 

x Provide for the conservation of BLM Special Status Species; and 

x Meet Oregon Department of Fish and Wildlife management goals for wildlife on public domain 

lands. 

In addition, the design, management objectives, and management direction for the Riparian Reserve on 

BLM-administered lands in the Klamath Falls Field Office east of Highway 97 do not vary among action 

alternatives (Appendix B). 

Resource-Specific Objectives that are Common to All Action 

Alternatives 

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. For some of these resources or 

programs, the management objectives and management direction do not vary among the action 

alternatives, but the management of the resource is tied to allocations that do vary among action 

alternatives. For example, the management objectives and management direction for designated Areas of 

Critical Environmental Concern do not vary among action alternatives, but which specific areas the BLM 
Chapter 2 - Alternatives 

38 | Page

would designate as Areas of Critical Environmental Concern would vary with the land use allocations of 

each alternative. The following section summarizes the resource-specific management objectives that are 

common to all action alternatives. Appendix B contains detailed descriptions of the management 

objectives and management direction that are common to all action alternatives. 

Air Quality: The BLM would follow the Clean Air Act by protecting air quality in Class 1 areas, such as 

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 alternative). 

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. 

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. It 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 Federally-listed 

plant and fungi species. It 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. 
Chapter 2 - Alternatives 

39 | Page

Travel and Transportation: The BLM would maintain a travel network that best meets the full range of 

public, resource management, and administrative access needs. 

Visual Resource Management: The BLM would protect the quality of the scenic values on public lands 

where visual resource management is an issue or where high value visual resources exist, and protect 

areas having high scenic quality, visual sensitivity, and public visibility. 

Soils: The BLM would manage to maintain the overall soil capacity 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 Federally-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, 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: 

x Competitive and commercial recreation activities 

x Special forest product collection permit issuance 

x Lands and realty actions (including the issuance of grants, leases, and permits) 

x Trespass resolution 

x Facility maintenance 

x Facility improvements 

x Road maintenance 

x Hauling permit issuance 

x Recreation site maintenance 

x Recreation site improvement 

x Hazardous materials removal 

x Law enforcement 

x Legal land or mineral estate ownership surveys 

x Engineering support assistance in mapping 

x Field visits for the design of projects, include clearance inventories 

x Tree sampling (including using the 3P fall, buck, and scale sampling method) 

x Project implementation and plan effectiveness monitoring 

x Incidental live or dead tree removal for safety or operational reasons 

x Wildlife, fisheries, or plant population monitoring 
Chapter 2 - Alternatives 

40 | Page

Potential Mitigation Measures that are Common to All 

Action Alternatives 

BLM Participation in Barred Owl Management 

The U.S. Fish and Wildlife Service is currently authorizing the removal of barred owls from four study 

areas in California, Oregon, and Washington to evaluate the feasibility, cost, and effectiveness of barred 

owl removal and the resulting effects to northern spotted owl populations (USDI FWS 2013). In the 

Revised Recovery Plan for the Northern Spotted Owl, Recovery Action 29 describes the design and 

implementation of large-scale barred owl control experiments to assess the effects on spotted owl site 

occupancy, reproduction, and survival (USDI FWS, 2011, p. III-65). Recovery Action 30 calls for 

management to reduce the negative effects of barred owls on spotted owls so that the recovery criterion 

for a stable population trend can be achieved. In the Revised Recovery Plan for the Northern Spotted 

Owl, the U.S. Fish and Wildlife Service acknowledges the need for aggressive strategies to address the 

threat from barred owls in the face of scientific uncertainty, and will employ an active program of 

adaptive management in order to deal with uncertainty and risk (USDI FWS 2011, p. II-6–II-10). 

Based on information in the Revised Recovery Plan for the Northern Spotted Owl (USDI FWS 2011), the 

analysis in the U.S. Fish and Wildlife Service EIS for Experimental Removal of Barred Owls to Benefit 

Threatened Northern Spotted Owls (USDI FWS 2013), and preliminary results from experimental 

removals (Diller 2013, Diller et al. 2014), barred owl management may result in decreased competition 

between barred owls and northern spotted owls, increased site occupancy by northern spotted owls, and 

increased northern spotted owl survival and reproduction. These outcomes may increase the likelihood of 

recovery of the northern spotted owl. As such, the experimental removals represent an inquiry into the 

best manner in which barred owl management can contribute to the recovery of the northern spotted owl. 

As a potential mitigation measure, the BLM would cooperate with the U.S. Fish and Wildlife Service and 

provide financial support for this 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. These actions would 

be implemented pursuant to appropriate NEPA analysis and decision-making. To the extent the BLM 

funds implementation of the Experimental Removal of Barred Owls to Benefit Threatened Northern 

Spotted Owls (USDI FWS 2013), the NEPA analysis for that action is already completed. The EIS 

prepared by the U.S. Fish and Wildlife Service describes and evaluates nine alternatives for an 

experimental removal of northern barred owls on a scale sufficient to determine if the removal would 

increase northern spotted site occupancy and improve population trends. Results from these experiments 

would be used by the U.S. Fish and Wildlife Service to inform future decisions on potential long-term 

management strategies for barred owls (USDI FWS 2013). That analysis is hereby incorporated by 

reference. 

Action Alternative Descriptions 

This section includes a summary of those features that differ among the action alternatives. Appendix B 

contains detailed descriptions by alternative of the management objectives and management direction that 

differ among the action alternatives. 
Chapter 2 - Alternatives 

41 | Page

Alternative A 

Alternative A has a Late-Successional Reserve larger than the No Action alternative (Figure 2-3, 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 (clear cuts). 

Figure 2-3. Alternative A land use allocations. 

Table 2-4. Alternative A land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

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 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 - 

Late-Successional 

Reserve 

46% 

Other 

Reserves 

7% 

Harvest Land 

Base 

14% 

Eastside 

Management 

Area 

6% 

Riparian Reserve 

27% 


Chapter 2 - Alternatives 

44 | Page

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 stands120-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 (Dry)15

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 restoration thinning to promote the development of structurallycomplex forest, but without commercial removal of timber (i.e., coarse woody debris and snag 

creation only). In dry forests, the BLM would conduct restoration activities including thinning 

and prescribed burning to promote the development of structurally-complex forest and to improve 

resilience to disturbance. In dry forests, restoration 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—

x 120 feet on either side of perennial and fish-bearing intermittent streams; and 

x 50 feet on either side of non-fish-bearing, intermittent streams. 

Outside of the inner zone, the BLM would conduct restoration thinning as needed to ensure that stands are 

able to provide trees to form stable instream structures. In moist forests, the BLM would conduct 

restoration thinning without commercial removal of timber (i.e., coarse woody debris and snag creation 

only). In dry forests, restoration 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 high-intensity 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 

 

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. 
Chapter 2 - Alternatives 

45 | Page

thinning and regeneration harvest with no retention (clear cuts). The High Intensity Timber Area has no 

snag or coarse woody debris retention requirements. 

Wildlife

Within the Harvest Land Base, Alternative A does not include—

x Specific protections for northern spotted owl known or historic sites; 

x A requirement for surveys for the marbled murrelet prior to management actions; 

x Specific management requirements for trees capable of providing marbled murrelet nesting 

structures in younger stands; or 

x 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 Federally-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. 

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 generally been vacant or inactive for 5 years or more. 

Minerals

Under Alternative A, the BLM would recommend for withdrawal from locatable mineral entry 268,981 

acres and would close 232,367 acres to salable mineral development. 

Areas of Critical Environmental Concern 

Under Alternative A, the BLM would designate 119 Areas of Critical Environmental Concern. 

Recreation Management Areas 

Alternative A includes designation of Special Recreation Management Areas at developed recreation 

sites. 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. 

Lands with Wilderness Characteristics

Alternative A includes management for wilderness characteristics of all lands with wilderness 

characteristics that are not within the Harvest Land Base. 

Wild and Scenic Rivers

Under Alternative A, the BLM would not find any of the eligible Wild and Scenic River segments 

suitable for inclusion in the National Wild and Scenic River System. 

Visual Resource Management
Chapter 2 - Alternatives 

46 | Page

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 and scenic sections of Wild and Scenic 

Rivers as Visual Resource Management Class II. The BLM would manage ACECs according to their 

visual resource inventory class. 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 2-4, 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 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. 

Figure 2-4. Alternative B land use allocations. 

 

Late-Successional 

Reserve

46% 

Other Reserves 

11% 

Harvest Land 

Base 

22% 

Eastside 

Management 

Area 

6% 

Riparian Reserve 

15% 
Chapter 2 - Alternatives 

47 | Page

Table 2-5. Alternative B land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

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% 

Occupied Marbled Murrelet Sites 41,633 2% 

Predicted Marbled Murrelet Sites 13,738 <1% 

Occupied 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 - 

 


Chapter 2 - Alternatives 

50 | Page

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 (Dry)17

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 restoration thinning to promote the development of structurally-complex forest, which 

may include commercial removal of cut trees. In dry forests, the BLM would conduct restoration 

activities including thinning and prescribed burning to promote the development of structurallycomplex 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—

x One site-potential tree height on either side of fish-bearing and perennial streams; 

x 100 feet on either side of debris-flow-prone, non-fish-bearing, intermittent streams; and 

x 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—

x 60 feet on either side of perennial and fish-bearing intermittent streams; and 

x 50 feet on either side of non-fish-bearing, intermittent streams. 

Outside of the inner zone, the BLM would conduct restoration 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 

 

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. 
Chapter 2 - Alternatives 

51 | Page

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 to 30 percent of the stand. In the Low 

Intensity Timber Area, the BLM would rely on natural tree regeneration after timber harvest. Timber 

harvest in the Moderate Intensity Timber Area includes thinning and regeneration harvest with retention 

of 5 to 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—

x No specific protections for northern spotted owl known or historic sites; 

x 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; 

x The protection of trees capable of providing marbled murrelet nesting structures in younger 

stands in marbled murrelet Zone 1; and 

x 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 and 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. 

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 generally been vacant or inactive for 5 years or more. 

Minerals

Under Alternative B, the BLM would recommend for withdrawal from locatable mineral entry 266,473 

acres and would close 226,367 acres to salable mineral development. 

Areas of Critical Environmental Concern 

Under Alternative B, the BLM would designate 114 Areas of Critical Environmental Concern. 

Recreation Management Areas 

Alternative B includes designation of Special Recreation Management Areas at currently developed 

recreation facilities. 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 
Chapter 2 - Alternatives 

52 | Page

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. 

Lands with Wilderness Characteristics

Alternative B includes management for wilderness characteristics of all lands with wilderness 

characteristics that are outside of the Harvest Land Base and are compatible with existing and potential 

recreation opportunities. 

Wild and Scenic Rivers

Under Alternative B, the BLM would recommend for inclusion in the National Wild and Scenic River 

System the eligible Wild and Scenic River segments with recreation identified as an Outstandingly 

Remarkable Value and the eligible river segments that the BLM found suitable during its administrative 

process (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 and scenic sections of Wild and Scenic 

Rivers as Visual Resource Management Class II. The BLM would manage ACECs according to their 

visual resource inventory class. The BLM would manage all other lands as Visual Resource Management 

Class IV. 
Chapter 2 - Alternatives 

53 | Page

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 2-5, Table 2-6, and Map 2-4). 

Figure 2-5. Sub-alternative B land use allocations. 

 

Late-Successional 

Reserve 

57% 

Other Reserves 

9% 

Harvest Land 

Base 

12% 

Eastside 

Management 

Area 

6% 

Riparian Reserve 

16% 
Chapter 2 - Alternatives 

54 | Page

Table 2-6. Sub-alternative B land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

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% 

Occupied Marbled Murrelet Sites 41,633 2% 

Predicted Marbled Murrelet Sites 13,738 <1% 

Occupied 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 - 

 



Chapter 2 - Alternatives 

58 | Page

Alternative C 

Alternative C has the largest Harvest Land Base of any of the alternatives (Figure 2-6, 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 (clear 

cuts). Alternative C has the smallest acreage in the Riparian Reserve of all of the 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. 

Figure 2-6. Alternative C land use allocations. 

 

Late-Successional 

Reserve 

38% 

Other Reserves 

11% 

Harvest Land 

Base

30% 

Eastside 

Management 

Area 

6% 

Riparian Reserve 

15% 
Chapter 2 - Alternatives 

59 | Page

Table 2-7. Alternative C land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

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% 

Occupied Marbled Murrelet Sites 40,468 2% 

Predicted Marbled Murrelet Sites 2,761 <1% 

Occupied 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 - 

 


Chapter 2 - Alternatives 

62 | Page

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 (Dry)18

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 restoration 

thinning to promote the development of structurally-complex forest, which may include 

commercial removal of cut trees. In dry forests, the BLM would conduct restoration 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—

x 150 feet on either side of fish-bearing and perennial streams; and 

x 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—

x 60 feet on either side of fish-bearing and perennial streams; and 

x 50 feet on either side of non-fish-bearing, intermittent streams. 

Outside of the inner zone, the BLM would conduct restoration 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 

 

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. 
Chapter 2 - Alternatives 

63 | Page

thinning and regeneration harvest with no retention (clear cuts). The High Intensity Timber Area has no 

snag or coarse woody debris retention requirements. 

Wildlife

Within the Harvest Land Base, Alternative C includes—

x No specific protections for northern spotted owl known or historic sites; 

x 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; 

x No specific management requirements for trees capable of providing marbled murrelet nesting 

structures in younger stands; and 

x 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 federally 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. 

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 generally been vacant or inactive for 5 years or more. 

Minerals

Under Alternative C, the BLM would recommend for withdrawal from locatable mineral entry 269,963 

acres and would close 246,584 acres to salable mineral development. 

Areas of Critical Environmental Concern 

Under Alternative C, the BLM would designate 111 Areas of Critical Environmental Concern. 

Recreation Management Areas 

Alternative C includes designation of Special Recreation Management Areas at currently developed 

recreation facilities. 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, 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. 

Lands with Wilderness Characteristics

Alternative C includes management for wilderness characteristics of lands with wilderness characteristics 

that are not within the Harvest Land Base and are compatible with existing and potential recreation. 
Chapter 2 - Alternatives 

64 | Page

Wild and Scenic Rivers

Under Alternative C, the BLM would recommend for inclusion in the National Wild and Scenic River 

System those eligible river segments that the BLM found suitable during the BLM’s administrative 

process. 

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 the wild sections of Wild 

and Scenic Rivers) as Visual Resource Management Class I and scenic sections of Wild and Scenic 

Rivers as Visual Resource Management Class II. The BLM would manage ACECs according to their 

visual resource inventory class. The BLM would manage all other lands as Visual Resource Management 

Class IV. 

 
Chapter 2 - Alternatives 

65 | Page

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 2-7, Table 2-8, and Map 2-

6). 

Figure 2-7. Sub-alternative C land use allocations. 

 

Late-Successional 

Reserve 

55% 

Other Reserves 

7% 

Harvest Land 

Base

20% 

Eastside 

Management 

Area 

4% 

Riparian Reserve 

14% 
Chapter 2 - Alternatives 

66 | Page

Table 2-8. Sub-alternative C land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

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% 

Occupied Marbled Murrelet Sites 40,468 2% 

Predicted Marbled Murrelet Sites 740 <1% 

Occupied 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 2% 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 - 

 



Chapter 2 - Alternatives 

70 | Page

Alternative D 

Alternative D has the smallest Late-Successional Reserve of any of the action alternatives (Figure 2-8, 

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 all of the action alternatives. 

Figure 2-8. Alternative D land use allocations. 

 

Late-Successional 

Reserve 

29% 

Other Reserves

10% 

Harvest Land 

Base 

26% 

Eastside 

Management 

Area 

6% 

Riparian Reserve 

29% 
Chapter 2 - Alternatives 

71 | Page

Table 2-9. Alternative D land use allocations. 

Allocation Acres 

Total 

Acres 

(%) 

Sub-Allocation Acres 

Total 

Acres 

(%) 

LateSuccessional 

Reserve

714,292 29% 

Structurally-Complex Forest 482,920 19% 

Northern Spotted Owl Sites 96,666 4% 

Occupied Marbled Murrelet Sites 33,037 1% 

Predicted Marbled Murrelet Sites 91,816 4% 

Occupied 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 - 

 


Chapter 2 - Alternatives 

74 | Page

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-yearsold 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 restoration 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 to 15 

percent of the stand. 

Wildlife

Within the Harvest Land Base, Alternative D includes—

x Specific protections to maintain habitat within the home ranges of all northern spotted owl known 

and historic sites; 

x A requirement for surveys for the marbled murrelet prior to management actions in marbled 

murrelet Zones 1 and 2 and protection of habitat within 1⁄2 mile around newly discovered 

occupied sites; 

 

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. 
Chapter 2 - Alternatives 

75 | Page

x Protection of trees capable of providing marbled murrelet nesting structures in younger stands in 

marbled murrelet Zones 1 and 2; and 

x 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. 

Grazing

Under Alternative D, the BLM would eliminate livestock grazing by terminating existing grazing 

authorizations and making the allotments unavailable for grazing. 

Minerals

Under Alternative D, the BLM would recommend for withdrawal from locatable mineral entry 307,308 

acres and would close 239,618 acres to salable mineral development. 

Areas of Critical Environmental Concern 

Under Alternative D, the BLM would designate 118 Areas of Critical Environmental Concern. 

Recreation Management Areas 

Alternative D includes designation of Special Recreation Management Areas where the BLM recognizes 

recreation opportunities and setting characteristics for their unique value, importance, and distinctiveness 

on public domain lands and acquired lands and on O&C lands not available for sustained-yield timber 

production (“The O&C Act and the FLPMA” in Chapter 1). 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, Alternative D would include 

designation of Special and Extensive Recreation Management areas where the BLM is seeking to address 

activity-specific demand and to increase travel and tourism opportunities. 

Lands with Wilderness Characteristics

Alternative D would not include the management for wilderness characteristics of any lands with 

wilderness characteristics. 

Wild and Scenic Rivers

Under Alternative D, the BLM would recommend all 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 and scenic sections of Wild and Scenic 

Rivers as Visual Resource Management Class II. The BLM would manage ACECs according to their 

visual resource inventory class. The BLM would manage all other lands according to their visual resource 

inventory class, except that in the Harvest Land Base, lands inventoried as Visual Resource Inventory 

Class II would be managed as Visual Resource Management Class III. 
Chapter 2 - Alternatives 

76 | Page

Preferred Alternative 

Consistent with the BLM planning regulations (43 CFR 1610.4-7) and as part of the BLM’s commitment 

to an open and transparent planning process, the BLM is identifying Alternative B as its preferred 

alternative at the Draft RMP/EIS stage. In identifying the BLM preferred alternative, the BLM evaluated 

how well each of the alternatives in the Draft RMP/EIS would respond to the purpose and need for action 

and the guidance for the formulation of alternatives, as well as the effects of each of the alternatives 

relevant to the issues identified for detailed analysis. In this evaluation, the cooperating agencies provided 

feedback that the BLM considered in identifying the preferred alternative. 

The identification of the preferred alternative does not constitute a commitment or decision. Nor does it 

mean that the BLM will necessarily present the preferred alternative as the Proposed RMP in the 

Proposed RMP/Final EIS. Instead, the BLM is simply identifying that Alternative B provides the most 

useful starting point from which to construct a Proposed RMP based on the analysis in this Draft 

RMP/EIS. 

The BLM has identified Alternative B as the preferred alternative because the effects analysis 

demonstrates that it would—

x Create a network of large blocks of northern spotted owl habitat across the landscape; 

x Provide active management with designated northern spotted owl critical habitat consistent with 

the recovery plan for the northern spotted owl; 

x Increase marbled murrelet habitat over time; 

x Create habitat for species associated with complex early-successional habitat; 

x Speed the redevelopment of structurally-complex forest conditions after regeneration harvest; 

x Protect the river values associated with the six river segments that the BLM has identified as 

meeting the Wild and Scenic River suitability requirements; 

x Provide more sustained-yield timber harvest than the current Allowable Sale Quantity declared in 

the 1995 RMPs; and 

x Provide more payments to counties from timber harvest on BLM-administered land than the 

counties would receive at the current Allowable Sale Quantity declared in the 1995 RMPs. 

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. Recognizing this, the BLM will seek to develop a 

Proposed RMP that would also—

x Reduce the risk of adverse effects to listed fish and water quality; 

x Increase protection of unique recreation settings and increase recreation use; 

x Increase protection of identified lands with wilderness characteristics; and 

x Minimize the spread of Sudden Oak Death. 

In developing the Proposed RMP, the BLM may therefore make modifications to the design of 

Alternative B; make modifications to the design of a different alternative analyzed in the Draft RMP/EIS; 

or develop a new alternative from within the spectrum of alternatives considered in the Draft RMP/EIS. 

In developing the Proposed RMP, the BLM will also consider public comments on the Draft RMP/EIS 

and feedback from cooperating agencies. 
Chapter 2 - Alternatives 

77 | Page

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–

x It does not meet the purpose and need (see Chapter 1 for the purpose and need); 

x It is technically or economically infeasible; 

x 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); 

x Its implementation is remote or speculative; 

x It is substantially similar to an alternative being considered in detail; or 

x It would have substantially similar effects to an alternative being considered in detail. 

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. 

This Draft RMP/EIS does make use of a reference analysis of no timber harvest on BLM-administered 

lands. This reference analysis is not a reasonable alternative. Instead, this Draft RMP/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 Draft RMP/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 

continuation of the practices from a specific year (or set of years) since 1995. Second, 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 (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 of current practices, the BLM 

cannot project their implementation into the future; thus, 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 for 

multiple decades into the future and provide a baseline for comparison to the action alternatives. 
Chapter 2 - Alternatives 

78 | Page

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. 

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 RMP/EIS 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 subalternative demonstrates that high 

levels of thinning cannot be maintained for extended periods to sustain an allowable sale quantity”20

(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 RMP/EIS, 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 RMP/EIS 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). 

 

20 As noted in Chapter 1, the terms “annual productive capacity,” “annual sustained yield capacity,” and “allowable 

sale quantity” are synonymous.
Chapter 2 - Alternatives 

79 | Page

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 RMP/EIS provides an approximation of the effects of this management approach, 

concluding that thinning levels can only be sustained for less than a decade. 

“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. 

Maximize Carbon Storage 

This alternative would maximize the storage of carbon on BLM-administered lands. This Draft RMP/EIS 

analyzes the effects of the alternatives on carbon storage. The BLM will consider those effects on carbon 

storage, as well as the effects on other resources, in the development of the Proposed RMP and the 

eventual selection of an RMP. However, the BLM has no specific legal or regulatory mandate or policy 

direction to manage BLM-administered lands 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: 

x 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 

x 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 

x 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 

x Departmental Manual 523 DM 1, which directs the Department of the Interior agencies to 

integrate climate change adaptation strategies into programs, plans, and operations 
Chapter 2 - Alternatives 

80 | Page

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 Draft RMP/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 Draft RMP/EIS. This alternative would leave too much older, more structurally-complex multilayered conifer forest available for timber harvest to constitute a substantial and meaningful contribution 

to maintaining older, more structurally-complex multi-layered conifer forest.

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 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. 

Increase Riparian Reserve Widths 

This alternative would include Riparian Reserves that would be wider than the Riparian Reserves 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 Reserves in the No Action alternative, because of its effect on the 

conservation and recovery of 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 for a fifteen-year period (1994-2008) in the Northwest Forest Plan area, the 

protections provided, in part, by the Riparian Reserves are improving watershed conditions (Lanigan et 

al. 2012). Additional width of Riparian Reserves would not provide additional protections for fish habitat 

or water quality. Furthermore, the Riparian Reserves in the No Action alternative were designed to meet 

an array of objectives, including broad ecological objectives and riparian and terrestrial species habitat. In 

contrast, the Riparian Reserves in the action alternatives are designed to meet narrower objectives: 

conservation and recovery of listed fish and protection of clean water, consistent with the purpose and 
Chapter 2 - Alternatives 

81 | Page

need for action. Because of these narrower objectives, the action alternatives considered in detail do not 

include widening the Riparian Reserve widths. 

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. Mar. 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. 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 and therefore would not meet the purpose 

of the action to contribute to the conservation and recovery of 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 RMP/EIS, 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” (USDI BLM 2008b, p. 484). The 2008 RMP/EIS 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 RMP/EIS 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 listed species, including the northern spotted owl, marbled murrelet, and 

listed fish. 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 late-successional 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.”
Chapter 2 - Alternatives 

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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 

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 

Table 2-10 summarizes key features of the alternatives. This table is not comprehensive and focuses on 

design features that vary substantially among the alternatives and are easily quantified and summarized. 

Appendix B provides detailed descriptions of the management objectives and management direction for 

each action alternative. 

Table 2-11 summarizes key effects of the alternatives. This table is not comprehensive and focuses on 

effects that vary substantially among the alternatives and are easily quantified and summarized. Inclusion 

or omission of effects from this table does not indicate the importance of the effects to the decisionmaking process. For example, the table does not include summarization of effects to northern spotted 

owls, because differences among the effects of alternatives cannot be summarized briefly or 
Chapter 2 - Alternatives 

83 | Page

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. 



Chapter 2 - Alternatives 

87 | Page

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. 

Diller, L. V. 2013. To shoot or not to shoot: the ethical dilemma of killing one raptor to save another. The Wildlife Professional 

7(2013): 54-57. 

Diller, L.V., J. P. Dumbacher, R. P. Bosch, R. R. Bown, and R. J. Gutierrez. 2014. Removing barred owls from local areas: 

techniques and feasibility. Wildlife Society Bulletin 38(1): 211-216. 

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 FS, Pacific 

Northwest Research Station, Portland, OR. 155 p. 

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. 

USDI BLM. 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. 

USDI BLM. 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. 

USDI FWS. 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. 

USDI FWS. 2013. Experimental removal of barred owls to benefit threatened northern spotted owls - Final Environmental 

Impact Statement. Portland, Oregon. 

http://www.fws.gov/oregonfwo/Species/Data/NorthernSpottedOwl/BarredOwl/Documents/Final_EIS.pdf. 
88 | Page

 
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Chapter 3 – Affected Environment and 

Environmental Consequence

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 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 alternatives analyzed in detail, including 

the No Action alternative. 

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 Lakeview District’s 

Klamath Falls Field Office (Map 1-1). Approximately, the entire planning area includes 22 million acres, 

but only 2.5 million acres, or 11 percent, are Federal lands administered by the BLM.31 Private 

landowners own and manage the majority of lands within the planning area (Figure 3-9).

 

31 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). 
Chapter 3 - Affected Environment and Environmental Consequence

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Figure 3-9. 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 3-10). The physiographic provinces vary in vegetation, 

hydrology, geology, and other processes (e.g., fire-return intervals) (FEMAT 1993). 

Private/Other

54%

BLM

11%

Forest Service

30%

Other Federal

1%

State/Local

4%

Chapter 3 - Affected Environment and Environmental Consequence

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Table 3-12. Land status of the decision area. 

Land Status Acres Percent of Decision Area

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%
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Analytical Methodologies and Assumptions 

This section describes the overall scope and analytical approach for this Draft RMP/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 (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 substantial 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 to offhighway vehicle use, 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 

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 are not certain, the BLM can project a reasonable forecast of 

future actions consistent with the management direction of the alternatives for the analysis in this Draft 

RMP/EIS. The section below on vegetation modeling includes 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 Draft RMP/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 
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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. 

As the Council on Environmental Quality points out, in guidance issued on June 24, 2005, the 

“environmental analysis required under NEPA is forward-looking,” and 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 Draft RMP/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 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. 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 sitespecific actions that would occur in the future on lands managed by others over the time period analyzed 
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in the Draft RMP/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 consider as reasonably foreseeable 

actions for analyzing cumulative effects, including the U.S. Forest Service revision of the OkanaganWenatchee Forest Plans and the Jordan Cove Energy and Pacific Connector Pipeline Project. 

Revision of the Okanagan-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 draft 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. 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. 

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). The BLM is a cooperating agency in the 

preparation of that draft 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. If the Pacific Connector pipeline were to be implemented prior to this RMP revision, 

implementation would require RMP amendments of the Coos Bay, Roseburg, and Medford District 

RMPs. If the Pacific Connector pipeline were to be implemented after the completion of this RMP 

revision, and if the BLM were to adopt any of the action alternatives as described in this Draft RMP/EIS 

as the eventual RMP, implementation would require RMP amendments as well. 

The 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 800 acres of BLM-administered lands: 61 acres of urban-built-up 

and transportation-utility lands, less than 0.1 acre of agricultural land, 62 acres of rangeland, 674 acres of 

forest, 0.8 acre of wetlands, 1 acre of water, and 2 acres of barren lands/quarries. The construction of the 

pipeline would require the temporary clearing of vegetation within a 95-foot-wide construction right-ofway. 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 2,108 acres of forest and the permanent loss of 542 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 Draft EIS, which is incorporated here by 

reference (FERC 2014, pp. 4-12 – 4-241; 4-369 – 4-546). 
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96 | Page

No Federal lands would be utilized for the Jordan Cove LNG terminal. Construction of the LNG 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 LNG terminal are described in more detail in the 

Jordan Cove Energy and Pacific Connector Pipeline Project Draft EIS, which is incorporated here by 

reference (FERC 2014, pp. 4-2 – 4-11). 

The Jordan Cove Energy and Pacific Connector Pipeline Project is a reasonably foreseeable future action, 

in that there is a formal proposal for the project. This Draft RMP/EIS addresses the cumulative effects of 

the Jordan Cove Energy and Pacific Connector Pipeline Project together with the effects of this proposed 

action in those specific resource sections for which analysis at this scale would provide meaningful 

information. 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 this 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 this scale of analysis and 

would not have the potential to alter any of the analytical conclusions related to vegetation and habitat in 

this 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 this 

Draft RMP/EIS. 

The BLM would address the cumulative effect of BLM implementation actions together with the effects 

of the Jordan Cove Energy and Pacific Connector Pipeline Project in project-level NEPA analysis, as 

appropriate. Project-level cumulative effects analysis would include the Jordan Cove Energy and Pacific 

Connector Pipeline Project if the effects of the Jordan Cove Energy and Pacific Connector Pipeline 

Project would be within the geographic and temporal scope of the effects of the BLM implementation 

action and would have a combined effect with the BLM implementation action (see generally USDI BLM 

2008, pp. 57-61). 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 this Draft RMP/EIS, given the small acreage and localized effects of the Jordan Cove Energy and 

Pacific Connector Pipeline Project. 

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 
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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. 

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 Draft RMP/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 Draft RMP/EIS set the 

temporal scale of analysis based on a time frame that illuminates differences in the outcomes under the 

alternatives. 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 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 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 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 Draft RMP/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 
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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 Draft RMP/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 fine-scale features, 

such as streams and roads, which the BLM could not previously consider. The data summaries in the 

analyses in the Draft RMP/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 from the date of the decision. That is, the BLM has modeled and analyzed implementation of 

actions at the level directed by each alternative from January 2013 forward, as discussed further in the 

following section. For some alternatives, especially those that differ substantially from the current 

implementation of the 1995 RMPs, the necessary organization transition may take several years before 

the BLM would be able to implement a new RMP fully. For example, if the amount of timber harvest 

under a new RMP were to be substantially higher than the current timber harvest levels, the BLM might 

need up to five years to reach full implementation of the new RMP, given the time required to plan, 

prepare, and implement new timber sales. If the amount of timber harvest under a new RMP were to be 

similar to or lower than the current timber harvest levels, a lengthy transition period would not be 

required. Due to the speculative nature of this transition period and the widely varying difference in the 

alternatives from the current implementation of the 1995 RMPs, the BLM does not attempt to account for 

this transition period in the analysis of effects in the Draft RMP/EIS. If the eventual Proposed RMP 

differs substantially from the current implementation of the 1995 RMPs, such that the BLM anticipates a 

lengthy transition period, the BLM will address this transition period in the analysis for the Proposed 

RMP/Final EIS. 

For the purpose of this analysis, the BLM assumed adequate funding and staffing to implement the 

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 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. 
Chapter 3 – Affected Environment and Environmental Consequence

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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. For each land use allocation, the 

BLM described treatments to reflect the management direction for each alternative. 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. 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 land. 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 threatened, endangered, and special 

status plant species locations. 

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. 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. Nevertheless, it is not possible 

to model different future wildfire scenarios under different alternatives, given the following: 

x The inherent challenges in predicting the location and timing of future stochastic events 

x The inability at this scale of analysis to forecast the site-specific location and conditions of future 

management actions 

x 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 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. 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. 
Chapter 3 - Affected Environment and Environmental Consequence

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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, 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. 

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, the Woodstock model projected development of the forest under the alternatives 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 spatiallyexplicit 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 
Chapter 3 – Affected Environment and Environmental Consequence

101 | Page

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. 

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 the BLM offices32, 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 inches or larger diameter at breast height and is larger and older than 

other trees in the stand. The 2008 EIS provides more 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: 

x Non-forest 

x Woodland 

x Forest 

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 

 

32 Since there are 5 Districts and 1 Field Office, for the rest of this analysis, these will be referred to as BLM offices 

or offices. 
Chapter 3 - Affected Environment and Environmental Consequence

102 | Page

 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 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 under each alternative. 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 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, consequently, the 

calculated annual productive capacity varies among the alternatives as well. 

The modeling also provided outputs related to timber production from the reserve land use allocations 

under each alternative. 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, consequently, the 

calculated timber production from the reserve land use allocations varies among the alternatives as well. 

Unlike the annual productive capacity, 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 on socio-economic conditions, including employment 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 this 

Draft RMP/EIS, the BLM has 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 LateSuccessional 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 this Draft 

RMP/EIS only includes the effects on forest management and northern spotted owls. 

Reference Analysis 

A reference analysis of No Timber Harvest is included in this Draft RMP/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 
Chapter 3 – Affected Environment and Environmental Consequence

103 | Page

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. 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. 

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 FS, 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. 

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. 

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. 

Federal Energy Regulatory Commission. (FERC). 2014. Draft Environmental Impact Statement – Jordan Cove Energy and 

Pacific Connector Pipeline Project. Washington, D.C. Vol. I-II 

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, USA. Canadian Journal of Forest Research 32(4): 725-741. 

dx.doi.org/10.1139/X02-011. 

Chapter 3 – AE&EC – Air Quality

105 | Page

Air Quality 

Key Points 

x All action alternatives are expected to produce more particulate emissions than the No Action 

alternative and current conditions; however, adherence to the requirements of the Oregon Smoke 

Management Plan should continue to limit impacts to human health and visibility from prescribed 

fires. 

x Based on the amount of area where active management would occur, Alternative C has the 

greatest potential to reduce adverse effects to human health and visibility from wildfires over the 

long-term while the No Action likely would have the least effect. 

Issue 1 

How will the proposed management actions affect PM2.5, PM10, and expected visibility? 

Summary of Analytical Methods 

The Woodstock model produced estimates of the acres of activity fuels treatments by treatment type (e.g., 

hand pile burning, machine pile burning, broadcast burning) for each alternative. The 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. These details were 

used in 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 (available at 

http://www.oregon.gov/odf/pp./fire/smp/smkmgtannualrpts.aspx) and visibility information from the 

Interagency Monitoring of Protected Visual Environments (IMPROVE) program (available at 

http://vista.cira.colostate.edu/improve/) 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. 

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. 
Chapter 3 - AE&EC – Air Quality

106 | Page

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 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 (VOCs), 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 prescribed burning in 

western Oregon is conducted under requirements in the Oregon Smoke Management Plan 

(http://arcweb.sos.state.or.us/pp./rules/oars_600/oar_629/629_048.html). 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 Congressionally-designated wilderness areas, identified under the Clean Air Act 

as requiring the highest level of protection.33 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. 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 wildernesses 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 estimates 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).

33 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 5000 

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. 


Chapter 3 – AE&EC – Air Quality

109 | Page

BLM must register all prescribed burns on BLM-administered lands within the planning area with ODF. 

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. 

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 3-14). Index values range from 0 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 3-14. Air Quality Index (AQI) 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., oxides of nitrogen (NOx) and volatile organic 

compounds (VOCs)) 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 expected to 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 the greatest activity for prescribed burning is 

during spring and fall. Therefore, it is very unlikely that any of the alternatives would have a notable 

effect on problematic ozone levels in the planning area and are not analyzed 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 nonattainment pollutants (or their precursors) exceeds specific thresholds (known as di minimis levels). The 

intent of the General Conformity requirements is to prevent the air quality impacts of Federal actions 

from causing or contributing to a violation of the National Ambient Air Quality Standards (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 (available at 
Chapter 3 - AE&EC – Air Quality

110 | Page

http://www.epa.gov/air/genconform/), Federal agencies must make a determination that proposed actions 

in Federal non-attainment areas conform to the applicable EPA-approved State Implementation Plan 

before an action is taken. 

All prescribed burns within western Oregon must comply with the Oregon Smoke Management Plan, 

which prohibits smoke intrusions into smoke sensitive receptor areas. As a result, the Conformity Rule is 

not applicable for BLM prescribed burning actions within non-attainment areas since the burning would: 

1) not likely cause or contribute to new violations of Federal air quality standards; 2) would not increase 

the severity of existing violations for Federal and State air quality standards; or 3) would not 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 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, landings) occurs in 

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 g/m3 (it 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 1000 tons per year and exceeded 6000 tons per year in 2006, 2007, and 2012. The 

2012 fire season resulted in the highest estimated PM2.5 emissions from wildfire at nearly 12,000 tons. 

However, most of these emissions were from the large rangeland wildfires in southeastern Oregon. Data 

for the 2013 fire season were not available; however, there were several large wildfires in southwestern 

Oregon in 2013 that likely contributed a significant amount of particulate pollution, and potentially 

created problematic surface ozone concentrations as well. 

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 3-11). 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 BLM 

with only minor contributions from the National Park Service and U.S. Fish and Wildlife Service. 
Chapter 3 – AE&EC – Air Quality

111 | Page

 Figure 3-11. 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. 

BLM prescribed burning comprises most of the Other Federal category. 

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 g/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 g/m3

, effective 18 March 2013. Whether this change 

will result in any areas designated as non-attainment for the annual PM2.5 standard will not be known until 

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 smoke 

sensitive receptor areas can and do occur. The occurrence of intrusions is not related to the number of 

acres burned in any given year (Figure 3-12), 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. 

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. 
Chapter 3 - AE&EC – Air Quality

112 | Page

Figure 3-12. Number of smoke intrusions attributed to BLM prescribed fires into sensitive receptor areas 

compared to annual acres burned from 2002 through 2013 in western Oregon. 

Nearly all intrusions were in southwest Oregon. Sources: ODF annual smoke reports 2002-2013, available at 

http://www.oregon.gov/odf/pages/fire/smp/smkmgtannualrpts.aspx. 

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 3-15). Visibility 

is generally improving at Crater Lake National Park and the Mount Hood and Kalmiopsis wildernesses, 

although not all trends are significant. Visibility at Three Sisters Wilderness is slowly degrading, although 

the trend is not significant yet. 

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

Acres Burned by Non-USFS Federal 

BLM - Attributable Smoke Intrusions

Agencies (mostly BLM)

Comparison of Acres Burned and Smoke Intrusions

Acres Burned by Federal Agencies (except USFS)

BLM-Attributed Intrusions
Chapter 3 – AE&EC – Air Quality

113 | Page

Table 3-15. Visibility conditions and trends at four mandatory Class 1 areas within or adjacent to the 

planning area from 2003 through 2012. The main contributors to the haziest days are organic carbon and 

ammonium sulfate. 

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) 

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) 

Trends in haziest 

days 

Non-significant 

downward 

Significant 

downward 

Non-significant 

downward 

Non-significant 

upward 

Source: IMPROVE website: http://vista.cira.colostate.edu/improve/. Accessed 18 November 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 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 3-13). 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 

or the Kalmiopsis Wilderness. 

 
Chapter 3 - AE&EC – Air Quality

114 | Page

Figure 3-13. Example of identification of the 20 percent worse days in a given year and the proportional 

contribution of various factors to reduced visibility. 

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. Conversely, 

wildfire adverse impacts tend to be of longer duration (days to weeks) and occur over a much broader 

area and produce much unhealthier conditions (Figure 3-14).
Chapter 3 – AE&EC – Air Quality

115 | Page

Figure 3-14. 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 

woodstoves with some smoke from pile burning possible. Three intrusions attributed to BLM-prescribed burning into mandatory 

Class 1 areas did occur. 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 3-15) and for nine days in both Grants Pass and Cave Junction (Figure 3-16). It also 

resulted in severe degradation of visibility in Crater Lake National Park (Figure 3-17) and the Kalmiopsis 

Wilderness (data not shown). 
Chapter 3 - AE&EC – Air Quality

116 | Page

Figure 3-15. Air quality index for 2013 for Medford. 

The large spike in late July was due to a series of wildfires, of which the Douglas Complex was the largest. “FF” refers to the 

days where air quality degradation was attributed to forest fires. Additional air quality degradation occurred from November 

through February from sources other than prescribed fire. Source: ODEQ 2014. 

Figure 3-16. Air quality index for 2013 for Grants Pass. 

The large spike in late July was due to a series of wildfires, of which Douglas Complex was the largest. “FF” refers to the days 

where air quality degradation was attributed to forest fires. Source: ODEQ 2014. 
Chapter 3 – AE&EC – Air Quality

117 | Page

Figure 3-17. Degradation of visibility from burning vegetation in 2013 as measured through light 

scattering (inverse megameters) at Crater Lake National Park. 

Wildfires typically create 5-10 times greater impacts than other types of events and over several weeks. Source: IMPROVE 

website, available at http://views.cira.colostate.edu/fed/DataWizard/Default.aspx , accessed 25 November 2014. 

Environmental Effects 

Particulate Matter Emissions 

Since the hazardous fuels prescribed fire program does not vary between alternatives or over time, the 

expected emissions are constant. Estimated wildfire emissions vary over time, but not between 

alternatives. Therefore, the main variable in estimated particulate emissions is the amount of activity fuels 

prescribed burning both over time and between alternatives. Since fuel treatment levels are projected to 

increase under all alternatives, including the No Action alternative, relative to actual levels in the past, 

emissions of both PM10 and PM2.5 are expected to increase relative to the 2013 baseline (Figures 3-18 

and 3-19). 
Chapter 3 - AE&EC – Air Quality

118 | Page

Figure 3-18. Expected increases in PM10 emissions from prescribed fire and wildfire over time and under 

each alternative relative to the estimate for current prescribed fires and wildfires. 

Figure 3-19. Expected increases in PM2.5 emissions from prescribed fire and wildfire over time and under 

each alternative relative to the estimate for current prescribed fires and wildfires. 

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, 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

110%

2023 2033 2043 2053 2063

Percent Change in PM10 Emissions

Year

No Action Alt. A Alt. B Alt. C Alt. D

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

110%

2023 2033 2043 2053 2063

Percent Change in PM2.5 Emissions

Year

No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 – AE&EC – Air Quality

119 | Page

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 consumed reported to ODF, with insufficient information to determine the 

proportions of actual treatment methods. Thus, the current condition is based on a generic multiplier 

applied to the reported tons consumed. Whether this value represents an under-estimation or overestimation of current conditions is not known. The projected emissions were based on more detailed 

information using more sophisticated tools than a generic multiplier. 

Similar to the current condition, the Medford District is projected to 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 fuel 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 varies by alternative. 

Under all alternatives, including the No Action alternative, the Medford District would produce the most 

emissions from prescribed burning (Figure 3-20), with the highest emissions under Alternative B and 

lowest under Alternative A. Emissions under the No Action alternative and Alternative D would be 

similar. 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 their associated smoke sensitive areas, along with the Kalmiopsis Wilderness and 

Crater Lake National Park. Much of the activity for natural fuels burning consists of pile burning, which 

typically occurs in fall and winter. In fall, atmospheric instability and relatively frequent storms tends to 

limit smoke impacts during the day, but areas down drainage from burn locations could experience smoke 

effects at night. Inversions in winter could result in prescribed fire smoke mingling with woodstove 

smoke to adversely affect air quality (e.g., Figure 3-15), although compliance with the smoke 

management plan usually limits degradation of air quality. 
Chapter 3 - AE&EC – Air Quality

120 | Page

Figure 3-20. Average annual PM2.5 emissions from prescribed burning over the 50-year analysis period 

by district or field office and alternative. 

The Klamath Falls Field Office would produce its highest emissions under Alternative A with no 

difference in emissions under the No Action alternative and Alternatives B through D (Figure 3-20). 

Potential effects to the Klamath Falls Field Office non-attainment area likely would not differ from those 

currently experienced. Similarly, emissions from the Coos Bay District would change little from present 

emissions under all alternatives. 

Emissions from the Eugene and Salem Districts would increase under all alternatives, except for 

Alternative D in the Eugene District, relative to the current condition, with the biggest increases under 

Alternative C (Figure 3-20). As a result, the probability of adverse impacts to smoke sensitive receptor 

areas 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 result in additional adverse 

impacts to air quality in Oakridge, although the combined effects of the location of BLM-administered 

parcels relative to Oakridge, compliance with the 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 smoke management plan is expected to limit adverse effects to visibility and 

air quality across all alternatives, although some issues are likely to 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 action alternatives would result in additional effects on visibility and air quality from 

smoke intrusions as compared to the observed past. 

99 180 198 340

132

140 106 144

200

120

607 583

697

666

618

141 183

145

144

143

118

139

149

298

85

87

92

74

162

58

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

2,000

No Action Alt. A Alt. B Alt. C Alt. D

Average PM2.5 Emissions (Tons per Year)

Coos Bay Eugene Klamath Falls Medford Roseburg Salem
Chapter 3 – AE&EC – Air Quality

121 | Page

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. 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, Volkova et al. 2014). Less active 

management under the 1995 RMPs has tended to create more homogeneous landscapes, particularly with 

respect to stand structure, promoting larger patches of similar burn severity, longer-term smoldering, and 

resulting emissions. 

The number of acres receiving active management indicates the potential to reduce adverse effects from 

wildfires over time. How much area would need to be treated before such an effect occurred is not known, 

but likely would take two or more decades of increased land management activity to begin to become 

apparent. Table 3-16 depicts a relative rating for each alternative for each district within the planning area 

using land allocation as a basis for identifying the amount of area expected to receive some degree of 

active management. Administrative reserves, Congressional reserves, Late-successional Reserves where 

the primary approach is protection and the inner, no-cut areas of Riparian Reserves are assumed to have 

little to no active management. 

Table 3-16. Relative risk to human health and visibility by alternative based on the estimated acres 

expected to receive some degree of active management. The highest risk is 5, the lowest risk is 1, and a 

tie between two alternatives is x.5. 

District No Action Alt. A Alt. B Alt. C Alt. D

Coos Bay 5 2.5 2.5 1 4 

Eugene 5 2 3.5 1 3.5 

Medford 4.5 4.5 2 1 3 

Roseburg 5 2 3.5 1 3.5 

Salem 5 2 3 1 4 

Means 5 3 3 1 4 

A high proportion of the Klamath Falls Field Office (over 80 percent) would be available for active 

management due to the high number of acres in the eastside management area, so it was not rated. Risks 

to human health and visibility from wildfires likely would not differ from current conditions. On all other 

districts, the No Action alternative would have the lowest number of acres under active management. 

Current trends towards forest homogenization would continue, increasing the risk of large wildfires, large, 

homogeneous burn patches, and prolonged smoldering. Those factors, in turn, are expected to increase the 

risks to human health and visibility from wildfires over time. 

Alternative C would have the most area under active management on each office, so would have the 

highest potential to create sufficient landscape heterogeneity and lower risks to human health and 

visibility over time. Alternative C also includes a large amount of clear-cutting, which can create 

landscape homogeneity although it does not necessarily follow that it will. Harvest levels would remain 

below that of the 1980s and a greater diversity of general harvest prescriptions would occur. Whether the 

amount of active management would generally have a larger influence than the amount of clear-cutting on 

wildfire burn patterns, would depend on the distribution and sizes of clearcut patches and subsequent 

management of the next stand, particularly in relation to adjoining private forestlands. 
Chapter 3 - AE&EC – Air Quality

122 | Page

The potential risk of adverse effects under alternatives A, B, and D depend more on the BLM office in

question. As such, no other alternative clearly stands out in its potential to reduce the potential risks to 

human health and visibility from wildfires. Overall, alternatives A and B would result in similar effects 

over the planning area as a whole, with some reduced risks relative to No Action and Alternative D, but 

greater risks relative to Alternative C. In the Medford and Roseburg Districts, the two with the most 

active fire regimes, the order of potential risk reduction from greatest to least would be Alternative C, 

Alternative B, Alternatives A and D, and the No Action alternative. 

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. 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 

EPA. 2013. 40 CFR 50-53, 58: National ambient air quality standards for particulate matter, Final Rule. Federal Register 78: 

3085-3287. 

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 managament guide for prescribed 

and wildland fire 2001 edition. National Wildfire Coordination Group, Boise, ID. 

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. 

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: 184-203. 

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: 643-655. 

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.

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. 

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. 

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. 

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.
Chapter 3 – AE&EC –Areas of Critical Environmental Concern

123 | Page

Areas of Critical Environmental Concern 

Key Points 

x The No Action alternative would provide special management attention or interim special 

management attention to all 126 existing and potential Areas of Critical Environmental Concern. 

x The action alternatives consider the designation of 12135 potential (designated, old, and 14 new) 

Areas of Critical Environmental Concern including 106,546 acres or about 4 percent of the 

planning area in this EIS for designation. 

x Alternative A would designate the most and Alternative C the least Areas of Critical 

Environmental Concern at 119 and 111 respectively. 

x All action alternatives would maintain 90 to 99 percent of the relevant and important values 

within the potential Areas of Critical Environmental Concern. 

x 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. 

Issue 1 

How would 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 each potential Area of Critical 

Environmental Concern’s relevant and important values. The BLM then determined if the management 

direction for other resources under each alternative protects or maintains the relevant and important 

resource values associated with each potential Area of Critical Environmental Concern (ACEC). They 

also considered whether the BLM could apply special management needed to protect relevant and 

important values so as not to 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. The 

BLM would not designate ACECs under alternatives where the needed special management would 

preclude O&C Harvest Land Base sustained-yield production. 

For every alternative, the BLM assigned each potential ACEC to one following categories: 

x Yes, the BLM would designate the entire potential ACEC under the given alternative. The area 

requires special management to maintain relevant and important values and management would 

not preclude O&C sustained-yield timber harvest at the stand level in the Harvest Land Base 

Special management may condition, but not preclude, O&C sustained-yield timber production 

x Yes, the BLM would designate a portion of the potential ACEC under the given alternative. The 

BLM removed portions of the potential ACEC where special management would conflict with 

O&C sustained-yield timber harvest; the BLM determined that the remaining area still supports 

relevant and important values needing special management 

 

35 Five would be consolidated into existing ACECs or dropped from consideration for other reasons. 
Chapter 3 - AE&EC – Areas of Critical Environmental Concern

124 | Page

x No, the BLM would not designate the potential ACEC under the given alternative because the 

area does not require special management to maintain the relevant and important values in the 

given alternative 

x No, BLM would not designate the potential ACEC under the given alternative 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 that the BLM 

designates under any particular alternative would be adequately protected by the special management 

direction and would persist for at least the life of this plan. 

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, 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: 

x Important historic, cultural, or scenic values 

x Fish and wildlife resources 

x Other natural processes or systems 

x Life and safety from natural hazards 

The BLM develops special management direction to protect relevant and important values. The BLM 

does not apply special management where other management mechanisms adequately protect the relevant

and important values or where designation is not warranted. 

The BLM designed some special management direction to move the relevant and important value onto a 

trajectory to reach a desired condition. The BLM designed 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. 

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 one or 

more of the categories of values described in the first paragraph of this section. 

The value, resource, process or system, or hazard described above must have substantial significance to 

satisfy the importance criteria. This generally means that one or more of the following characterize the 

value, resource, process or system, or hazard: 

x The qualities that give it special worth, consequence, meaning, distinctiveness, or cause for 

concern, especially compared to any similar resource, are more than locally significant 

x It has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, 

unique, endangered, threatened, or vulnerable to adverse change 

x It has been recognized as warranting protection to satisfy national priority concerns or to carry 

out the mandates of the FLPMA 

x It has qualities that warrant highlighting to satisfy public or management concerns about safety or 
Chapter 3 – AE&EC –Areas of Critical Environmental Concern

125 | Page

public welfare 

x It poses a significant threat to human life or safety, or to property 

The BLM describes relevant and important values in four categories as shown in Table 3-17. These 

categories are: 

x 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. 

x Fish and wildlife resources include, but are not limited to, habitat needed for endangered, 

sensitive, or threatened species, or habitat essential for maintaining species diversity. 

x 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. 

x Natural hazards include, but are not limited to, areas of avalanche, dangerous flooding, 

landslides, 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 3-17. Value categories for designated and formerly identified potential ACECs by district or field 

office. 

District/ 

Field Office Fish and Wildlife Historic, Cultural, and Scenic Natural Hazard Natural Process or System 

Coos Bay 14 2 - 18 

Eugene 12 2 1 20 

Klamath Falls 3 3 - 4 

Medford 7 5 - 31 

Roseburg 3 1 - 11 

Salem 22 9 1 36 

Totals 61 22 2 120 

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 land has one or more of the 

following characteristics: 

x Typical representation of a common plant or animal association 

x Unusual plant or animal association 

x Threatened or endangered plant or animal species 

x Typical representation of common geologic, soil, or water feature 

x 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 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 
Chapter 3 - AE&EC – Areas of Critical Environmental Concern

126 | Page

congressionally-designated “outstanding natural area” provides permanent protection for the values for 

which Congress designated the area. 

After the development of the 2008 FEIS, the BLM received nominations for ACECs for consideration in 

subsequent planning efforts. During the development of this Draft RMP/EIS planning effort, the BLM 

found 17 of the 32 nominated areas to meet the relevance and importance criteria and recommended them 

for further analysis as new potential ACECs. Although not currently designated as ACECs, the relevant 

and important values in these formerly identified and new potential ACECs receive interim protective 

management. The Medford District identified West Fork Illinois River as a new potential RNA and the 

Roseburg District expanded an existing RNA in the potential Beatty Creek ACEC. The BLM received no 

nominations for Outstanding Natural Areas. 

Affected Environment 

There are 87 ACECs currently designated in the planning area, 39 previously nominated ACECs that have 

been under interim protective management since late in the 1995 RMP planning process or during the 

2008 RMP planning effort (Table 3-18), and 14 new potential ACECs nominated after the 2008 RMP 

planning effort (Table 3-19). 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. 

Table 3-18. Designated (1994) and formerly identified (1995-2008) potential ACECs. Potential ACECs 

have been under interim management. 

District/

Field 

Office

Designated 

ACECs

(#)

Potential 

ACECs

(#)

Research 

Natural 

Areasa

(#)

Outstanding 

Natural 

Areas

(#)

Designated and 

Potential

ACECs (Acres)

BLM 

Lands

(Acres)

Percentage of 

BLM Acres in 

Designated and 

Potential ACECs

Coos Bay 11 5 1 - 14,258 325,824 4.4%

Eugene 13 8 5 2 14,841 313,705 4.7%

Klamath 

Falls 4 3 1 - 7,398 215,077 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 13 8 6 24,713 402,983 6.1%

Totals 87 39 32 9 92,839 2,493,655 3.7% a The research natural areas and outstanding natural areas are dually designated as ACEC, and their numbers are already counted 

within the designated and potential numbers.
Chapter 3 – AE&EC –Areas of Critical Environmental Concern

127 | Page

Table 3-19. New potential ACECs. 

District/

Field Office 

New Potential 

ACECs (#)36

New Potential ACECs 

(Acres) 

BLM Lands 

(Acres) 

Percentage of BLM 

Acres in New 

Potential ACECs 

Coos Bay 1 45 325,824 <0.01% 

Eugene 7 6,280 313,705 2% 

Klamath Falls 2 318 215,077 <0.14% 

Medford 3 6,332 810,261 1% 

Roseburg 0 - 425,805 - 

Salem 1 805 402,983 <0.20% 

Totals 14 13,780 2,493,655 1% 

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 within the planning area meet these 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, ACEC values 

range from a historical gold mining ditch in the Sterling Mine Ditch Potential ACEC in Roseburg, to a 

combination of unique geologic features, vernal pools, special status plants (natural processes and 

systems), listed fairy shrimp (fish and wildlife), a developed interpretive educational area, and scenic and 

cultural values at the Table Rocks ACEC in Medford. 

Environmental Effects 

This analysis examines the designation of ACECs and the effects on relevant and important values under 

each alternative. 

Under the alternatives, 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, their associated acres, and their relevant and 

important values. This analysis provides a broad discussion of the various resources that the BLM would 

protect through ACEC designations under the alternatives. Acres the BLM removed from ACECs to 

avoid precluding O&C Harvest Land Base sustained-yield production create all of the variation in the 

number and acres of ACEC designations under the action alternatives. As described below, 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 No Action alternative. 

The BLM considered 121 of the 140 existing and potential ACECs in the planning area for designation 

under the action alternatives. Of the 19 the BLM is not considering for designation under the action 

alternatives, the BLM found that 9 did not meet the criteria: 2 are not on BLM-administered land and 8 

were incorporated other potential ACECs. 

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 be the continued persistence of the 

relevant and important value, or a change to those values in a trend towards a desired condition. 

 

36 While 17 were found to meet the relevance and importance criteria, 3 were merged with existing ACECs, leaving 

14 new potential ACECs. 
Chapter 3 - AE&EC – Areas of Critical Environmental Concern

128 | Page

Under the action alternatives, the BLM is considering for designation: 

x 76 of 87 currently designated ACECs 

x 31 of 39 old potential ACECs that are currently under interim management 

x 14 new potential ACECs that are currently under interim management 

x 32 designated and one new potential ACECs that are also Research Natural Areas 

x 6 of 9 designated ACECs that are also Outstanding Natural Areas 

No Action 

Under the No Action alternative, there would be no change to the designation of 87 existing ACECs or 

the application of interim protective management to the 39 formerly identified and 14 new potential 

ACECs (Table 3-20). The BLM offices 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, as they currently exist, or to change those values in a 

trend towards the desired condition for those values. 

Table 3-20. All potential ACECs designations by alternative. 

District/

Field Office

No Action Alt. A Alt. B Alt. C Alt. D

# Acres # Acres # Acres # Acres # Acres

Coos Bay 11 10,159 17 14,002 17 14,002 17 14,002 17 14,002

Eugene 13 2,560 22 20,994 22 20,994 21 20,644 23 21,071

Klamath Falls 4 6,277 8 7,653 5 1,436 5 1,436 7 7,516

Medford 24 12,944 32 27,284 30 26,937 31 27,028 32 27,284

Roseburg 9 10,272 9 9,854 9 9,854 9 9,854 9 9,854

Salem 26 7,861 31 26,203 31 26,203 28 25,140 30 26,057

Totals 87 50,073 119 105,990 114 99,427 111 98,104 118 105,784

Alternative A 

Under Alternative A, the BLM would designate of 119 of the 121 existing and potential ACECs (Table 

3-20). Not precluding O&C Harvest Land Base sustained-yield production would require boundary 

revisions for three of the areas. The effect of the application of special management attention on the 

relevant and important values in these areas would be to maintain those values, as they currently exist, or 

to change those values in a trend toward the desired condition for those values. 

The BLM would not designate two potential areas. The relevant and important values in these areas 

would not receive the special management attention needed to maintain or protect them (Table 3-21). The 

areas would eventually experience a loss or degradation of these values. 
Chapter 3 – AE&EC –Areas of Critical Environmental Concern

129 | Page

Table 3-21. Potential ACECs not designated under each alternative. 

District/ 

Field Office 

No Action* Alt. A Alt. B Alt. C Alt. D 

# Acres # Acres # Acres # Acres # Acres 

Coos Bay 7 4,092 - - - - - - - - 

Eugene 15 18,159 2 85 2 85 3 436 1 9 

Klamath Falls 5 1,437 - - 3 6,217 3 6,217 1 137 

Medford 10 14,506 - - 2 347 1 256 - - 

Roseburg 3 158 - - - - - - - - 

Salem 14 15,958 - - - - 3 1,063 1 146 

Totals 54 54,310 2 85 7 6,649 10 7,972 3 292 

* While the BLM would not designate these areas under the No Action alternative, they would continue to receive protective 

management as potential ACECs. 

Alternative B 

The BLM would designate 114 of the 121 existing and potential ACECs under Alternative B (Table 3-

20). Avoiding the preclusion of sustained-yield production in the Harvest Land Base would require 

boundary revisions for four of the areas. The effect of the application of special management attention on 

the relevant and important values in these areas would be to maintain those values, as they currently exist, 

or to change those values in a trend toward the desired condition for those values. 

The BLM would not designate would not occur for seven of the areas under Alternative B (Table 3-21). 

The relevant and important values in these areas would not receive the special management attention 

needed to maintain or protect them. The areas would eventually experience a loss or degradation of these 

values. 

Alternative C 

The BLM would designate 111 of the 121 existing and potential ACECs Alternative C (Table 3-20). 

Avoiding the preclusion of sustained-yield production in the Harvest Land Base would require boundary 

revisions for five of the areas. The effect of the application of special management attention on the 

relevant and important values in these areas would be to maintain those values, as they currently exist, or 

to change those values in a trend toward the desired condition for those values. 

The BLM would not designate ten of the areas under Alternative C (Table 3-21). The relevant and 

important values in these areas would not receive the special management attention needed to maintain or 

protect them. The area would eventually experience a loss or degradation of these values. 

Alternative D 

The BLM would designate 118 of the 121 existing and potential ACECs under Alternative D (Table 3-

20). Avoiding the preclusion of sustained-yield production in the Harvest Land Base would require 

boundary revisions for ten of the areas. The effect of the application of special management attention on 

the relevant and important values in these areas would be to maintain those values, as they currently exist, 

or to change those values in a trend toward the desired condition for those values. 

The BLM would not designate three of the areas under Alternative D (Table 3-21). The relevant and 

important values in these areas would not receive the special management attention needed to maintain or 

protect them. The area would eventually experience a loss or degradation of these values. 
Chapter 3 - AE&EC – Areas of Critical Environmental Concern

130 | Page

The No Action alternative would provide special management attention or interim special management 

attention to all 126 existing and potential ACECs. Alternative A would designate the most areas and the 

most acres as ACECs. Alternative C would designate the fewest and the least amount of acres as ACECs 

and would provide special management attention to the least number of relevant and important values. 

The following table (Table 3-22) shows the summary of the values categories that would not receive 

special management attention by each alternative. 

Table 3-22. Relevant and important value categories that would not receive special management 

attention. 

Value Category No Action Alt. A Alt. B Alt. C Alt. D

Fish and Wildlife - - 5 8 1

Historic, Cultural, and Scenic - - - 3 1

Natural Hazard - - - - -

Natural Process or System - 2 6 8 2

Totals - 2 11 19 4

Areas not designated as ACECs under the Action Alternatives 

The BLM determined that nine existing and proposed ACECs no longer meet the ACEC designation 

criteria. The BLM made the majority of these determinations on the basis either that the values no longer 

exist as relevant and important, or that these values would be protected without additional special 

management. Because of this, there would be no effects to relevant and important values without ACEC 

designation. The BLM found the following areas longer meet the ACEC criteria: 

x Long Gulch in the Medford District 

x China Ditch, Stouts Creek, and the Umpqua River Wildlife Area in the Roseburg District 

x 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. 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. Therefore, the values would persist under the action alternatives despite their lack of 

designation. 

The bald eagle is the single relevant and important value needing special management for the Umpqua 

River Wildlife Area ACEC. Over time, the bald eagle population has grown and the species has been 

delisted and this population no longer meets the relevance and importance criteria. In addition, Congress 

designated the North Umpqua River as a Wild and Scenic River in 1992. This designation provides the 

special management needed for the area’s relevant and important values. Therefore, there would be no 

effects to relevant and important values through the lack of designation. 

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 land. The adjacent BLM-administered land does not have these relevant and 

important values. A large population of former Special Status botanical species, Poa marcida occupies 
Chapter 3 – AE&EC –Areas of Critical Environmental Concern

131 | Page

Sheridan Peak, but it does not meet the relevance and importance criteria. Two special status botany 

species occurred at the Yampo ACEC. Tall bugbane (Cimicifuga elata) is no longer a 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. Since the values no 

longer meet the relevance and importance criteria, there would be no effect to relevant and important 

values through the lack of designation. 

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 would be prescribed would be 

the same as what is already in place without ACEC designation by way of having no road access to Wells 

Island. The BLM would only continue to apply special management associated with ACEC designation 

under the No Action alternative, but the values would persist under the action alternatives despite their 

lack of designation. 

The Klamath Falls Field Office discovered that its Miller Creek existing ACEC lies on Bureau of 

Reclamation withdrawn lands and is thus outside of the BLM’s decision area. Salem District discovered 

the Jackson Bend old potential ACEC is also not on BLM-administered land. The BLM can only 

designate ACECs on BLM-administered lands. 

In several instances, the BLM integrated existing and potential ACECs in the formation of potential 

ACECs for consideration under the action alternatives. While this changed the number of ACECs 

considered under the action alternative it did not remove acres or relevant and important values from 

potential protection under the action alternatives. 

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. 

 
Chapter 3 - AE&EC – Climate Change

132 | Page

Climate Change 

Key Points 

x Carbon storage would increase under all alternatives. 

x Greenhouse gas emissions associated with BLM-administered lands would increase under all 

alternatives, but would remain less than one percent of the 2010 statewide greenhouse gas 

emissions. 

x 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. 

x Active management would provide opportunities to implement climate change adaptive strategies 

and reduce potential social and ecological disruptions arising from warming and drying 

conditions. 

Issue 1 

What would be the effects of BLM forest management on long-term carbon storage? 

Summary of Analytical Methods 

The BLM estimated 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 one 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 

2014, pp. 36-38). As the nature of the data provided by the Woodstock model became available, the BLM 

changed some aspects of the analytical methods for estimating carbon. The volume harvested, whether 

part of the Harvest Land Base or reserves, in the different alternatives drives variation in carbon storage 

among the alternatives. Due to lack of data on the amount of biomass present prior to treatment or the 

amount removed by treatment, the BLM could not estimate the effects on carbon storage from the 

hazardous, or natural, fuels program. The BLM assumed the following categories to be constant across all 

alternatives: 

x Carbon stored in soils 

x Carbon stored in unmodeled polygons 

x Carbon stored in polygons with no data 

x Carbon loss from wildfire 

The BLM did not estimate the amount of live and dead biomass in savannahs, shrublands, shrub-steppe, 

and grasslands. A relatively small number of polygons had no data. Most of these consisted of slivers in 

the vegetation layer, but could also include roads and water. 

Although the BLM used much of the analytical approach described in the Planning Criteria, the BLM 

modified the data source for above-ground carbon. 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, available at http://www.ncasi2.org/GCOLE3/gcole.shtml) 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 
Chapter 3 – AE&EC – Climate Change

133 | Page

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 privately-owned forests tended to be skewed towards younger age classes than is 

typically present on the Federal lands and the data for BLM-administered lands appeared to lack 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. 

In addition to comparing the alternatives, the BLM also considered two reference analyses as a means of 

providing additional context for the alternatives: 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 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. 

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 likely exceeds the amount of variance between the alternatives. 

Affected Environment 

The BLM-administered lands within the planning area currently store an estimated 373 teragrams37 of 

carbon (Tg C) (Table 3-23). In the 2008 RMP/EIS, BLM estimated current carbon storage at 427 Tg, 

using a similar but more 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 3-23. Estimated current total carbon stored in vegetation and soil and carbon density by 

district/field office. 

District/Field Office Acres Total Carbon (Tg C) Carbon Density (Mg C/Acre) 

Coos Bay 324,236 61.21 1,152.2 

Eugene 311,063 61.12 1,188.8 

Klamath Falls 214,084 8.92 143.5 

Medford 806,675 98.13 713.0 

Roseburg 423,639 65.95 934.9 

Salem 399,157 77.69 1,160.2 

Totals - 373.02 - 

 

37 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. 
Chapter 3 - AE&EC – Climate Change

134 | Page

The Medford District currently stores the most carbon, with an estimated 98 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 5.6 Tg C is currently stored in products made from wood harvested from 

BLM-administered lands that are either still in use or located in sanitary landfills where decay rates are 

minimal (Earles et al. 2012). In the 2008 RMP/EIS, 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, 

p. 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 373 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 Eugene and Salem Districts are moderate 

in size but have a high carbon density (Table 3-23). The Medford District is the largest district, and has 

the largest amount of total carbon storage, but has the second lowest estimated carbon density. The 

Klamath Falls Field Office is the smallest office and has the lowest carbon density. 

Environmental Effects 

Timber harvest volume removed is the primary driver of differences across alternatives in 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 will reduce estimated carbon storage by less than 1 percent 

across the planning area through 2063. For the Eugene District, Klamath Falls Field Office, and Salem 

District, the reduction will generally be less than 0.3 percent, while it will be close to 0.5 percent on the 

Coos Bay and Roseburg Districts. The reduction on the Medford District will be more substantial, ranging 

from 1 percent to around 2.5 percent, given that approximately 82.5 percent of the acres burned are 

forecast to occur on that district. 

All alternatives, including the No Action alternative, would increase carbon storage over time relative to 

the current condition (Figures 3-21 and 3-22). Differences between the alternatives, and in comparison to 

the No Timber Harvest Reference Analysis with fire, would be minor until around 2033, and afterwards 

would become increasing apparent. Alternative D would store the most carbon of all alternatives. 

Although Alternative D has the second largest Harvest Land Base of the alternatives, 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 A would store the second-most amount of carbon. 
Chapter 3 – AE&EC – Climate Change

135 | Page

Figure 3-21. Estimated carbon storage over time by alternative. 

Figure 3-22. Change in carbon storage relative to the estimated total storage as of 2013. 

The No Action alternative and Alternative B would store similar amounts of carbon over time, only 

slightly less than Alternative A. Alternative C would store the least carbon. The relative outcomes of the 

alternatives for carbon storage generally reflect the relative outcomes for the alternatives in total timber 

volume harvested. 

All alternatives would increase carbon storage, but not as much as under the No Timber Harvest 

Reference Analysis with fire (Figure 3-23). The difference in the increase in 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. 

0

100

200

300

400

500

600

No Action Alt. A Alt. B Alt. C Alt. D

Teragrams of Carbon 

2013 2023 2033 2043 2053 2063

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

2023 2033 2043 2053 2063

Change in Carbon Storage 

Year 

No Timber Harvest No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 - AE&EC – Climate Change

136 | Page

Figure 3-23. Percent reduction in aboveground carbon storage from timber harvest relative to projected 

carbon storage in the No Timber Harvest Reference Analysis with fire. 

Issue 2 

What would be the BLM’s expected contribution to greenhouse gas emissions from vegetation 

management activities such as timber management and hazardous fuels reduction? 

Summary of Analytical Methods 

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). Greenhouse gas emissions from BLM-authorized activities 

that are most likely to be substantial and to vary among alternatives are timber harvesting, grazing, and 

prescribed burning. 

The BLM estimated greenhouse gas emissions for each alternative, expressed in the form of carbon 

dioxide equivalent (CO2e), using projected timber harvest, permitted levels of grazing, and prescribed 

burning. To provide context, the BLM also estimated greenhouse gas emissions from wildfires. 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 it 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 it modeled wildfire. 

The BLM estimated emissions from harvesting 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). It 

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 

0%

2%

4%

6%

8%

10%

12%

14%

16%

2023 2033 2043 2053 2063

Percent Reduction in Carbon Stored

Year

No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 – AE&EC – Climate Change

137 | Page

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). 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. 

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 (http://www.globalcarbonproject.org/index.htm). 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, EPA 2014b). United States emissions of greenhouse gasses (6,526 Tg CO2e) were 14 

percent of global emissions (~46,000 Tg CO2e) in 2012 (Le Quéré et al. 2014, EPA 2014b). In 2010, the 

latest year in which data are available, Oregon’s emissions were about 1 percent of the US emissions 

(McConnaha et al. 2013, EPA 2014b). Globally, ocean and land greenhouse gas sinks removed about 51 

percent of that emitted in 2012 (Le Quéré et al. 2014). Land sinks in the U.S. effectively reduced total 

greenhouse gas emissions by nearly 18 percent nationally in 2012, with forests and wood products 

accounting for about 16 percent (Joyce et al. 2014, EPA 2014b). The forests of western Oregon sequester 

more carbon per acre than the national average (Joyce et al. 2014, Figure 7.5). 

Affected Environment 

Total greenhouse gas emissions from timber harvest operations, grazing, prescribed fire, and wildfires on 

BLM-administered lands within the planning area average 192,034 Mg CO2e yr-1 over the past 19 years 

(1995-2013), or approximately 0.3 percent of the Oregon in-boundary38 greenhouse gas emissions in 2010 

(McConnaha et al. 2013). Most greenhouse gas emissions from BLM-administered lands within the 

planning area come from prescribed fires (Figure 3-24). With wildfire emissions excluded, total 

estimated current greenhouse gas emissions are 122,398.1 Mg CO2e yr-1, or about 0.2 percent of Oregon’s 

in-boundary 2010 emissions, with most emissions from prescribed fires. Emissions for any one year vary 

widely, largely depending on the amount of prescribed fire and wildfire. 

 

38 In-boundary emissions are those that occur within Oregon’s borders and emissions associated with electricity use 

within Oregon. 
Chapter 3 - AE&EC – Climate Change

138 | Page

Figure 3-24. Proportion of estimated greenhouse gas emissions from grazing (enteric fermentation), 

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 

represent 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 was anticipated in the 1995 RMPs (USDI BLM 2013). 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 

has partially compensated for the reduction in activity fuels burning. The National Fire Plan increased 

funding for hazardous fuels reduction beginning in 2001. 

The BLM is a relatively small emitter of greenhouse gases from harvest operations and prescribed fire 

within the planning area (Figure 3-25). Management on privately-owned forests and on the National 

Forests each results in greater emissions. In large part, the differences reflect the differences in land base 

and, in the case of privately-owned forests, management intensity. Prescribed fire emissions in privatelyowned forests are largely due to clean up of harvest-generated residue (activity fuels), whereas a portion 

of the prescribed fire emissions from National Forests and BLM-administered lands arises from the 

hazardous fuels reduction program in both agencies under the National Fire Plan. 

Enteric 

Fermentation

1%

Harvest 

Operations

5%

Prescribed Fire

58%

Wildfire

36%

Greenhouse Gas Emissions (Mg CO2e/year)
Chapter 3 – AE&EC – Climate Change

139 | Page

Figure 3-25. Proportion of estimated greenhouse gas emissions from (A) harvest operations and (B) 

prescribed burning by different entities. 

The Other Federal category in B is largely BLM. 

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 

number of active animal unit months 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 privately-owned 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 prerecession levels. In contrast, harvesting levels and resulting emissions have been slowly increasing on 

both BLM-administered and National Forest System lands since 2001, with a slightly higher trend on 

National Forest System lands. 

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 National Forest System 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 National Forest System lands have risen slowly, while emissions have fallen slowly on 

BLM-administered lands. 

Environmental Effects 

Greenhouse gas emissions would increase substantially relative to the estimate of current actual emissions 

under all alternatives, with the exception of Alternative D (Figures 3-26 and 3-27). This increase would 

84% 

7% 

4% 

5% 

Private

State

BLM

Forest Service

A. 

74% 

3% 

8%

15% 

Private

State

Other Federal

Forest Service

B. 
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be largely due to the amount of prescribed burning that would occur in conjunction with harvesting. 

Alternative C would result in the greatest 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). Alternative B greenhouse gas emissions would be the second-most of all alternatives. The No 

Action alternative and Alternative A would result in similar emissions, lower than Alternative B. 

Alternative D would result in the lowest emissions of all alternatives, only slightly higher than current 

emissions. 

Figure 3-26. Estimated average annual greenhouse gas emissions from the combination of harvesting, 

grazing, prescribed fire, and wildfire. Variation in the amount of wildfire and prescribed fire cause most 

of the fluctuation in expected emissions between decades. 

Figure 3-27. Projected increases in average annual greenhouse gas emissions from harvesting, grazing, 

prescribed burning and wildfires relative to average annual emissions as of 2013. 

0

100,000

200,000

300,000

400,000

500,000

600,000

No Action Alt. A Alt. B Alt. C Alt. D

Megagrams CO2e

2013 2023 2033 2043 2053 2063

0%

20%

40%

60%

80%

100%

120%

140%

160%

180%

2023 2033 2043 2053 2063

Increase in Average Annual 

GHG Emissions

Year

No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 – AE&EC – Climate Change

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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 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 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 

in the context of fish habitat, and habitat for 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 

(http://www.natureserve.org/conservation-tools/climate-change-vulnerability-index) 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 (http://www.cefa.dri.edu/Westmap/), 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 annual 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 (http://www.wcc.nrcs.usda.gov/snow/) 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, 
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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). 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 al. 2013). Although 

annual snowpack also fluctuates widely, generally snow accumulation is 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 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 all three basins since 1896, and in 

some seasons, although the increases were not statistically-significant (Figure 3-28). The one exception is 

a statistically significant increase in spring precipitation in the Willamette River and Klamath River 

basins. All basins show a non-significant decline in fall precipitation, and the Oregon coastal basins have 

a non-significant decrease in winter precipitation. 
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Figure 3-28. Observed changes in annual and seasonal precipitation by basin. 

Star indicates change is statistically-significant. Annual = Oct 1-Sep 30, Winter = Dec-Feb, Spring = Mar-May, Summer = JuneAug, Fall = Sep-Nov. 

The WestMap data also indicate that average annual and seasonal temperatures have experienced 

statistically-significant increases across the planning area (Figure 3-29). 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 statisticallysignificant 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 

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. 

 

-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
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Figure 3-29. Observed changes in (A) annual, (B) maximum, and (C) minimum temperature in each 

basin. 

Star indicates the change is statistically-significant. Annual = Oct 1-Sep 30, Winter = Dec-Feb, Spring = Mar-May, Summer = 

June-Aug, Fall = Sep-Nov. 

0

0.5

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1.5

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3

Annual Winter Spring Summer Fall

Annual Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

A.

0

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Maximum Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

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Annual Winter Spring Summer Fall

Minimum Temperature (°F)

Willamette River Basin Oregon Coastal Basins Klamath River Basin

C.
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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 to 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 noticeable changes in forests, most 

disturbance regimes, and terrestrial wildlife species ranges or habitat within the planning area. 

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. 

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). 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 densitydependent factors (Allen et al. 2010). In conifer forests and woodlands, climate-related 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, Salem, and Eugene Districts. 

Devine et al. (2012) developed climate vulnerability rankings for major tree species on the National 

Forests in Oregon and Washington, breaking out the results by geographic area. The authors based the 
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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 were rare, had low seed 

production and low seed viability with very short dispersal distances, were habitat specialists, were either 

disjunct or at the edge of the species’ range, and had insect pests or diseases that were increasing in 

distribution and impacts with typically high mortality of mature trees, among other characteristics. 

Species rated as less vulnerable were 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 within the National Forests, although the rankings provide an indicator of potential 

vulnerability on BLM-administered lands within the planning area. The authors normalized rankings so 

they varied between 0 and 100, with the higher the ranking, the more vulnerable the species. 

Rankings sometimes differed for species that occur in both northwest and southwest Oregon (Table 3-

24). 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 National 

Forests so 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 3-24. Climate change vulnerability scores for different tree species in western Oregon from Devine 

et al. 2012. 

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 

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 

* A higher score indicates greater vulnerability. 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. 

One factor in the ratings was whether the species was 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, Cahill et al. 2014). Pacific silver fir, subalpine fir, Alaska yellow-cedar, and Engelmann spruce 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. 
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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 favor 

pathogens that require leave 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 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). 

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. 

Fire 

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 west-wide 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 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 fires in recent decades also tend to have a higher proportion of high severity burn area in 
Chapter 3 – AE&EC – Climate Change

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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 fires have occurred 

consistent with the west-wide results above; however, there are simply too few fires that have originated 

on BLM-administered lands (or in western Oregon), to provide a clear signal of such changes. An 

analysis of Oregon large fires using data from the Monitoring Trends in Burn Severity site 

(http://mtbs.gov/index.html) indicates that the proportion of high-severity 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 west-wide with an increased proportion of the annual flow 

occurring in winter and a decreasing proportion in summer (Safeeq et al. 2013). Rain-dominated streams 

have earlier peak spring flows and declining late fall and winter flows, whereas snow-dominated 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, 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 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 
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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 greatest 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. 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 

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. 
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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 greatest increase in summer (Table 3-

25). 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 3-25. 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. Ranges are in parentheses. 

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%) 

Some of the projected changes displayed in Table 3-25 are not consistent with observed trends displayed 

in Figures 3-28 and 3-29, 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 is 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 2014-2070, 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 

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). 
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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). At least three and possibly four different types of drought occur in the Pacific Northwest

(Bumbaco and Mote 2010). 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 

tends to 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. The fourth type of drought, which has 

not been formally described, consists of very warm temperatures and near normal precipitation (very hot 

drought) as represented by conditions in 2013. 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; hot-dry drought; and very hot drought are also associated with more severe fire seasons in 

western Oregon. Based on the temperature and precipitation projections, the warm-dry drought, hot-dry 

drought, and very hot drought are expected increase in frequency while the dry drought would likely 

decrease in frequency (Bumbaco and Mote 2010). 

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, 
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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, incensecedar, 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 

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 http://climate.databasin.org/). Douglas-fir is a substantial component of all 

three forest types, but consists of different ecotypes, or climatypes,39 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 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. 

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, 

 

39 A climatype is a population defined primarily by the temperature and precipitation ranges to which it is 

presumably adapted genetically. 
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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 mortality will increase, but do not expect major dieoffs 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 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 differ from and are 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). 

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. 

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, 
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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). 

Fire 

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. 

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). 

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 

increases to 6 to 8weeks (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 
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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 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 areas. 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). 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 (Cansler and McKenzie 2013). 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 (Cansler and McKenzie 2013). Climate and weather 

are top-down controls on fire, but bottom-up controls are also important; 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 evapotransiprational demand, and then increase through 

the end of the century by 0.6-5.5 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 
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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 to 2.0 oF warmer by 

mid-century 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; and shorebirds, long-distance migratory 

birds 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, 

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, actions that would respond to changes in climate (such as modifying seed stock for replanting 

after harvest) would be implementation-level decisions that are made in the years after the completion of 

this planning effort. This discussion considers how the alternatives 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 6-93 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). 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 
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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 facilitating 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—

x 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, increase 

resistance to fire, insects, and pathogens; 

x Protecting large old trees, large snags, and large downed wood; and 

x Planting new genotypes/ecotypes/climatypes and species to aid development of communities 

that can persist under both the current and expected future climate. 

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). 

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 
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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 

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, Hurteau et al. 2014, Loudermilk et al. 2014, 

Volkova et al. 2014). 

The degree to which an alternative promotes active management provides opportunities to mitigate the 

effects of and adapt to changing climate. In dry forests under all action alternatives, 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, especially 

within the Late-Successional Reserve and the Riparian Reserve. 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 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, except Alternative B in the LITA, 

where the BLM would use only natural regeneration harvest. 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. Comparing recent 

satellite imagery of western Oregon with that collected in the mid-1990s, 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, stand-replacing fire and the development 

of large, stand-replacing patch sizes based on recent fires and maps of burn severity. 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. However, it is unclear to what extent such minimally-managed 

Reserves would be more stable and more resistant to climate change effects. 

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. 

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Cultural and Paleontological Resources 

Key Points 

x The BLM can reduce or eliminate effects to cultural and paleontological resources through 

systematic and thorough cultural and paleontological resource inventories. 

x Implementation of alternatives A and D are the least likely to result in potential adverse effects to 

cultural and paleontological resources because they allow for the type of ground-disturbing 

activity most likely to disturb cultural and paleontological resources on the least amount of acres 

within the decision area. 

Issue 1 

How would BLM land management actions affect cultural resources across the decision area under each 

alternative? 

Summary of Analytical Methods 

Each BLM office 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 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 2014 OHIMS). The BLM 

provided Gnomon with all of the datasets used to run the model. For the model, Gnomon assigned 

weighted values between 0 and 50 to different slope breakpoints as well as distance to water breakpoints 

(Table 3-26). The breakpoints for distance to water represent discrete sets of distance in meters along a 

range from 0 to >1000. Similarly, the breakpoints for degrees of slope represent discrete sets of slope 

degrees that range from 0 to >20. Gnomon assigned the breakpoints based on previously 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 3-27). More details of the modeling methodology can be found in 

Ingbar et al. 2014. 

Table 3-26. Values for slope and distance to water break points. 

Slope (Degrees) Weighted Value Distance to Water (Meters) Weighted Value 

0-5 50 0-250 50 

5-10 25 250-500 25 

10-20 12 500-1000 12 

>20 0 >1000 0 

Table 3-27. Total value scores and corresponding probability. 

Total Value Score (Product of Slope 

Value and Distance to Water Value) Probability Zone 

0-24 Low 

25-50 Medium 

51-100 High 
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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 3-28). Then, 

for each alternative, the BLM overlaid these three categories with the land use allocations that allow 

commercial thinning and regeneration harvest. The BLM calculated acres of land allowing commercial 

thinning and regeneration harvest for each probability category to determine which alternatives are most 

likely to create the potential for disturbance of cultural resources from timber harvesting activities (Table 

3-32). This portion of the analysis focused on potential impacts from timber harvest (including both 

commercial thinning and regeneration harvest) because it is one of the most impactful activities to the 

ground and varies substantially by alternative. 

Table 3-28. Distribution of all acres within the decision area by probability zone. 

Probability Level Acres

High 913,639

Medium 1,167,907

Low 397,309

Additionally, the BLM considered the risk of disturbance to cultural resources from road construction by 

comparing the total number of estimated new miles of road construction in the first decade by alternative. 

The BLM used new road construction miles as a factor because it is also one of the most impactful 

activities to the ground. Finally, the BLM considered potential effects from OHV area designation. In 

comparing the potential effects of the alternatives’ OHV destinations on cultural resources, the BLM 

assumed that open areas are the most likely to cause unintended disturbance of cultural resources from 

OHV use, while such disturbance is much less likely in limited areas and very unlikely in closed areas. 

In this analysis, the BLM assumed that OHV users would operate vehicles consistent with BLM decisions 

about OHV use. Although the BLM has some site-specific and anecdotal information about illegal OHV 

use, the BLM does not have a basis for predicting the location or effects of any widespread or systematic 

illegal OHV use. In addition, much of the decision area has physical limitations to potential illegal OHV 

use, including dense vegetation, steep slopes, and locked gates. In most of the interior/south, the ability to 

track numerous different routes across the open spaces can lead to degradation and erosion in a greater 

proportion than most of the coastal/north. However, the BLM lacks a basis for characterizing current 

illegal OHV use or forecasting such potential illegal OHV use in the future under any of the alternatives 

at this scale of analysis. 

As described below, this analysis considered the potential for impacts from timber harvest, new road 

construction, and OHV designation but also assumed that pre-disturbance surveys will prevent impacts in 

most instances. 

It is important to note that phenomena that the BLM does not manage, such as wildfire and looting, may 

also negatively affect cultural resources in unpredictable ways. 

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. 41-43). The analytical methods described above differ from those set out in the Planning 

Criteria. BLM annual reporting over the last seven years spurred this change in analysis. The annual 

reports state that the implementation of project activities inadvertently damaged very few sites (two). 

Conversely, the BLM and project proponents discovered 641 sites prior to implementation of project 

activities. As a result, the BLM applied mitigation measures to avoid adverse impacts to these sites. In the 

end, predicting the numbers of sites within each physiographic province, as the BLM described in the 

Planning Criteria, does not tell us the effects to cultural resources. Without more accurate data that tracks 
Chapter 3 – AE&EC – Cultural and Paleontological Resources

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all impacts 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 vary between the activities most likely to create impacts and the 

distribution of these activities across the three probability categories. 

Background 

The BLM and members of the public discover cultural resources in a multitude of ways, from finding 

artifacts during a hike, to systematic cultural resource inventories, and even occasionally through the 

implementation of project activities. 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 of high probability to yield cultural resources. The Analysis of the 

Management Situation (USDI BLM 2013) contains a synthesized explanation of cultural resources in 

Oregon. 

Cultural resources inventories are primarily project driven and conducted in support of other resources 

such as timber, recreation, aquatic restoration, road building etc. The BLM conducts this type of survey in 

compliance with section 106 of the National Historic Preservation Act. 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. 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 2,470-recorded cultural sites on BLM-administered lands 

within the decision area. Since much of these lands remain un-inventoried, it is very likely that there are 

far more undocumented cultural sites on these lands. 

The following tables provide a snapshot of cultural resources and inventories on BLM-administered lands 

in the decision area. Table 3-29 illustrates that the BLM has inventoried 10.5 percent of the BLMadministered lands in the decision area for cultural resources. These acres only reflect Class III - intensive 

field surveys, as conducted per BLM Manual 8110.21C. It is notable that the Klamath Falls Field Office 

has completed inventory of over 70 percent of their land base due to multiple large-scale projects (e.g. 

vegetation management, fuels treatments) where contractors surveyed thousands of acres at a time. Of the 

259,693 acres inventoried in the decision area, 40 percent (103,877 acres) occurred in high probability 

areas, 44 percent (114,265 acres) occurred in medium probability areas, and 16 percent (41,551 acres) 

occurred in low probability areas. With 89.5 percent of the decision area considered unsurveyed, the BLM 

anticipates that inventories will continue for the near future in compliance with section 106 and 110 of the 

National Historic Preservation Act. Given that 89 percent of the high probability acres on BLMadministered lands in the decision area are unsurveyed, it is highly likely that the BLM will find more 

cultural properties in the future. 

 
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Table 3-29. Summary of acres of cultural resource inventories by district or field office. 

District/Field Office Inventoried (Acres) Totals (Acres) Inventoried (Percent)

Coos Bay 3,430 324,236 1%

Eugene 4,801 311,064 1.5%

Klamath Falls 155,262 214,084 72.5%

Medford 78,782 806,675 9.8%

Roseburg 14,977 423,640 3.5%

Salem 2,441 399,157 0.6%

Totals 259,693 2,478,856 10.5%

Table 3-30 shows the distribution of site types across the districts. Ground disturbing activities may be 

more or less likely to damage sites depending on their type. The term “prehistoric site” generally refers to 

archaeological sites that Native Americans occupied prior to European contact; 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 50 years ago or earlier. 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. 

Table 3-30. Distribution of site types by district or field office. 

District/Field Office Prehistoric Historic Multicomponent Unknown Totals

Coos Bay 30 24 1 1 56

Eugene 132 15 - - 147

Klamath Falls 762 284 62 61 1,169

Medford 148 492 22 6 668

Roseburg 250 34 14 - 298

Salem 67 62 3 - 132

Totals 1,389 911 102 68 2,470

Table 3-31 shows the last recorded 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 impacts from 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 within the site. The BLM 

has determined > 0.5 percent of recorded sites have been destroyed. Thirty-seven percent of the sites are 

in excellent or good condition and 22 percent are in fair or poor condition. 

Table 3-31. Distribution of site conditions. 

Site Condition Count

Excellent 232

Good 693

Fair 256

Poor 282

Destroyed 34

Other 11

Unknown 962

Totals 2,470
Chapter 3 – AE&EC – Cultural and Paleontological Resources

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Environmental Effects 

Under all alternatives, 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 3-32 shows the number of acres of potential commercial thinning and regeneration harvest 

activities by each alternative along with their distribution across the probability zones. The resulting acres 

reflect the range of both commercial thinning and regeneration harvest across the alternatives. Overall, 

Alternative A, which has no commercial thinning in the moist forest reserves, and Alternative D, which 

has substantial acres of selection cutting and thinning, would have the lowest potential for disturbance to 

cultural resources through timber harvest; they have the lowest total acreage of harvest types that have the 

potential to damage cultural resources and the lowest acreage of potential harvest in high probability 

zones. Alternatives B and C would have the highest potential for disturbance of cultural resources through 

timber harvest, with both the highest total acreage of potential harvest and the highest acreage of potential 

harvest in high probability zones. The No Action alternative would have a slightly lower potential for 

disturbance of cultural resources through timber harvest than Alternatives B and C. 

Table 3-32. Acres of potential harvest activity in each probability zone by alternative. 

Alternative Low (Acres) Medium (Acres) High (Acres) Total (Acres) 

No Action 258,612 605,715 345,566 1,209,893 

Alt. A 122,886 277,250 203,535 593,671 

Alt. B 206,294 623,600 480,746 1,310,640 

Alt. C 193,890 634,520 491,341 1,319,751 

Alt. D 126,746 376,129 294,975 797,850 

The No Action alternative 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. Table 3-33 shows that the number of miles of estimated new road construction corresponds 

generally with the total acres of commercial harvest. 

Table 3-33. Total number of new miles of estimated road construction by alternative. 

Alternative Total Estimated New 

Road Construction (Miles) 

No Action 944 

Alt. A 303 

Alt. B 687 

Alt. C 790 

Alt. D 246 

For all action alternatives, the BLM will apply interim management guidelines for OHV use until travel 

management planning is completed (Appendix N). On the majority of the BLM-administered lands OHV 

use would be limited to existing roads and trails (Table 3-34). Shotgun Creek in Eugene, Blue Ridge 

Parkway in Coos Bay, and Upper Nestucca in Salem are the only areas that would remain as limited to 

designated across all alternatives. None of the action alternatives has lands designated as OHV open

areas. This differs from current practices and the No action Alternative, under which there are 330,394 
Chapter 3 - AE&EC – Cultural and Paleontological Resources

170 | Page

acres of land designated as open. Due to this change, the BLM would expect a reduction in inadvertent 

impacts to cultural resources from OHV use under all action alternatives. The BLM is deferring 

implementation level transportation management planning until after completion of this RMP. Route 

designation will occur at that time and the BLM will consider affects to cultural resources in compliance 

of Section 106 of the National Historic Preservation Act. The Trails and Travel Management section 

contains more information on transportation management planning. 

Table 3-34. OHV area designations by alternative. 

Trails and Travel Management

Designations

No Action

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

Closed to OHV Use 84,589 128,757 148,551 178,001 153,305

Limited to Designated Routes 1,119,686 10,469 76,200 244,785 91,857

Limited to Existing Routes 1,037,026 2,335,106 2,249,464 2,051,528 2,229,130

Open to Cross-country Travel 330,394 - - - -

Issue 2 

How would land management actions affect paleontological resources? 

Summary of Analytical Methods 

The BLM does not maintain a central or consolidated dataset of paleontological resources within the 

decision area. Therefore, analysis of effects is difficult. The BLM must assume prior to ground disturbing 

activities it will 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. 

As with the cultural resources analysis, despite the assumption that affects would be avoided through predisturbance inventories, the BLM also considered the extent to which the alternatives would create the 

potential for disturbance to paleontological resources. To compare the potential for disturbance across 

alternatives the BLM considered the range of acres allowing commercial thinning and regeneration 

harvest activities and the estimated number of miles of new road construction. The BLM assumed that 

these two ground-disturbing activities were the most likely of the activities considered under the 

alternatives to create the potential for disturbance to paleontological localities. 

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. 41-43). 

Background 

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.”
Chapter 3 – AE&EC – Cultural and Paleontological Resources

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Fossils are fragile and non-renewable 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 lands it administers. Qualified paleontologists and 

academic institutions can obtain permits from the BLM for collecting. Permits are not necessary for 

collecting most invertebrate and plant fossils. The public may to collect reasonable amounts for personal 

use. The rules for the collection of petrified wood are addressed in 43 CFR 8365. 

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. 

Affected Environment 

Most of the paleontological localities of scientific interest in Oregon exist on the central and east side of 

the state. However, there are scattered fossil localities within the decision area. 

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 3-35). The recorded localities may provide a sense of the distribution of paleontological 

resources throughout the decision area. Table 3-35 lists the number of paleontological localities reported 

in the FEIS (USDI BLM 2008, Vol. I, p. 444). The BLM compiled these numbers by querying each 

districts’ specialists for the number of recorded or known localities on their district. The condition of 

these localities is currently unknown. 

Table 3-35. Number of reported paleontological localities by district or field office. 

District/Field Office Paleontological 

Localities (2008) 

Coos Bay 19 

Eugene 1 

Klamath Falls 1 

Medford 2 

Roseburg 18 

Salem 6 

Totals 47 
Chapter 3 - AE&EC – Cultural and Paleontological Resources

172 | Page

Environmental Effects 

As described in the analytical methods section above, the BLM would avoid the majority of damage to 

paleontological localities under all alternatives 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. Under all alternatives, each office would implement suitable protection 

measures for known paleontological localities that it manages. However, some inadvertent loss is possible 

due to the lack of a strategic inventory plan for paleontological resources within the decision area.

Table 3-36 shows the number of acres of potential commercial thinning and regeneration harvest 

activities by each alternative along with total miles of new road construction estimated for the first decade 

of implementation of the RMP. Alternatives A and D have by far the least acreage of commercial timber 

harvest and thus creates the least potential for the destruction of paleontological localities through timber 

harvest. Alternatives B and C have the most acreage of commercial timber harvest and thus creates the 

most potential for the destruction of paleontological localities through timber harvest The No Action 

alternative, Alternative B and C have the highest number of miles of estimated new road construction, 

while Alternatives A and D have the lowest number. Alternatives A and D are the alternatives that would 

create the least potential for the destruction of paleontological localities through timber harvest, while the 

No Action alternative would create the most potential for the destruction of paleontological localities 

through road construction. 

Table 3-36. Acres of commercial harvest allowed and total miles of estimated new road construction by 

alternative. 

Alternative Total Commercial Harvest

(Acres)

Total Estimated New Road 

Construction (Miles)

No Action 1,209,893 944

Alt. A 593,671 303

Alt. B 1,310,640 687

Alt. C 1,319,751 790

Alt. D 797,850 246

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, Nevada. 

USDI BLM. 2004. Identifying and Evaluating Cultural Resources. MS-8110. Release 8-73, 3 December 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. 

---. 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. 

---. 2014. Oregon Heritage Information Management System. Oregon State Office. Portland, OR. 

---. 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. 

---. 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. 
Chapter 3 – AE&EC – Fire and Fuels

173 | Page

Fire and Fuels 

Key Points 

x 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 structural and compositional changes. 

x The BLM-administered lands constitute only a small portion of the entire interior/south dry forest 

landscape. Consequently, the modest shifts under any alternative 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. 

x All alternatives would increase stand-level fire resistance and reduce wildfire hazard on BLMadministered lands compared to current conditions. Within the Harvest Land Base, there would 

be greater variation in these variables among the alternatives over time. 

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 (grasslands, 

chaparral, 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 3-37). 

Table 3-37. Fire regime groups and descriptions used in current LANDFIRE Fire Regime Condition 

Class Guidebook Version 3 (Barrett et al. 2010). 

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 

mixed-severity 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 

In the mixed-severity fire regime, the influence of fuels, topography, and weather on fire behavior and 

fire effects plays out across the landscape, resulting in highly variable forest structure, patterning and 
Chapter 3 - AE&EC – Fire and Fuels

174 | Page

successional stages (Perry et al. 2011). In low severity fire regimes, fuels tend to be the dominant factor 

influencing fire behavior, while in high severity fire regimes weather primarily drives 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 finescale mosaic of fire regimes (Agee 1991b, 1998, and 2005, Odion et al. 2004 Taylor and Skinner 2003). 

Within the administrative boundaries of the Coos Bay, Eugene, and Salem Districts, high proportions of 

the landscape, ranging from 44 to 53 percent, fall into the infrequent and commonly replacement-severity 

fire regime group, with fire return intervals (FRIs) measured in hundreds of years (Table 3-38).

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 

wildfires in these areas rarely aligned, and fires that burned were large and of high severity (Morrison and 

Swanson 1990). 

Table 3-38. Percent distribution of burnable lands by Historic Fire Regime Groups (LANDFIRE 2010 

(LF_1.2.0)) across the planning area within district/field office administrative boundaries. 

District/

Field Office

Historic Fire Regime Group and Description

I II III IV V

0-35 Year 

FRI*, Low 

and Mixed 

Severity

0-35 Year 

FRI, 

Replacement 

Severity

35-200 Year 

FRI, Mixed 

and Low 

Severity

35-200 Year 

FRI, 

Replacement 

Severity

>200 Year 

FRI, Any 

Severity

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%

*FRI- Fire return interval 

The Klamath Falls Field Office and the Medford and Roseburg Districts have high proportions, 73 to 98 

percent, of lands within their administrative boundaries classified as frequent, to moderately frequent low 

and mixed severity fire regime groups (Table 3-38).

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 burned regularly in most dry forest ecosystems in the southern portion of the planning area, with 

ignitions caused by both lightning and humans (Agee 1991a, 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 grazing and farming and to expose rock and soil for 

mining and set frequent and extensive fires (Atzet and Wheeler 1982). Regional studies have found 

historic pre-settlement median fire return intervals ranging from 8 to 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). 
Chapter 3 – AE&EC – Fire and Fuels

175 | Page

Frequent low- to moderate-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). 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 (Jain et al. 2012, Halofsky et al. 2011, Perry 

et al. 2011). These heterogeneous landscape patterns and uneven-aged, uneven-structured stands of firedependent species contributed towards the fire resilience of the southern Oregon landscape. 

Fire Exclusion in the Dry Forest 

In the early 1900s, suppression of all fires became a goal of land management agencies and policy 

(Graham et al. 2004). This effectively took hold in the 1940s with the advent of mechanized equipment 

and the establishment of the smoke jumper base in Cave Junction (Atzet 1996, Atzet and Wheeler 1982). 

Effective fire exclusion, along with other land management practices, has altered natural fire return 

intervals, 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). 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 

(Jain et al. 2012, North et al. 2009, Comfort et al. in review). Dry forest stand species composition has 

shifted resulting in significant reductions in the proportion and diversity of fire-adapted conifers, 

hardwoods, shrubs, and herbaceous species (Franklin and Johnson 2010, Comfort et al. in review, Duren 

et al. 2012, Taylor and Skinner 2003 and 1998), and understory and canopy fuels have increased 

(Sensenig 2002, Hessburg et al. 2005). 

The absence of frequent low and mixed severity fire has allowed for homogenization of landscape 

vegetation patterns and fuel conditions, resulting in a loss of finer scale diversity (Perry et al. 2011; 

Halofsky et al. 2011), and fewer and smaller forest openings (Taylor and Skinner 1998, Skinner 1995, 

Larson and Churchill 2012). Open areas, such as forest gaps, shrublands, savannahs, grasslands, and 

hardwood woodlands, have been converting to closed areas via the recruitment of conifers, threatening 

the persistence of these ecosystems and landscape patterns (Comfort et al. in review, Taylor and Skinner 

1998, Hosten et al. 2007). 

The absence of fire has also changed successional pathways and the development of forest structure 

(Halofsky et al. 2011), landscape seral distribution, and tree establishment (Comfort et al. in review, 

Sensenig et al. 2013, Donato 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 review). The 

abundance of dense forest and homogenization of vegetation patterns compromises individual tree vigor, 

overall forest health, and resistance and resilience to disturbance from fire, insects, and disease (Sensenig, 

et al. 2013, Franklin and Johnson 2012). Densely forested conditions result in extremely slow tree growth 

and delay or hinder the development of structurally-complex forest (Sensenig 2002, Sensenig et al. 2013). 

Additionally, these shade-tolerant species accumulate to abnormally high densities and, together with an 

increase of dead material, can easily transmit fire to the upper canopies (Peterson et al. 2005). These 

changes to forest structure have altered the horizontal and vertical stand structure and fuel profile. 

Surface, ladder, and canopy fuels have increased in loading and continuity, increasing the potential for 

larger scale crown and stand-replacing fires (Hessburg et al. 2005, Graham et al. 2004, Agee 1998). As a 

result, the landscape that had been composed of forests adapted to frequent fire is now at risk of 

uncharacteristically large, severe fires that can be destructive to habitats, species, and people (Hessburg 

and Agee 2003, Perry et al. 2011, Stein et al. 2013). 
Chapter 3 - AE&EC – Fire and Fuels

176 | Page

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 northern and coastal 

districts, human ignitions are prevalent and account for greater than 90 percent of all ignitions within 

these districts (Figure 3-30). Human caused ignitions typically occur in relatively accessible locations and 

do not come in droves compared to lightning events; coupled with overarching climatic patterns, human 

ignitions are typically manageable for suppression resources. Relative to frequent fire systems, fire

exclusion in these infrequent fire systems is an insignificant factor influencing current fire frequency, fire 

severity, and structural stage distribution (Brown et al. 2004). 

Figure 3-30. Average annual number and cause of ignitions (1984-2013) within the planning area by 

district or field office. 

Source: Oregon Department of Forestry ignition data. 

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 3-30). Depending on fuel 

conditions, lightning from these storms can start numerous fires 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 fire perimeters greater than 1,000 acres, even though these fires 

account for > 1 percent of all ignitions (Table 3-39). 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. 

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
Chapter 3 – AE&EC – Fire and Fuels

177 | Page

Table 3-39. Fire 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. 

In recent decades, the frequency of large fires and the annual acres burned have increased across the West 

(Westerling et al. 2006) and in Oregon (OFRI 2014, USDI BLM 2013). Modeled projections indicate the 

trend will continue (Mote et al. 2014). Based on an analysis of fire start dates for fires greater than 1,000 

acres, Westerling et al. (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 play out. These changes in climate strongly correlate with increasing fire 

size, large wildfire frequency, and longer wildfire durations (Littell et al. 2010, Miller et al. 2012, 

Westerling et al. 2006, see Climate Change section in this chapter). These observed trends and forecasts 

suggest that wildland fire 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. Recognition of both the spatial and temporal process and vegetative structure of fire regimes is 

necessary to increase resilience in frequent fire-adapted forests (Agee 2002, Jain et al. 2012). In the 

absence of natural fire as a disturbance agent, management activities can serve as a partial surrogate to 

promote and maintain desired structural and compositional changes. Recently, there has been a growing 

body of evidence (Martinson and Omi 2013) demonstrating 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). Kennedy and Johnson (2014) also found that these 

types of treatments improved wildfire management opportunities. 

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 BLM40 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 

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 (Brown et al. 2004, Hessburg and Agee 2003, North et al. 2009). 

In this analysis, the BLM quantified how the seral stage distribution would vary in 50 years for each 

alternative, relative to the reference condition. This analytic process built upon the conceptual framework 

of the LANDFIRE Fire Regime Condition Class concept (Barrett et al. 2010, Schmidt et al. 2002). The 

LANDFIRE Fire Regime Condition Class conceptual framework assumes that, given natural disturbance 

 

40 The Nature Conservancy conducted this analysis of landscape-scale fire resiliency under an agreement with the 

BLM. 
Chapter 3 - AE&EC – Fire and Fuels

178 | Page

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. 

This issue presents an analysis of the cumulative effects on landscape-scale fire resiliency of past, present, 

and reasonably foreseeable future actions, including both land management on BLM-administered lands 

and non-BLM-administered lands.

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, Medford and Roseburg Districts)

(Map 3.2) 

4. A spatial delineation of both current and future forest vegetation structure using BLM structural 

stages cross-walked to seral stages and gradient nearest neighbor (GNN) imputation datasets 

derived from inventory field plots, environmental gradients and Landsat imagery (Ohmann and 

Gregory 2002) classified into seral stages (Haugo et al. 2015). 

Chapter 3 - AE&EC – Fire and Fuels

180 | Page

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). United States 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 (Appendix H). 

The analysis area is the dry forest area within the boundaries of the western portion of the Klamath Falls 

Field Office, Medford District, and Roseburg District administrative boundaries. Each of these three 

administrative units constituted a landscape for the purpose of this analysis. 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-

38), the overwhelming majority of the BLM-administered lands in the Coos Bay District is classified as 

moist forest (Figure 3-31). 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 

Figure 3-31. Forest type (moist and dry) distribution on BLM-administered lands by district/field office. 

In this analysis, the BLM created a cross-walk between the structural stages used in the Woodstock model 

(see the Vegetation Modeling section in this chapter) and the five seral stages used in the LANDFIRE 

Fire Regime Condition Class conceptual framework: early seral, mid-seral closed, mid-seral open, lateseral 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. 

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

Acres

District/FieldOffice

Moist Dry
Chapter 3 – AE&EC – Fire and Fuels

181 | Page

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, 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, Medford District, and Roseburg District 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 

consistent with the assumption used in the analysis of forest structure and spatial pattern in the 2008 

RMP/EIS, 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. 

The BLM-administered lands comprise 28 percent of the analysis area. Therefore, BLM-administered 

lands have a relatively small ability to influence the overall landscape distribution of seral stages at the 

scale of the entire analysis area. 

This analysis evaluated the departure, relative to the 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 3-40). 

 
Chapter 3 - AE&EC – Fire and Fuels

182 | Page

Table 3-40. 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

(%) (Acres)

Douglas-fir/Dry 41% 1,336,438

Douglas-fir/Moist 33% 1,090,723

Douglas-fir/White oak 8% 250,616

Tan oak/Douglas-fir 8% 277,579

Shasta Red fir 5% 157,989

Jeffrey pine 2% 59,152

Ponderosa pine/Lodgepole pine 2% 66,714

Western hemlock 1% 20,192

Lodgepole pine <1% 443

Mixed Conifer <1% 15,833

Oregon white oak/Ponderosa pine <1% 43

Ponderosa pine/Dry <1% 8,776

Total Dry Forested Acres in Analysis Area 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. 

Appendix H provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales in this analysis. 

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 seral and a substantial 

overabundance of mid-seral closed forest (Figure 3-32). The Douglas-fir/dry vegetation type has a slight 

deficit of mid-seral open forest41 and late-seral closed forest and a substantial deficit of late-seral open 

forest. 

41 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. Figure 3-

32 does not depict this slight overabundance. 
Chapter 3 – AE&EC – Fire and Fuels

183 | Page

Figure 3-32. Departure from reference conditions in the Douglas-fir/dry vegetation type by seral stage; 

current conditions and by alternative and the No Timber Harvest Reference Analysis in 2063. 

In 50 years, conditions in the Douglas-fir/dry vegetation type under any alternative and the No Timber 

Harvest Reference Analysis would generally result in continued departure from reference conditions 

(Figure 3-32). The alternatives 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, 

due in large part to continued fire exclusion. The action alternatives and the No Timber Harvest 

Reference Analysis would result in slight improvements in the early seral and late-seral closed departure 

and 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 and the No 

Timber Harvest Reference Analysis, the landscape condition in the Douglas-fir/dry vegetation type would 

continue to be shaped by an overabundance of mid-seral closed forest and a 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 historic range of variability. There is a substantial overabundance of mid-seral closed forest 

and slight overabundance of mid-seral open forest (Figure 3-33). The Douglas-fir/moist vegetation type 

is also slightly deficit of late-seral closed forest and substantially deficit of late-seral open forest. 

-600,000

-400,000

-200,000

0

200,000

400,000

600,000

800,000

Acres 

Seral Stage 

Current Condition No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
Chapter 3 - AE&EC – Fire and Fuels

184 | Page

Figure 3-33. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage 

for the Klamath Falls Field Office. This includes the current conditions and by alternative and the No 

Timber Harvest Reference Analysis in 2063. 

In 50 years, the alternatives would only result in modest shifts in the seral stage distribution on the BLMadministered 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. For all other 

seral-stages conditions in the Douglas-fir/moist vegetation type under any alternative and the No Timber 

Harvest Reference Analysis would result in essentially no change in current departure from reference 

conditions. 

Currently within the Medford District, the Douglas-fir/moist vegetation type is slightly deficit in earlyseral and mid-seral open forest (Figure 3-34). There is a substantial overabundance of mid-seral closed 

forest and slight overabundance of late-seral closed forest. The Douglas-fir/moist vegetation type is also 

substantially deficit in late-seral open forest. 

-40,000

-30,000

-20,000

-10,000

0

10,000

20,000

30,000

40,000

Acres

Seral Stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
Chapter 3 – AE&EC – Fire and Fuels

185 | Page

Figure 3-34. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage 

for the Medford District. This includes the current conditions and by alternative and the No Timber 

Harvest Reference Analysis in 2063. 

In 50 years, conditions in the Douglas-fir/moist vegetation type in the Medford District under any 

alternative and the No Timber Harvest Reference Analysis would generally result in continued departure 

from reference conditions (Figure 3-34), due in large part to continued fire exclusion. In the late-seral 

open forest, there would be essentially no change in current departure from reference conditions. 

Currently within the Roseburg District, the Douglas-fir/moist vegetation type has a slight overabundance 

of early seral and mid-seral closed forest (Figure 3-35). There is a substantial overabundance of mid-seral 

closed forest and slight overabundance of late-seral closed forest. The Douglas-fir/moist vegetation type 

is also substantially deficit in late-seral open forest and slightly deficit in mid-seral open forest. 

-400,000

-300,000

-200,000

-100,000

0

100,000

200,000

300,000

400,000

Acres 

Seral Stage 

Current Condition No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
Chapter 3 - AE&EC – Fire and Fuels

186 | Page

Figure 3-35. Departure from reference conditions in the Douglas-fir/moist vegetation type by seral stage 

for the Roseburg District; current conditions and by alternative and the No Timber Harvest Reference 

Analysis in 2063. 

Again, in 50 years, conditions in the Douglas-fir/moist vegetation type in the Roseburg District under any 

alternative and the No Timber Harvest Reference Analysis would generally result in continued departure 

from reference conditions, due in large part to continued fire exclusion. There would be little change from 

current departure in both the mid-seral and late-seral open forest under any alternative. 

Similar to the Douglas-fir/dry vegetation type, in 50 years, conditions in the Douglas-fir/moist vegetation 

type under any alternative and the No Timber Harvest Reference Analysis would generally result in 

continued departure from reference conditions (Figures 3-33, 3-34, and 3-35). The alternatives would 

result in only modest shifts in the seral stage distribution on the BLM-administered lands. 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/moist vegetation 

type. Under all alternatives 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. 

In both the Douglas-fir/dry and Douglas-fir/moist vegetation types, the differing BLM management under

the alternatives 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, the BLM would allocate only a small portion of the BLM-administered lands to the 

Harvest Land Base, in which 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 lateseral open forests). 

Fire exclusion continues to have an overwhelming influence on departure from reference conditions. Due 

to the configuration of BLM-administered lands within the larger landscape, restoring wildfire as a 

-200,000

-150,000

-100,000

-50,000

0

50,000

100,000

150,000

200,000

Acres

Seral Stage

Current Condition No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
Chapter 3 – AE&EC – Fire and Fuels

187 | Page

process would have limited application because of the high risk of wildfire affecting adjacent lands. 

Under any alternative, management with fire would primarily be limited to the application of prescribed 

fire to the landscape. 

In summary, the landscape would remain departed from reference conditions similarly under any 

alternative, 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. 

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 to a relative ranking of stand-level resistance to 

replacement fire (Table 3-41). 

Table 3-41. Stand-level resistance to 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). Particularly in the frequent fire-adapted 

dry forest, fire resistant stand structure reduces the likelihood of atypical large-scale crown fire (Agee and 

Skinner 2005, Franklin et al. 2013, Jain et al. 2012). 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. Mechanical and prescribed fire treatments that alter these aspects of the fuel 
Chapter 3 - AE&EC – Fire and Fuels

188 | Page

profile can create conditions that result in improved stand level resistance to replacement fire (Agee and 

Skinner 2005, Jain et al. 2012, Scott and Reinhardt 2001).

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 Reindhard 

2001) and the specific conditions related to crown fire initiation and spread (Van Wagner 1977). As fire 

weather indices increase throughout the summer, stand resistance to 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. 

The analysis area is the dry forest area within the interior/south: the Klamath Falls Field Office, Medford 

and Roseburg Districts, as described in Issue 1. The BLM quantified the acreage of BLM-administered 

lands in the dry forest in the Klamath Falls Field Office, Medford and Roseburg Districts in each fire 

resistance categories for each alternative 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. 

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 moderate or low fire resistance 

(i.e., relatively greater tendency of a stand-replacement fire). Approximately 5 percent of the BLMadministered lands in dry forest currently have high fire resistance (i.e., less probability of a standreplacement fire (Figure 3-36).
Chapter 3 – AE&EC – Fire and Fuels

189 | Page

Figure 3-36. Stand-level fire resistance categories in the dry forest in the interior/south for the current 

condition and each alternative in 50 years. 

In 50 years, all alternatives would result in an increase in stand-level fire resistance across the dry forest. 

All alternatives 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 the differences among 

the action alternatives are minor, Alternatives B and D would result in the greatest reduction in the 

acreage of low or moderate fire resistance, followed by Alternatives A and C. 

The effects of the alternatives on stand-level fire resistance in both the Medford and Roseburg Districts in 

50 years would approximate the effects across the dry forest (Figures 3-37 and 3-38). Differences among 

the alternatives would be more evident for the Klamath Falls Field Office than for the entirety of the dry 

forest or for the Roseburg and Medford Districts (Figure 3-39). In the Klamath Falls Field Office, the No 

Action alternative would result in only a slight increase in the acreage of mixed or high fire resistance 

from current conditions, and, consequently, only a slight reduction in the acreage of moderate or low fire 

resistance. Alternative C would result in no increase in the acreage of high fire resistance among all 

alternatives and less increase in the acreage of mixed fire resistance than the other action alternatives. 

322,697 

199,269 215,360 200,152 228,494 189,395

128,410 

169,833 57,872 47,151 64,440 63,338

419,998 

390,476 489,668 513,790 479,623 501,371

57,133 168,668 165,346 167,154 155,689 174,142

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres 

Low Moderate Mixed High
Chapter 3 - AE&EC – Fire and Fuels

190 | Page

Figure 3-37. Stand-level fire resistance categories in the dry forest in the Medford District for the current 

condition and each alternative in 50 years. 

Figure 3-38. Stand-level fire resistance categories in the dry forest in the Roseburg District for the current 

condition and each alternative in 50 years. 

249,164

158,847 168,547 159,190 175,425 151,922

95,035

133,376 49,043 42,204 51,147 48,913

330,030

306,803 379,131 395,642 375,709 391,053

41,274 116,485 118,790 118,476 113,231 123,624

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres

Low Moderate Mixed High

57,316

32,486 37,085 30,477 38,933 29,304

24,859

22,708

7,393 3,419 7,350 6,648

81,025

74,560 91,105 99,073 89,933 94,786

7,389

40,835 35,006 37,620 34,372 39,850

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres

Low Moderate Mixed High
Chapter 3 – AE&EC – Fire and Fuels

191 | Page

Figure 3-39. Stand-level fire resistance categories in the dry forest in the Klamath Falls Field Office for 

the current condition and each alternative in 50 years. 

The alternatives differ in the extent and location of both the Harvest Land Base and the Late-Successional 

Reserve system. The associated changes in vegetation, due to different extents and management direction 

within the Harvest Land Base among the alternatives, would influence the overall patterns of stand-level 

fire resistance, rather than changes occurring within the reserves. Even though the alternatives differ 

substantially in the extent and location of the Late-Successional Reserves in the dry forest, current fire 

resistance within the Late-Successional Reserves is similar among all alternatives (Figure 3-40). 

Additionally, all alternatives would similarly reduce the acreage in the low or moderate fire resistance 

categories within the Late-Successional Reserves 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 among the alternatives over time, and this would 

drive the differences among the alternatives across the dry forest overall. 

16,217 

7,935 9,728 10,485 

14,136 

8,168 

8,516 

13,750 

1,436 1,528 

5,942 

7,778 

8,943 

9,113 

19,432 19,075 

13,980 

15,532

8,470 11,348 11,550 11,058 8,086 10,668

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres 

Low Moderate Mixed High
Chapter 3 - AE&EC – Fire and Fuels

192 | Page

Figure 3-40. Stand-level fire resistance categories in the Late-Successional Reserves in the dry forest in 

the interior/south for the current condition and each alternative in 50 years. 

Within the Harvest Land Base, the current stand-level fire resistance conditions differ among the 

alternatives, due to the differing extents and locations of the Harvest Land Base among the alternatives 

(Figure 3-41). 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. 

The size of the Harvest Land Base is relatively similar in Alternatives B, C, and D, and approximately 60 

percent of the acreage is 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. 

38,232 

24,741 

151,759 

77,086 

92,464 

54,874 

101,014 

62,419 54,734 28,015 

15,910 

5,933 

44,072 

20,985 

38,034 

11,399 

38,093 

14,168 11,169 8,543 

71,205 

75,653 

299,650 

341,843 

225,793 

250,165 

261,374 

284,199 

218,787 

232,455 

6,991 

26,010 

33,411 

88,987 

21,054 

60,907 

22,843 

62,548 

16,425 32,112 

0%

20%

40%

60%

80%

100%

Current

Conditions

Year 2063 Current

Conditions

Year 2063 Current

Conditions

Year 2063 Current

Conditions

Year 2063 Current

Conditions

Year 2063

No Action (132,338) Alt. A (528,901) Alt. B (377,345) Alt. C (423,333) Alt. D (301,124)

Late Successional Reserve by Alternative (Acres)

Low Moderate Mixed High
Chapter 3 – AE&EC – Fire and Fuels

193 | Page

Figure 3-41. Stand-level fire resistance categories in the Harvest Land Base in the dry forest in the 

interior/south for the current condition and each alternative in 50 years. 

In 50 years, all of the action alternatives would reduce the proportion of the Harvest Land Base in low or 

moderate fire resistance (Figure 3-41). Alternative A would reduce this proportion by 7 percent, while 

Alternative C would result in a decrease of 12 percent. Alternatives B and D would result in the greatest 

decrease (25 and 26 percent, respectively) in the proportion of the Harvest Land Base in low or moderate 

fire resistance. In contrast to all action alternatives, the No Action alternative would slightly increase the 

proportion of the Harvest Land Base in low or moderate fire resistance in 50 years. BLM office results 

approximate the same trends as the entire dry forest Harvest Land Base (Appendix H). 

The differences among alternatives, 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 3-42). A greater 

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. In Alternative C, a greater proportion of the Harvest Land Base is in the Uneven Aged 

Timber area than in Alternative A. While having a larger portion of the Harvest Land Base in the Uneven 

Aged Timber Area would improve overall stand-level fire resistance slightly more than Alternative A, 

Alternative C has a larger Harvest Land Base and thus has more acres in both the High Intensity Timber 

Area and the Uneven Aged Timber Area. 

 

179,908 

109,136 

63,964 62,776 

110,068 

67,645 

120,455 

101,879 

127,584 

73,840 

70,841 

153,387 

29,899 

22,632 

42,276 

17,080 

48,686 

35,095 

57,295 

35,184 

200,390 

140,063 

20,983 

21,975 94,507 

130,790 

84,386 

89,988 

81,120 

110,604 

33,414 

81,977 

10,968 18,430 

22,469 

53,814 

23,660 

50,226 

23,363 

69,735 

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

No Action (484,563) Alt. A (125,814) Alt. B (269,329) Alt. C (277,188) Alt. D (289,363)

Harvest Land Base by Alternative (Acres)

Low Moderate Mixed High
Chapter 3 - AE&EC – Fire and Fuels

194 | Page

Table 3-42. Land use allocations in the Harvest Land Base in the dry forest in the interior/south by 

alternative.

Alternative Dry Forest Harvest Land Base – Harvest Type Acres

No Action HLB in Decision Area 484,563

Alt. A

HLB in Decision Area 125,814

HLB - High Intensity Timber Area 71,474

HLB - Uneven Aged Timber Area 54,340

Alt. B HLB in Decision Area 269,329

HLB - Uneven Aged Timber Area 269,329

Alt. C

HLB in Decision Area 277,188

HLB - High Intensity Timber Area 92,588

HLB - Uneven Aged Timber Area 184,528

Alt. D

HLB in Decision Area 289,363

HLB - Moderate Intensity Timber Area 31,258

HLB - Owl Habitat Timber Area 195,891

HLB - Uneven Aged Timber Area 62,214

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 and conditions more closely aligned with high severity 

fire. Although mixed fire regimes would have historically included some small patches of high severity 

fire, there currently exists an overabundance of young and closed conditions and the likelihood of large, 

high severity fire has increased. 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). Additionally, contiguous fuel profiles have 

reduced stand-level fire resistance. 

Alternative B has all of the Harvest Land Base in the dry forest in the interior/south in the Uneven-Aged 

Timber Area. Alternative D has most of the Harvest Land Base in the dry forest in the interior/south in the 

Uneven-Aged Timber area or Owl Habitat Timber Area. Alternatives B and D, would result in the 

greatest decrease in low and moderate fire resistance, relative to current conditions. Alternative D also has 

a little more than 30,000 acres of the Harvest Land Base in the Moderate Intensity Timber Area. The 

Moderate Intensity Timber Area includes thinning and regeneration harvest with 5-15 percent basal area 

retention, and longer rotations and rapid reforestation. This management approach would result in more 

continuous horizontal and vertical fuel profiles and conditions more closely aligned with high severity 

fire. However, the Moderate Intensity Timber Area constitutes only about 11 percent of the Harvest Land 

Base in the dry forest in the interior/south under Alternative D, diminishing its influence on overall standlevel fire resistance. 

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 

greatest reduction of low and moderate stand-level resistance and the largest increase in the mixed- and 

high-resistance acres. These mixed- and higher-resistance stands would result in more discontinuous fuel 

profiles, and thus greater resistance to 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. 
Chapter 3 – AE&EC – Fire and Fuels

195 | Page

The Uneven-Aged Timber Area management direction also provides the latitude to increase fine-scale 

within-stand heterogeneity in response to topographic and vegetative complexity, as well as create 

strategic landscape conditions that provide fire management opportunities through a combination of 

silviculture treatments, harvest, and prescribed burning (Appendix B). Increasing spatial heterogeneity at 

multiple scales, and disrupting fuel continuity, can alter potential fire behavior (Finney 2001) and may 

create conditions in which fire can occur without detrimental consequences, reducing impacts to highly 

valued resources, including timber and wildlife habitat (Jain et al. 2012). These conditions may also 

provide opportunities for effective fire management, including the ability to utilize wildfire for resource 

benefit in under conditions outlined in Management Direction (Appendix B). Particularly in stands that 

are not currently 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). 

In large part, the lack of difference among alternatives for the dry forest in the interior/south is due to the 

abundance of acres in the mixed resistance category (Figure 3-36), especially in the Late-Successional 

Reserve (Figure 3-40). The mixed fire resistance category has the potential to exhibit the full range of 

resistance categories (high to low). Particularly in these stands, management involving mechanical 

treatments and prescribed burning that affects the horizontal and vertical arrangement of canopy, ladder, 

and surface fuels, can reduce crown fire potential (Agee and Skinner 2005, Scott and Reinhardt 2001, Jain 

et al. 2012). This type of management would trend these mixed resistance stands toward higher relative 

resistance to replacement fire. The BLM assumed that the restoration approach taken in the LateSuccessional Reserve in the dry forest would include stand density reductions, cultivation of large trees 

with old-growth characteristics, and introductions of heterogeneity into increasingly uniform stands, and 

treatments to reduce fire risk adjacent to high-value habitat. However, a degree of uncertainty surrounds 

the implementation of treatments within Late-Successional Reserve, due to potentially conflicting 

management objectives and management direction. 

In summary, all alternatives would reduce the acres of moderate or low fire resistance and increase the 

acres of high resistance, relative to current conditions across the dry forest in the interior/south. Although 

the alternatives would differ only slightly across the dry forest, those differences reflect the varied extent 

and patterns resulting from management within the Harvest Land Base among the alternatives. The 

effects of some alternatives, 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 wildfire 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. 

Wildfire risk encompasses the potential for a wildfire to start and have adverse effects to human values 

(lives, homes, ecosystem services, or ecological functions and attributes). In this analysis, the BLM 

assumed that a one-mile buffer around the 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 
Chapter 3 - AE&EC – Fire and Fuels

196 | Page

(WUI)42 across the planning area. The BLM used a one-mile buffer around the Wide Wildfire Risk 

Assessment Wildland Development Areas data layer as a surrogate for the WUI in this analysis. 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 

one 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 3-42).

Figure 3-42. Average annual number of human-caused ignitions, 1984-2013. 

Source: Oregon Department of Forestry ignition data. 

The BLM assigned forest structural stages to a relative ranking of stand-level fire hazard (Table 3-43).

Wildfire 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). 

42 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. 

57 64

28

179

47

160

9 10

11

13

8

25

0

40

80

120

160

200

Coos Bay Eugene Klamath Falls Medford Roseburg Salem

Number of Human Caused Ignitions

District/Field Office

Proximity to Wildland Developed Areas: Outside Within
Chapter 3 – AE&EC – Fire and Fuels

197 | Page

Table 3-43. Stand-level wildfire hazard ratings by structural stage. 

Structural Stages Subdivisions Wildfire 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 

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 primary fuel characteristics associated with potential fire behavior and 

crown fire potential are canopy base height, canopy bulk density, and surface fuel loading (Scott and 

Reinhardt 2001, Jain and Graham 2007). 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 greatest potential to threaten wildland urban interfaces (Graham et al. 2004). In addition, treatments 

that reduce surface and ladder fuels may reduce the stand-level fire hazard (Agee and Skinner 2005, Scott 

and Reinhardt 2001, Jain et al. 2012). 

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 Reindhard 2001). 

The BLM quantified the acreage of forested BLM-administered lands in each fire hazard category for 

each alternative over the course of 50 years within a 1-mile buffer of the Wide Wildfire Risk Assessment 

Wildland Development Areas data layer (WWRA 2013). 

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. 

Appendix H provides detailed information on analytical assumptions, methods and techniques, and 

geographic and temporal scales. 

Background 

Managing wildfire risk in the western United States is becoming an increasingly complex challenge. 

Wildland fuels continue to build, drought conditions persist, human development spreads, budgets 

continue to fluctuate, and wildfire suppression costs increase, particularly given the complex multijurisdictional landscape that surround the decision area. New home construction steadily increased within 
Chapter 3 - AE&EC – Fire and Fuels

198 | Page

wildland areas in Oregon between 1990 and 2008 (Brown et al. 2014, Stein et al. 2013), and this trend is 

likely to continue in the future, given expected increases in Oregon’s population (OR OEA 2012). 

The Healthy Forest Restoration Act 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, Community Wildfire Protection Plans 

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). Community 

Wildfire Protection Plans and collaborating partners use WUI boundaries for local coordination, 

prioritization, and implementation of landscape-level fuel treatments, the identification of strategicallydefensible fuel breaks for wildfire management, and the recognition and protection of local values. 

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. Much of the planning area has a checkerboard pattern of 

ownership, with square mile sections alternating between private land and BLM-administered land. This 

checkerboard land ownership pattern increases the inherent complexities and difficulties of operational 

fire management and fuel reduction efforts (OFRI 2014, 2013 fire season observations). The 

checkerboard ownership pattern also limits the options for managing wildfires for resource benefits 

because of the risk of affecting neighboring private lands. 

Between 21 and 49 percent of BLM-administered lands by office are within 1mile of Wildland 

Development Areas. The Eugene and Medford Districts have the greatest proportion, 49 and 47 percent, 

respectively. The Medford District has nearly three times the acreage of any other office within close 

proximity to developed areas. The Klamath Falls Field Office has the smallest proportion (21 percent) of 

BLM-administered lands within 1 mile of Wildland Development Areas. Slightly more than 1/3 of BLMadministered lands within Coos Bay (36 percent), Roseburg (38 percent), and Salem (33 percent) are 

within close proximity to developed areas. For many offices, the footprint of Wildland Development 

Areas buffered by 1 mile is a considerably smaller extent than the CWPP WUI boundaries (Map 3-3).

Chapter 3 - AE&EC – Fire and Fuels

200 | Page

The vast majority of BLM-administered lands burned by wildfire are in the interior/south (Table 3-44). In 

the past decade, less than 5 percent of the acres burned in the decision area were in the coastal/north. 

Table 3-44. Total acres burned by wildfires within the planning area, 1984-2013. 

Region Acres

1984-1993 1994-2003 2004-2013

Coastal/North 23,478 12,938 6,716

Interior/South 138,715 583,749* 163,382

* 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 fires for nearly all offices 

within the planning area (Figure 3-30). The vast majority of all human-caused ignitions occurred within 

close proximity to developed areas (Figure 3-42). 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 managed fire suppression 

on BLM-administered lands in the planning area under the Western Oregon Fire Services Protection 

contract. 

Firefighting resources across the planning area have been highly effective at minimizing acres burned for 

most fires, keeping 96 percent of all ignitions to less than 10 acres in size (Table 3-39). However, 

extreme fire weather conditions still present problems for control. The cost of large wildfires is a growing 

economic concern, in part prompting The National Cohesive Wildland Fire Management Strategy 

(Cohesive Fire Strategy or CFS), a comprehensive effort created by the FLAME Act (H.R. 5541). 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 fireadapted communities, effective and efficient wildfire response, and resilient landscapes.

Affected Environment and Environmental Consequences 

Currently, almost half of all forested, BLM-administered lands within close proximity to Wildland 

Developed Areas have High stand-level fire hazard. In the coastal/north, approximately 20 percent of 

forested, BLM-administered lands within close proximity to Wildland Developed Areas have Low standlevel fire hazard (Figure 3-43). In the interior/south, less than 10 percent of forested, BLM-administered 

lands within close proximity to Wildland Developed Areas have Low stand-level fire hazard (Figure 3-

44).
Chapter 3 – AE&EC – Fire and Fuels

201 | Page

Figure 3-43. Stand-level fire hazard for all BLM-administered lands in the coastal/north within the WUI, 

current condition, and alternative in 2063. 

Figure 3-44. Stand-level fire hazard for all BLM-administered lands in the interior/south within the WUI, 

current condition, and alternative in 2063. 

 78,407 

 122,184 117,874 118,786 103,770 118,057 9,395 

 25,403 26,449 43,901 40,806 16,657 

 118,645 

 183,370 166,384 

 175,921 

 132,642 

199,335 

 168,101 

 43,591 63,841 35,940 

 97,330 

 40,498 

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres 

Low Moderate Mixed High

 28,343 

 94,570 92,551 87,962 78,985 39,309 100,725 

 48,073 33,539 35,426 37,801 27,214 

 232,163 

 212,374 268,697 281,596 262,782 278,112 

 232,686 

 177,492 137,722 127,526 152,941 126,458 

0%

20%

40%

60%

80%

100%

Current

Condition

No Action Alt. A Alt. B Alt. C Alt. D

Acres 

Low Moderate Mixed High
Chapter 3 - AE&EC – Fire and Fuels

202 | Page

In 50 years, all alternatives would result in a decrease of stand-level fire hazard for the 374,548-forested 

acres within close proximity to Wildland Developed Areas (WWRA 2013) in the coastal/north (Figure 3-

43). All alternatives 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 acreage of 

High or Moderate hazard. The No Action alternative and Alternative D would result in the greatest 

reduction in the acreage of Moderate or High fire hazard, closely followed by Alternatives A and B. The 

effects of the alternatives on stand-level fire resistance for individual offices in 50 years would 

approximate the effects across the entire coastal/north portion of the planning area (Appendix H). 

In 50 years, all alternatives would result in a decrease in stand-level fire hazard for the 532,500 forested 

acres within close proximity to developed areas in the interior/south (Figure 3-44). All alternatives 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 acreage of 

High or Moderate hazard. Alternatives A, B, and D would result in the greatest reduction in the acreage of 

Moderate or High fire hazard within close proximity to Wildland Developed Areas (WWRA 2013). The 

effects of the alternatives on stand-level fire resistance for individual districts in 50 years would 

approximate the effects across the entire interior/south portion of the planning area (Appendix H).

As in Issue 2, the extent of the Harvest Land Base under each alternative 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 extent of the Harvest Land Base is 

relatively small, and changes in fire hazard patterns are minimized at the entire Wildland Developed 

Areas scale. 

In addition, as concluded in Issue 2, all alternatives would have similar effects on fire resistance within 

the Late-Successional Reserve. Similarly, the patterns of change in stand-level fire hazard would not 

differ within Late-Successional Reserves among alternatives (Appendix H).

The alternatives differ in the extent and location of the Harvest Land Base for the coastal/north. However, 

the current fire hazard conditions are relative similar within close proximity to Wildland Developed Areas 

among the alternatives (Figure 3-45). All alternatives 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 Developed Areas (WWRA 2013), closely followed by the No Action alternative. 

The amount of Harvest Land Base within proximity to Wildland Developed Areas (WWRA 2013) is 

relatively similar among Alternatives A, B, and D. 
Chapter 3 – AE&EC – Fire and Fuels

203 | Page

Figure 3-45. Stand-level fire hazard for the Harvest Land Base in the coastal/north within the WUI, 

current condition, and alternative in 2063. 

In 50 years, the No Action alternative and Alternatives B, C and D would slightly increase the proportion 

of Low hazard acres in the Harvest Land Base, relative to the current condition in the coastal/north 

(Figure 3-45). Alternative D would decrease the proportion of High and Moderate hazard by 28 percent, 

and the No Action alternative would result in a decrease of 15 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. Alternative A and C would both increase 

(15 and 14 percent, respectively) the proportion of High or Moderate hazard within close proximity to 

Wildland Developed Areas. 

For the interior/south, the alternatives differ in the extent and location of the Harvest Land Base, and the 

current conditions of fire hazard differ (Figure 3-46). The No Action alternative has the largest Harvest 

Land Base (i.e., Matrix and Adaptive Management Area; see Chapter 2) 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 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. 

 30,080 

 39,656 

 21,742 

 19,346 23,883 

 30,835 

 38,654 

 42,768 

 27,220 

33,954 

 4,351 

 20,852 

 3,312 

 21,295 

 3,622 

 39,109 

 5,399 

 37,114 

 3,859 

12,110 

 27,809 

 35,929 

 14,913 

 3,310 

 17,692 

 16,511 

 39,151 

 9,872 

 18,843 

44,050 

 59,032 

 24,835 

 51,212 47,228 59,586 

 18,326 

 91,316 84,766 

 65,526 

25,334 

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

No Action (121,273) Alt. A (91,179) Alt. B (104,783) Alt. C (174,520) Alt. D (115,448)

Harvest Land Base by Alternative (Acres)

Low Moderate Mixed High
Chapter 3 - AE&EC – Fire and Fuels

204 | Page

Figure 3-46. Stand-level fire hazard for the Harvest Land Base in the interior/south within the WUI, 

current condition and by alternative in 2063. 

In 50 years, all alternatives would slightly increase the proportion of Low hazard acres, relative to the 

current condition in the Harvest Land Base in the interior/south (Figure 3-46). Alternative D would 

decrease the proportion of High and Moderate hazard by 35 percent, Alternative B would result in a 

decrease of 30 percent, and Alternative C would only slightly decrease the proportion of High hazard. The 

No Action alternative and Alternative A would both result in slight increases of the acreage in High and 

Moderate hazard within close proximity to Wildland Developed Areas. 

In summary, all alternatives would reduce the acres of High or Moderate fire hazard and increase the 

acres of Low hazard, relative to current conditions, within close proximity to Wildland Developed Areas. 

The slight differences among the alternatives largely reflect the different extents and varied patterns 

resulting from management within the Harvest Land Base. 

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 wildfire risk associated with residual activity fuels 

resulting from timber management activities, treatment locations relative to Wildland Developed Areas 

(WWRA 2013 explanation in Issue 3), and the Wildland Fire Potential (WFP) (FSIM – USDA 2012) for 

all BLM-administered lands within the decision area.

16,991 

47,795 

5,840 7,532 10,241 

26,804 

10,466 

24,991 

10,446 

37,710 25,263 

41,233 

9,338 

14,742 

11,251 

19,604 

12,457 

22,192 

12,843 

11,350 

125,874 

90,216 

14,547 

12,200 

59,547 

74,884 

59,341 

58,649 

49,018 

61,941 

136,977 125,869 

52,356 47,607 88,720 

48,477 

101,886 

78,318 

90,843 

52,150 

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

No Action (305,105) Alt. A (82,080) Alt. B (169,759) Alt. C (184,150) Alt. D (163,151)

Harvest Land Base by Alternative (Acres )

Low Moderate Mixed High
Chapter 3 – AE&EC – Fire and Fuels

205 | Page

Wildfire risk describes the likelihood, susceptibility, and intensity for wildfire and adverse effects to 

human values. In this analysis, the BLM assumed that Wildland Developed Areas are a highly-valued 

resource, the Wildland Fire Potential describes the likelihood for fire, 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 

(FSim). Within the planning area, the distribution of Wildland Fire Potential closely resembles the 

proportions of dry and moist forest across the planning area (Figure 3-47 and Figure 3-48). The 

interior/south has more acreage in the very high and high Wildland Fire Potential categories than the 

coastal/north. 

Chapter 3 – AE&EC – Fire and Fuels

207 | Page

Figure 3-48. Wildland Fire Potential for BLM-administered lands. 

In this analysis, the BLM determined a relative weighting of residual activity fuel that would remain 

following timber management activities (Table 3-45), 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 

the event of a wildfire (Weatherspoon and Skinner 1995, North 2012, 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 3-45. 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 HITA in Alternatives A and C. Heavy and moderate two-age regeneration harvest would 

occur in the Matrix in the No Action alternative and the MITA in Alternatives B and D. Light two-age 

regeneration harvest would occur in the LITA in Alternative B. Heavy selection harvest would generally 

occur in the Uneven-Aged Timber Area in all action alternatives. 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. Thinning and pre-commercial thinning would occur throughout the Harvest 

Land Base in all alternatives. These harvest intensities are rough generalizations used as analytical 

assumptions, but are not intended to replace or supplement management direction in each alternative. 

 154,398 

 377,879 

 385,572 

 450,944 

 499,709 

 205,162 

 399,605 

 1,675 

0

250,000

500,000

750,000

1,000,000

1,250,000

1,500,000

Interior/South Coastal/North

Acres 

Planning Area Region 

Wildland Fire Potential: Low and Very Low Moderate High Very High
Chapter 3 - AE&EC – Fire and Fuels

208 | Page

Additional factors influence the need and ability to mitigate residual fuel loading, such as stand structure, 

yarding method, harvest unit size, biomass utilization, topography, road proximity, soil composition, fuel 

decomposition rates and 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 3-46) based on the weighted combination of 

Wildland Fire Potential (USDA FS FMI 2013), treatment location relative to the zone within 1 mile of 

developed areas (WWRA – WDA 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 developed areas 

and a weight of 2 to areas within 1 mile of wildland developed 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. 

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. The BLM evaluated the alternative effects on the potential acres in 

need of treatment to mitigate the hazard and relative risk posed from residual activity fuel loading 

associated with management activities throughout the decision area. 

Table 3-46. Risk category based on predicted residual activity fuel following harvest, proximal location 

to Wildland Developed Areas, and wildfire potential. 

Wildfire 

Potential

Proximity to Developed 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 Developed Areas (WWRA – WDA 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 (Table 3-46). 

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 wildfire risk, based on Wildfire Potential and proximity to WUI, for BLM-administered lands 

follows a similar pattern to the moist and dry forest distribution across offices (Table 3-47). The 

coastal/north has over 60 percent of BLM-administered lands in the Low risk category. Most of the 
Chapter 3 – AE&EC – Fire and Fuels

209 | Page

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, while nearly thirty percent is at Low risk. 

Table 3-47. Current fire risk for BLM-administered lands. 

Planning Area Region Risk Category (Acres) 

Low Moderate High Very High 

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 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 have the most average acres of timber management activities per decade in the coastal/north, and 

Alternative B would have the most average acres of timber management activities per decade in the 

interior/south (Figures 3-49 and 3-50). 

Figure 3-49. Activity fuel risk categories for BLM-administered lands in the coastal/north, decadal 

average 2013-2063, by alternative. 

84,338 

54,342 

77,838 

102,853 

70,678 

13,764 

19,555 

17,878 

32,750 

11,073 

2,187 

3,905 

3,477 

7,236 

1,624 

0 

5 

56 

58 

34 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

No Action Alt. A Alt. B Alt. C Alt. D

Acres 

Low Moderate High Very High
Chapter 3 - AE&EC – Fire and Fuels

210 | Page

Figure 3-50. Activity fuel risk categories for BLM-administered lands in the interior/south, decadal 

average 2013-2063, by alternative. 

The majority of managed acres in the coastal/north would be at Low risk from residual activity fuel under 

all alternatives (Figure 3-49). 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. Alternative C would result in the greatest amount of Low risk 

acreage per decade in the coastal/north. 

Over the course of 50 years, both Alternatives B and C would result in the most acres of Moderate and 

High risk for the interior/south. Alternatives A and D would result in the fewest average acres per decade 

of Moderate and High residual fuel risk (Figure 3-50). Alternatives B, C, and D would result in the 

largest amount of Low risk acreage. The No Action alternative and Alternative A would create a very 

small acreage of 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. For example, alternatives that would have the 

greatest amount of timber harvest and pre-commercial thinning per decade would also have the greatest 

acres in moderate and high risk. This is true of Alternative C in both the coastal/north and interior/south, 

and Alternative B in the interior/south. Alternative A has the smallest Harvest Land Base, but a larger 

portion of it is the High Intensity Timber Area. Consequently, Alternative A would have amounts of 

Moderate and High risk similar to Alternative B in the coastal/north and Alternative D in the 

interior/south. The Harvest Land Base is larger in both Alternatives B and D, but the harvest intensity 

would be less.

42,587 31,601

53,354 54,022 50,635

34,412

24,067

60,030 53,974

25,505

17,469

13,157

39,392

36,234

13,296

2,113

1,473

32

875

315

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

No Action Alt. A Alt. B Alt. C Alt. D

Acres

Low Moderate High Very High
Chapter 3 – AE&EC – Fire and Fuels

211 | Page

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 wildfire potential and wildfire probability 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, as the districts with greater proportions of moist forest tend to have lower Wildfire Potential 

(Figures 3-31 and 3-48). 

Coupling the activity fuel risk with stand-level hazard or resistance (Issue 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 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 (see Issues 2 and 3). Treatment 

of residual activity fuels in Alternative B may provide greater overall benefit at a similar cost. In addition, 

in the interior/south, Alternative D would have the fewest acres in high/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 

also have the greatest residual fuel load risk and the highest relative stand-level hazard. The No Action 

alternative, and Alternatives B and D would have similar amounts of activity fuel risk and stand-level 

hazard ratings. Under all alternatives, in the coastal/north, these relationships between stand-level hazard 

and activity fuel risk are more straightforward. 

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. The acreage in activity fuel risk categories 

provides an estimate of potential future work needed to reduce the risk associated with activity fuels. 

Coupling the stand-level wildfire 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 fuel treatments? 

All of the alternatives have similar management objectives and management direction regarding noncommercial natural hazardous fuel 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 (Table 3-48), 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 previously-treated non-commercial hazardous fuel units. 

 
Chapter 3 - AE&EC – Fire and Fuels

212 | Page

Table 3-48. Non-commercial natural hazardous fuel treatment acres, 2003-2012, by treatment type and 

BLM district/field office. 

District/

Field Office

Biomass 

Removal

(Acres)

Hand Pile

and Burn

(Acres)

Machine Pile 

and Burn

(Acres)

Mechanical 

Manual43

(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 fuel 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 fuel 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 

fuel treatments resulting from the alternatives 

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 ofthese factors. The full range of 

wildfire response tactics would be available under all alternatives. Maintenance of fire suppressionrelated infrastructure would not change among alternatives. The ability to conduct salvage harvest for 

purposes of protecting human health and safety within the dry forest would be available under all 

alternatives. Because these factors would not differ among the alternatives, there is no reasonable basis on 

which to identify a difference in the effect of the alternatives 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. 

43 Mechanical manual includes thinning, mowing, chipping, and lop and scatter, etc. See glossary for additional 

treatment descriptions. 
Chapter 3 – AE&EC – Fire and Fuels

213 | Page

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Fisheries 

Key Points 

x All of the alternatives would increase the potential large wood and small functional wood 

contribution to streams from the current conditions over time. 

x Sediment production from road construction and operation would increase by less than 1 percent 

under all alternatives, 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. 

x Under the No Action alternative, and Alternatives A and D, 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 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. 

Background 

Threatened and endangered anadromous fish species in the planning area include: 

x Lower Columbia River Chinook Salmon 

x Lower Columbia River Coho Salmon 

x Lower Columbia River Steelhead Trout 

x Columbia River Chum Salmon 

x Upper Willamette River Chinook Salmon 

x Upper Willamette River Steelhead Trout 

x Southern Oregon/Northern California Coho salmon 

x Oregon Coast Coho Salmon 

x North American Green Sturgeon 

x Pacific Eulachon 

The National Marine Fisheries Service designated critical habitat for eight anadromous salmonid species 

within the planning area (Table 3-49). 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 draft recovery plan for 

the Oregon Coast coho salmon. The U.S. Fish and Wildlife Service has published recovery plans for bull 

trout (USDI FWS 2014), Lost River sucker and shortnose sucker (USDI FWS 2012) and Oregon chub 

(USDI FWS 1998). 

 
Chapter 3 - AE&EC – Fisheries

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Table 3-49. Federal Register notices for listing status, critical habitat designation, and ESA protective 

regulation for listed anadromous fish in the planning area. 

Species Listing Status Critical Habitat Protective Regulation

Lower Columbia River Chinook Salmon 06/28/2005;

70 FR 37160 09/02/2005;

70 FR 52630

06/28/2005;

70 FR 37160

Upper Willamette River Chinook Salmon

Columbia River Chum Salmon

Lower Columbia River Steelhead Trout 01/05/2006;

Upper Willamette River Steelhead Trout 71 FR 834

Lower Columbia River Coho Salmon 06/28/2005;

70 FR 37160

01/14/2013;

78 FR 2726

Southern Oregon/Northern California 

Coho Salmon

05/05/1999;

64 FR 24049

Oregon Coast Coho Salmon 06/20/2011;

76 FR 35755 02/11/2008; 73 FR 7816

Pacific Eulachon 03/18/2010;

75 FR 13012

10/20/2011;

76 FR 65324

06/28/2005;

70 FR 37160

Threatened or endangered resident fish species in the planning area include: 

x Bull Trout 

x Lost River Sucker 

x Shortnose Sucker 

x Oregon Chub (proposed for delisting) 

The amount of critical habitat for non-salmonid fish species or resident salmonid fish species on BLMadministered lands is less than 5 percent of all critical habitat for fish in the decision area (Table 3-50). 

The BLM has very limited ability to affect these non-salmonid and resident salmonid fish species or their 

critical habitat through forest management, infrastructure maintenance, or habitat manipulations. The 

analysis contained herein will therefore focus on anadromous salmonids and effects to their habitat. 

Table 3-50. Listed fish species with miles and percent of critical habitat on BLM-administered lands. 

Species

Miles of 

Critical 

Habitat

Miles of Critical Habitat 

on BLM-administered 

land in the Planning Area

Percent of all 

Critical Habitat that 

is on BLM lands

Bull Trout (Salvelinus confluentus) 4,954 3.6 < 0.1

Shortnose sucker (Chasmistes 

brevirostris) 208 9.0 4.3

Lost River sucker (Deltistes luxatus) 141 0 0

Pacific eulachon (Thalyichthys pacificus) 335 0.1 < 0.1

Green sturgeon (Acipenser medirostris) 1,107 0.07 < 0.1

Pacific lamprey (Entosphenus tridentatus), though not a Federally-listed species, 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). Pacific lamprey life history and 

habitat usage is sufficiently similar to listed salmonid fish species to allow them to be analyzed together. 
Chapter 3 – AE&EC – Fisheries

219 | Page

Columbia River chum and Oregon chub, although occurring in the planning area, are not present in 

streams adjacent to BLM-administered lands. The U.S. Fish and Wildlife Service has recently proposed to 

delist the Oregon chub (79 FR 7136). 

Several other non-salmonid species occur in a relatively small percentage of streams on BLMadministered lands (Table 3-50). These populations, based on the very low interaction with BLMadministered lands, have very little potential to be affected by BLM management actions. 

In 2011, National Marine Fisheries Service conducted a formal status review of Federally-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 review in 2005. Only the Lower Columbia coho had a biological risk assessment of in 

danger of extinction with the remaining species likely to become endangered. 

Although a wide variety of anadromous and resident salmonid 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. 

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 RMP/EIS (USDI BLM 2008, pp. 372-390) provide more detailed explanation of the influence of 

key ecological processes on fish habitat and fish populations, and those discussions are incorporated here 

by reference. 

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 one percent of all fish-bearing streams in the planning 

area. The BLM has thinned 17,461 acres forest stands within the Riparian Reserves in the decision area 

since 1995. This accounts for approximately 2 percent of the 938,467 acres within Riparian Reserves 

under the 1995 RMPs. 

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 on the potential contribution of large 

and small functional wood to fish-bearing and non-fish bearing streams at the watershed scale 
Chapter 3 - AE&EC – Fisheries

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(Hydrologic Unit Code 10).44 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. 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. Instead, this analysis, like the 2008 RMP/EIS, evaluated the potential 

contribution of wood to streams by assessing the condition of forest stands that could potentially deliver 

wood to streams. The alternatives 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. 

The BLM analyzed the potential contribution of wood to streams over 100 years to provide a meaningful 

comparison of the effects of the alternatives 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 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 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 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 in-stream 

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 alternative 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, 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. 

44 Hydrologic Unit Codes (HUC) are a U.S Geological Survey classification based on a hierarchy of nested 

watersheds. 
Chapter 3 – AE&EC – Fisheries

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In this analysis, the BLM assumed that the analytical results in the 2008 RMP/EIS for potential wood 

contribution provide an approximation of the effects of the alternatives in this analysis. The 2008 

RMP/EIS utilized a spatially explicit GIS model to estimate large and small wood delivery to BLMadministered and non-BLM-administered streams for all HUC-10 watersheds within the planning area. 

The 2008 RMP/EIS 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 are intermediate 

between the No Action alternative and the 2008 Proposed RMP. Thus, the analytical results from the 

2008 RMP/EIS for the potential wood contribution of the No Action alternative and the 2008 Proposed 

RMP bracket the effects that would occur under the alternatives 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: 

x The density of large trees (greater than 20” diameter breast height (DBH)) 

x The percentage of forest stand canopy cover in hardwoods (e.g., red alder and big leaf maple) 

x The quadratic mean diameter (QMD) of trees (a weighted average of the size of trees in the 

stand) 

x The number of trees per acre 

These metrics provide broad measures 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 RMP/EIS for potential wood 

contribution provides a reasonable approximation of the effects of the alternatives 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 serves 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.

2000, Table 3-51). 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. 

 
Chapter 3 - AE&EC – Fisheries

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Table 3-51. 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 height45 in width from edge of the 

active channel. 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 flowss and slope failures. These slope 

failures 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 RMP/EIS 

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 48 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). 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 (Bigelow 2007, Reeves et al. 2003).

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. 

45 Site-potential tree-heights generally range from 140 feet to 210 feet across the decision area, depending on site 

productivity. 
Chapter 3 – AE&EC – Fisheries

223 | Page

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. (Poage and Tappeiner 2002, Tappeiner et al. 1997). The 2008 RMP/EIS 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 Reserves (Lanigan et al. 2012, Reeves et al. 2006). 

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 3-51). 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 more dense, with 

smaller diameter trees, than riparian stands historically. 

 
Chapter 3 - AE&EC – Fisheries

224 | Page

Figure 3-51. Stand conditions within one site-potential tree height; current condition, the No Action in 

2013 and 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 3-52, Figure 3-52). 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. 

Table 3-52. Acres in each structural stage for stands within one site-potential tree height from all streams 

for the current condition and all alternatives in 2113. 

Alternative

Earlysuccessional

(Acres)

Stand

Establishment

(Acres)

Young

(Acres)

Mature

(Acres)

Structurallycomplex

(Acres)

Current Condition 10,325 140,353 232,064 179,570 210,061

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

No Timber Harvest - - 39,354 332,784 400,620

19.0 20.4

8.0

315.7

36.3

15.0 5.9

130.0

39.5

15.4 6.1

121.9

0

50

100

150

200

250

300

350

Average TPA >20"

DBH

Hardwood Canopy

Cover (%)

QMD Conifers

(Inches)

Trees Per Acre

Stand Conditions

Current No Action in 2113 No Timber Harvest in 2113
Chapter 3 – AE&EC – Fisheries

225 | Page

Figure 3-52. Relative proportion of structural stage acres under each alternative for stands within one 

site-potential tree height from all streams; current condition and all alternatives in 2113. 

All of the alternatives 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 in their effect on potential wood contribution. The BLM based this conclusion on 

the analytical results in the 2008 RMP/EIS for potential wood contribution, which provide an 

approximation of the effects of the alternatives in this analysis, as discussed above under analytical 

methods. The 2008 RMP/EIS 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. Because the analytical results from the 2008 RMP/EIS for the No Action alternative and the 

2008 Proposed RMP bracket the effects that would occur under the alternatives in this analysis, and the 

No Action alternative and 2008 Proposed RMP had indistinguishable effects on potential wood 

contribution, the alternatives in this analysis would all have the same effects on potential wood 

contribution as those identified in the 2008 RMP/EIS for the No Action and 2008 Proposed RMP. 

The relative proportion of structural stages within one site-potential tree height would be similar over 

time across alternatives (Figure 3-52, Table 3-52). The similar proportion of structural stages over time 

under all alternatives is consistent with the analytical conclusion that the overall potential wood 

contribution from the alternatives would be similar. Under Alternative 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 would increase the number of trees per acre greater than 20” DBH near streams from the 

current condition (Figure 3-53). 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 Alternative 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 

1% 3% 4% 

18% 

5% 

30% 

5% 5% 

8% 

10% 

5% 5% 

23% 

44% 43% 

41% 

38% 

43% 43% 

27% 

51% 52% 48% 44% 

52% 52% 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Current No Action Alt. A Alt. B Alt. C Alt. D No Timber

Harvest

Acres (%) 

Early-successional Stand Establishment Young Mature Structurally-complex
Chapter 3 - AE&EC – Fisheries

226 | Page

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-

54). 

Figure 3-53. Trees per acre greater than 20” DBH within one site-potential tree height over time. 

Figure 3-54. Trees per acre greater than 20” DBH for stands within one site-potential tree height of 

streams; current conditions and all alternatives in 2113. 

All alternatives would result in a similar decrease in the percentage of canopy cover in hardwoods 

(Figure 3-55). 

0

5

10

15

20

25

30

35

40

45

2013 2023 2033 2113

Trees Per Acre >20" DBH

Year

No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest

18.8

36.3

39.2

34.9

31.5

39.4 39.5

0

5

10

15

20

25

30

35

40

45

Trees Per Acre >20" DBH

Current No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
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227 | Page

Figure 3-55. Percent hardwood canopy cover for stands within one site-potential tree height of streams; 

current conditions and all alternatives in 2113. 

All alternatives would increase the average diameter of trees in stands within one site-potential tree height 

of streams (Figure 3-56); 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 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. 

Figure 3-56. Quadratic mean diameter (QMD) of conifers for stands within one site-potential tree height 

of streams; current conditions and all alternatives in 2113. 

The trees per acre within one site-potential tree height of streams would decrease substantially from 

current conditions under all alternatives (Figure 3-57); that decrease would be similar under Alternatives 

A and D, and would be only very slightly less than the decrease under the No Timber Harvest Reference 

20.5 

15.1 15.4 14.1 

12.8 

15.5 15.5 

0

5

10

15

20

25

Hardwood Canopy Cover (%)

Current No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest

21.6 

29.9 30.2 

23.2 

27.1 

30.3 30.3 

0

5

10

15

20

25

30

35

QMD Conifers (Inches)

Current No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
Chapter 3 - AE&EC – Fisheries

228 | Page

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. The similar trends for these 

stand metrics within one site-potential tree height of streams over time under all alternatives is generally 

consistent with the analytical conclusion that the overall potential wood contribution from the alternatives 

would be similar, but reveals some specific differences among the alternatives in the potential to provide 

wood to streams. 

Figure 3-57. Total trees per acre for stands within one site-potential tree height of streams; current 

conditions and all alternatives in 2113. 

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. 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. In the various metrics shown above, these differences among the 

alternatives in Riparian Reserve width result in only modest differences in 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: 

x Substantial channel migration could move the stream closer to harvested stands outside of the 

Riparian Reserve. Under the action alternatives, this could reduce the potential wood 

contribution to the stream. 

317.7

130.8 123.4 128.7 134.3 122.5 122.8

0

50

100

150

200

250

300

350

Total Trees Per Acre

Current No Action Alt. A Alt. B Alt. C Alt. D No Timber Harvest
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229 | Page

x Tree fall on extremely steep slopes could result in delivery of wood to non-fish-bearing streams 

from beyond 50’ from the stream. Under Alternatives B and C, 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. 

x Debris flows could exceed 100’ in width. Under Alternative C, this could result in fewer trees 

and smaller diameter wood delivered to streams if the debris flow area 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 delineate an inner zone near streams in which stand thinning would not occur. 

Alternatives B and C delineate a smaller inner zone than Alternatives A and D. The No Action alternative 

does not specific 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, given the absence of specific management direction for an 

inner zone under the No Action alternative. Over time, the wider inner zone under Alternatives A and D 

could result in some stands 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 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 streamspecific 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. 

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 would direct thinning 

in the outer zone for a differing set of purposes, including increasing the diversity of riparian species and 

developing structurally-complex stands. Alternatives B and C would also direct that a portion of the trees 

in stand thinning in the outer zone be directionally felled to the stream. Alternatives A and D 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 could result in some stands 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 and Alternatives B and C could result in some 

stands 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 
Chapter 3 - AE&EC – Fisheries

230 | Page

only modest differences in the effect of differing management direction for thinning on potential wood 

contribution to streams. 

In summary, the analysis demonstrates only modest differences among the alternatives 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 would increase the large wood and small functional wood 

contribution to streams over time. This analytical conclusion is based on high-quality information using 

robust analytical methodology and provides an accurate, albeit generalized, description of the effects of 

the alternatives across the decision area and a sound basis for comparing the alternatives. 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 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? 

Analytical Approach 

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 every 1 percent increase in fine sediment from management 

activities would result in a 3.4 percent decrease in fish survival, and that increases in fine sediment less 

than 1 percent would not result in measurable or meaningful effects on fish survival. The 2008 RMP/EIS 

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 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 over time at this scale 

of analysis. Therefore, this analysis focuses on the sediment levels that would 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). 
Chapter 3 – AE&EC – Fisheries

231 | Page

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 

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 2012, the Aquatic and Riparian Effectiveness Monitoring Program, a joint monitoring program through 

the BLM and Forest Service released their 15-year monitoring summary and the analysis and findings 

contained are incorporated here by reference (Lanigan et al. 2012). 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 alternatives, 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. 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 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, 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 in in-stream 

turbidity that would be dispersed within about 500 feet downstream from the source. 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. 

Pacific lamprey require sediment accumulations in slow water habitat to complete juvenile rearing. 

Juvenile lamprey bury themselves in thick sediment deposits where they rear for up to 7 years while filter 

feeding (Luzier et al. 2009). Since none of the alternatives would increase sediment contribution above 

the site level, there are no anticipated effects from any of the alternatives on Pacific lamprey. 

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 
Chapter 3 - AE&EC – Fisheries

232 | Page

disturbance during summer in-stream operating periods (ODFW 2008). Juvenile fish rearing in these 

reaches would be displaced either moving 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 up to 500 feet downstream from the site of the disturbance. Application of 

BMPs (Best Management Practices, Appendix I) would help meet ODEQ water quality standards and 

further reduce the effects of elevated turbidity on juvenile fish. Additionally, because the BLM does not 

anticipate any difference among the alternatives in watershed restoration actions, there would be no 

difference among the alternatives in turbidity because of restoration actions. 

Under all of the alternatives, including the No Action alternative, the effect on stream sediment from 

grazing would remain the same or decrease. As discussed under Livestock Grazing, under all of the action 

alternatives, livestock grazing (acres for grazing, number of allotments, animal unit months, and 

permittees/lessees) would remain the same or decrease. Grazing allotments would either be discontinued 

(Alternative D) or would make progress toward meeting rangeland health standards. 

Where grazing decreases or is eliminated, there would be some recovery of stream-side vegetation that 

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 

including the No Action in the effects to fish from grazing. 

Issue 3 

How would the alternatives vary in maintaining stream temperatures for fish and non-fish bearing 

streams? 

Background 

The 2008 RMP/EIS 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 3-53).

Table 3-53. State of Oregon cold-water protection criteria for trout, salmon, and steelhead. 

Salmonid Beneficial Use Criteria

Salmon and Steelhead Spawning 55.4 qF

Core Coldwater Habitat 60.8 qF

Salmon and Trout Rearing and Migration 64.4 qF

Salmon and Steelhead Migration Corridor 68.0 qF

Lahontan Cutthroat Trout or Redband Trout 68.0 qF

Bull Trout Spawning and Juvenile Rearing 53.6 qF

Affected Environment and Environmental Consequences 

As stated in Hydrology, the riparian management strategies under the No Action and Alternatives A and 

D would be highly protective of stream shade and would have little risk of increasing stream 

temperatures. Under these alternatives, 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 
Chapter 3 – AE&EC – Fisheries

233 | Page

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. 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. 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 in 30 years 

under the No Action alternative. 

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 reach scale, a loss in stream shade that would result in stream heating could induce non-lethal heat 

stress on juvenile salmonids rearing where stream temperatures already exceede ODEQ standards for fish 

use. This could include lowered disease resistance and reduced growth rates. 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 Hydrology section identifies watersheds that would be susceptible to peak flow increases from rainon-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 RMP/EIS 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 

land in the planning area would be susceptible to peak streamflow increases under any alternative. 

Consistent with the conclusions in the 2008 RMP/EIS, there would be no identifiable difference among 

the alternatives in the effects on fish from peak flow increases for the following two reasons: 1) there is 

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 
Chapter 3 - AE&EC – Fisheries

234 | Page

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. 

How would stream productivity resulting from nutrient and sunlight influences vary between the 

alternatives? 

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 (Kiffney et 

al. 2014, Wootton 2012). 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 year-round and, in turn, support large numbers of juvenile fish (Wifpli 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 

would limit near-stream thinning to maintain stream shading; however, Alternatives B and C, which 

could partially reduce stream-side 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. 

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 Wifpli 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. 

References 

Beechie, T. J., G. Pess, P. Kennard, R. E. Bilby and S. Bolton. 2000. Modeling recovery rates and pathways for woody debris 

recruitment in northwestern Washington streams. North American Journal of Fisheries Management 20: 436-452. 

Benda, L., C. L. Veldhuisen, and J. Black. 2003. Debris flows as agents of morphological heterogeneity at low-order confluences, 

Olympic Mountain, Washington. Geological Society of America 115(9): 1110-1121. 

Bigelow, P. E., L. E. Benda, D. J. Miller, and K. M. Burnett. 2007. On debris flows, river networks and the spatial structure of 

channel morphology. Forest Science 53: 220-238. 

Cederholm, C. J., L. M. Reid, and E. O. Salo. 1981. Cumulative effects of logging road sediment on salmonids populations in the

Clearwater River, Jefferson County, Washington. In: Proceedings to the conference on salmon spawning gravel: a renewable 

resource in the Pacific Northwest? Water Research Center Report 39. Washington State University. Pullman, WA. 

Chaloner, D. T., and M. S. Wipfli. 2002. Influence of decomposing Pacific salmon carcasses on macroinvertebrate growth and 

standing stock in southeastern Alaska streams. Journal of the North American Benthological Society 21(3): 430-443. 

Hill, W. R., M. G. Ryon, and E. M. Shilling. 1995. Light limitation in a stream ecosystem: responses by primary producers and 

consumers. Ecology 76(4): 1297-1309. 

Kiffney, P. M., E. R. Buhle, S. M. Naman, G. R. Ress and R. S. Klett. 2014. Linking resource availability and habitat structure to 

stream organisms: an experimental and observational assessment. Ecosphere 5(4): Article 39. 

Lagrue, C., J. S. Koninoski, M. Danger, J. Baudoin, S. Lamothe, D. Lambrigot, and A. Lecergf. 2011. Experimental shading 

alters leaf litter breakdown in streams of contrasting riparian canopy cover. Freshwater Biology 56: 2059-2069. 

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 FS, Pacific 

Northwest Research Station, Portland, OR. 155 p. 

Luzier, C. W., and 7 coauthors. 2009. Proceedings of the Pacific Lamprey Conservation Initiative Work Session – October 28-29, 

2008. USFWS, Regional Office, Portland, Oregon, USA. 

May, C. L., and R. E. Gresswell. 2004. Spatial and temporal patterns of debris-flow deposition in the Oregon Coast Range, USA. 

Geomorphology 57: 135-149. 
Chapter 3 – AE&EC – Fisheries

235 | Page

Murphy, M. L., and K. V. Koski. 1989. Input and depletion of woody debris in Alaska streams and implications for streamside 

management. North American Journal of Fisheries Management 9: 427-436. 

USDC NMFS. 2011. United States Department of Commerce – National Marine Fisheries Service.Status Review Update of 

Pacific Salmon and Steelhead Listed Under the Endangered Species Act: Pacific Northwest. p. 281. 

---. 2011. Upper Willamette River Conservation and Recovery Plan for Chinook Salmon and Steelhead. Prepared by National 

Marine Fisheries Service, Northwest Region. 

---. 2013. Lower Columbia River Salmon and Steelhead ESA Recovery Plan. Prepared by National Marine Fisheries Service, 

Northwest Region. 

---. 2014. Final Recovery Plan for the Southern Oregon/Northern California Coast Evolutionarily Significant Unit of Coho 

Salmon (Oncorhynchus kisutch). National Marine Fisheries Service, Arcata, CA. 

Oregon Department of Environmental Quality. 2009. High level indicators of Oregon Forested Streams. Portland, OR. 76 p. 

Oregon Department of Fish and Wildlife (ODFW). 2008. Oregon Guidelines for timing of in-water work to protect fish and 

wildlife resources. Portland, OR. pp.12. 

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. 

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 FS, Pacific Northwest Research Station, Portland, Oregon. 

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. 

Spies, T., M. Pollock, G. Reeves, and T. Beechie. 2013. Effects of riparian thinning on wood recruitment: a scientific synthesis. 

Science Review Team Wood Recruitment Subgroup. USDA FS, Pacific Northwest Science Laboratory, Corvallis, OR, and 

NOAA Fisheries Northwest Fisheries Science Center, Seattle, WA. 

Suttle, K. B., M. E. Power, J. M. Levine, and C. McNeely. 2004. How fine sediment in riverbeds impairs growth and survival of 

juvenile salmonids. Ecological Applications 14(4): 969-974. 

Tappeiner, J. C., D. Huffman, D. Marshall, T. A. Spies and J. D. Bailey. 1997. Density, ages, and growth rates in old-growth and 

young-growth forests in coastal Oregon. Canadian Journal of Forest Research 27: 638-648. 

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. 

USDI FWS. 1998. Oregon Chub (Oregonichthys crameri) Recovery Plan. Portland OR. 69 pp. 

---. 2012. Revised Recovery Plan for the Lost River sucker (Deltistes luxatus) and shortnose sucker (Chasmistes brevirostris). 

USDI FWS, Pacific Southwest Region, Sacramento, California. 122 pp. 

---. 2014. Revised Draft Recovery Plan for the coterminous United States population of bull trout (Salvelinus confluentus). 

Portland, Oregon. 151 pp. 

Waters, T. F. 1995. Sediment in streams: sources, biological effects, and control. American Fisheries Society Monograph 7. 

Wifpli, 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: 957-969. 

Wooton, J. T. 2012. River food web response to large-scale riparian zone manipulations. PloS one 7(12): 1-9. 

 
Chapter 3 - AE&EC – Forest Management

236 | Page

Forest Management 

Key Points 

x 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 stand,s and mature forests with multiple canopy layers. 

x The allowable sale quantity (ASQ) under the alternatives would range from 120 million board 

feet per years under Sub-alternative B to 486 million board feet per year under Alternative C. The 

ASQ is primarily determined by the size of the Harvest Land Base, the intensity of forest 

management practices, and restrictions on timber harvest. 

x Non-ASQ timber harvest volumes in the first decade would range from 4 million board feet per 

year under Alternative D to 122 million board feet per year under the No Action alternative. 

x The proportion of harvest volume coming from large logs 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. 

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? 

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 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, based 

on the management direction found in Appendix B. 

In this analysis, the BLM evaluated the development of the forest categorized by structural stages (Table 

3-54). The Vegetation Modeling section has a more thorough discussion of the structural stage 

classification system. 

Chapter 3 - AE&EC – Forest Management

238 | Page

Figure 3-58. 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 million board feet 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 million board 

feet per year (Figure 3-59).

Figure 3-59. 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 (Million Board Feet)

Year

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

1962 1967 1972 1977 1982 1987 1992 1997 2002 2007

Timber Harvests (Million Board Feet )

Year

Grand Total Private USFS BLM State
Chapter 3 – AE&EC – Forest Management

239 | Page

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 forested lands in the decision areas is shown in Figure 3-60. 

Figure 3-60. 2013 age class distribution for forested acres within the decision area. 

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 34 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 10-year age class 

(Table 3-55). This is mostly due to the low levels of regeneration harvesting that the BLM has 

implemented since 1994 (Figure 3-71). 

 

33,762 

476,390 490,510 

320,388 335,502 

505,146

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) 

10-Year Age Class Groupings 
Chapter 3 - AE&EC – Forest Management

240 | Page

Table 3-55. 2013 age class distribution; forested acres and percent by district/field office. 

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 73,119 304,137

% 1% 30% 26% 7% 12% 24%

Eugene Acres 2,669 78,887 112,471 41,556 17,022 44,617 297,222

% 1% 27% 38% 14% 6% 15%

Klamath Falls Acres 4,656 3,636 8,321 18,105 6,965 5,090 48,011

% 10% 8% 17% 38% 15% 11%

Medford Acres 17,555 106,119 92,706 139,498 166,057 218,184 740,119

% 2% 14% 13% 19% 22% 29%

Roseburg Acres 3,187 106,920 74,160 35,108 50,838 128,950 399,163

% 1% 27% 19% 9% 13% 32%

Salem Acres 2,406 89,082 123,325 64,751 59,641 35,186 374,541

% 1% 24% 33% 17% 16% 9%

Totals Acres 33,762 476,390 490,510 320,388 335,502 505,146 2,163,193

% 2% 22% 23% 15% 16% 23%

The alternatives vary in their approach to protection of older, more structurally-complex 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 older than 80 years to the Harvest Land Base, while Sub-alternative 

C allocates the least (Figure 3-61). Of the forests older than 80 years in the Harvest Land Base in 

Alternative B, 73 percent of the acreage is in the dry forest portion of the decision area. 

20 172 202 157 140 147

13

304 287

163 195

357

0

100

200

300

400

500

600

Forested Acres (Thousands)

10-Year 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)

10-Year Age Class (Alt. A)

2013 Harvest Land Base 2013 Reserves
Chapter 3 – AE&EC – Forest Management

241 | Page

19 186 206 

139 92 63 

14 

290 285 

181 244 

442 

0

100

200

300

400

500

600

Forested Acres (Thousands) 

10-Year 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) 

10-Year Age Class (Sub. B) 

2013 Harvest Land Base 2013 Reserves

23 

246 267 

178 153 

11 

231 224 

142 183 505 

0

100

200

300

400

500

600

Forested Acres (Thousands) 

10-Year 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) 

10-Year Age Class (Sub. C) 

2013 Harvest Land Base 2013 Reserves
Chapter 3 - AE&EC – Forest Management

242 | Page

Figure 3-61. 2013 Age class distribution; by 10-year age class grouping by alternative, the Harvest Land 

Base, and Reserves. 

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 structurallycomplex forests in Alternative B is based on district-defined maps, rather than stand age, which explains 

why Alternative B would allocate some older stands, especially in the dry forest, to the Harvest Land 

Base (Figure 3-53).

Over time, the age class distribution in the decision area would represent the product of management 

under the different alternatives. 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 natural disturbances including wind-throw or insect and disease 

epidemics in the vegetation modeling. 

The BLM’s simulations of wildfire impacts on 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 forests. 

In the Harvest Land Base, the future age class distribution would be determined by the harvest intensity 

and cutting cycle under each alternative (Figure 3-62).

25

271 267

181

90

9

206 224

140

246

505

0

100

200

300

400

500

600

Forested Acres (Thousands)

10-Year Age Class (Alt. D)

2013 Harvest Land Base 2013 Reserves
Chapter 3 – AE&EC – Forest Management

243 | Page

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) 

10-Year 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) 

10-Year 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) 

10-Year 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) 

10-Year Age Class (Sub. B) 

2113 Harvest Land Base 2113 Reserves
Chapter 3 - AE&EC – Forest Management

244 | Page

Figure 3-62. 2113 age class distribution; by 10-year age class grouping by alternative, broken out 

between the Harvest Land Base and Reserves. 

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, the portions of 

the Harvest Land Base in the Moderate Intensity Timber Area (MITA) and Low Intensity Timber Area 

133 206 172 58

82

214

4 13 329

949

0

200

400

600

800

1,000

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1,400

Forested Acres (Thousands)

10-Year 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)

10-Year 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

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Forested Acres (Thousands)

10-Year Age Class (Alt. D)

2113 Harvest Land Base 2113 Reserves
Chapter 3 – AE&EC – Forest Management

245 | Page

(LITA) would generally trend towards regulation in age classes 0-140 years in the dry forest, and 0-100 

years in the moist forest. 

The portions of the Harvest Land Base in the Uneven-aged Timber Area (UTA) in all action alternatives 

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 UTA and OHTA 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 stand-wide regeneration harvest. These stands would transition to multiaged, 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 impacts on the future age class 

distribution (Table 3-56). 

Table 3-56. Percentage of Harvest Land Base in each land use allocation category. 

Alternative 

Long Rotation Two-aged; GFMA, NGFMA, 

SGFMA, CONN, AMA, LITA, MITA

(Percent) 

Short 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% 

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 UTA and OHTA, would 

continue to age since the stand age would never be reset to zero, barring an intense natural disturbance 

event. The relatively short rotation even-aged management regimes and associated clear-cutting in the 

HITA 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 (VRH) in the No Action alternative, in the MITA and LITA in Alternative B and 

Sub-alternative B, and in the MITA in Alternative D 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. The more clear-cutting and variable-retention 

regeneration harvesting46 in an alternative, 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 (Figures 3-61 and 3-62). 

Structural Stages 

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 

 

46 The BLM uses the term variable-retention regeneration harvest in this analysis to describe regeneration harvest 

practices in the No Action alternative. The 1995 RMPs require retention of green trees in regeneration harvests 

based on a range of trees per acre. 
Chapter 3 - AE&EC – Forest Management

246 | Page

establishment without structural legacies, young without structural legacies, mature, and structurallycomplex forest (Figure 3-63). Table 3-54 lists the structural stage classifications. 

Figure 3-63. Current structural stage distribution for decision area. 

The BLM management has the potential to cause significant changes to the structural stage distribution of 

forested lands in the decision area over time. The 2008 RMP/EIS 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 reserves 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. Since the majority of forested land resides in reserve land use 

allocations in all alternatives, structural stage differences between alternatives are muted when the 

Harvest Land Base and Reserves are combined, therefore they will be shown broken out. Figures 3-61

and 3-62 highlight the structural stage progression through time for each alternative, grouped into similar 

categories, and broken out by Harvest Land Base and reserves. 

The proportion of the Harvest Land Base composed of mature multiple canopy and structurally-complex 

forests in 2013 in each alternative would be mostly driven by the alternative-specific approach to the 

protection of older, more structurally-complex forests. The BLM has grouped mature multiple canopy 

forests with structurally-complex forests in the following figures and discussion due to their similarities 

related to northern spotted owl habitat quality (Figure 3-64).

13,97132,278

68,428

320,340

129,403

443,629

11,672

38,211

241,350

273,973

241,801

327,999

18,634

0

100,000

200,000

300,000

400,000

500,000

Acres 

Structural Stage Classification
Chapter 3 – AE&EC – Forest Management

247 | Page

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

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Figure 3-64. Structural stage progression over 200 years in the Harvest Land Base and reserves. 

The No Action alternative contains the highest proportion of the Harvest Land Base in mature, multiple 

canopy and structurally-complex structural stages (35 percent). Sub-alternative C contains the smallest 

proportion of these forests in the Harvest Land Base, with approximately 5 percent, since the BLM would 

reserve all stands greater than 80-years-old in this alternative. It is notable that although close to 25 

percent of the Harvest Land Base is in this category in Alternative B, 75 percent of those acres are in dry 

forests, which the BLM would allocate to the UTA in this alternative. Alternative B includes a districtdefined 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 

(Figures 3-65 and 3-66). 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 earlysuccessional, stand establishment, young, mature, and structurally-complex in 100 years. In the No Action 

alternative and Alternative B, the Harvest Land Base would mostly trend towards multi-storied stands and 

structural stages with structural legacies, with mature and structurally-complex 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 3-56), the majority of the Harvest Land 

Base would develop into mature or structurally-complex forest in 100 years. 

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Figure 3-65. Proportion of the Harvest Land Base as mature or structurally-complex. 

Under Alternatives A and C, clear-cutting in the HITA would produce relatively uniform, single–story 

stands, with little to no structural legacies. In contrast, the variable-retention regeneration harvesting in 

the No Action alternative and Alternatives B and D would produce heterogeneous, multi-layered stands 

with structural legacies (Figure 3-66). This is consistent with the analytical conclusions about the effect 

of different regeneration harvest approaches on structural stage development in the 2008 RMP/EIS (USDI 

BLM 2008, pp. 505-506, 508-513, 517) and recent publications on retention forestry (Gustafsson et al. 

2012). 

No Action 

Alt. A 

Alt. B 

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Alt. C 

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Alt. D 

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Figure 3-66. Proportion of the Harvest Land Base with structural legacies or multiple layers. 

The data is not shown for Alt. D MITA, Alt. A, C, and D UTA since the land use allocation development trends are nearly 

identical between alternatives. 

Clear-cutting under Alternatives A and C would produce different post-harvest conditions than variableretention regeneration harvesting under the No Action alternative and Alternatives B and D. Alternative C 

would produce the most early-successional conditions of any alternative, while Alternative B would 

produce the most early-successional with structural legacies (Figure 3-67).

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Alt. B UTA Alt. C HITA Alt. D OHTA
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Figure 3-67. Structural complexity and abundance of early-seral structural stage in 2063. 

In the Reserves, the pattern of structural stage development would vary little among the alternatives, 

because the BLM would implement silvicultural treatments in the reserve land use allocations only for 

restoration purposes under all alternatives. Under all alternatives, stands in the Reserve land use 

allocations would generally trend towards mature and structurally-complex conditions, while earlysuccessional, stand establishment, and young stands would mostly disappear over time. 

Natural disturbances, especially wildfire, would create some areas of early-successional forest, regardless 

of land use allocation designation. Because the acreage of Reserve allocations would vary by alternative, 

the acreage of reserve allocations that would be affected by wildfire would vary by alternative 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 condition for three decades. This would only 

yield up to 345 acres of early-successional forest in the coastal/north areas, and 6,951 acres of earlysuccessional forests in the interior/south areas in any given decade. The BLM did not simulate the 

impacts of other natural disturbances including wind-throw or insect and disease outbreaks in the 

vegetation modeling. 

Management direction for stand treatments within the Late-Successional Reserve would vary by 

alternative. The No Action alternative and Alternatives B and C would include timber harvesting as a tool 

for attainment of Late-Successional Reserve management objectives. Alternative A would achieve these 

management objectives in moist forest Late-Successional Reserves through non-commercial management 

(i.e., cutting trees but not removing them from the stand). In Alternative D, the Late-Successional 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 OHTA 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. Therefore, the outcomes for the OHTA 

110,272 

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Early-seral with Structural Legacies Early-seral without Structural Legacies
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in Alternative D provide a relevant comparison to the outcomes for portions of the Late-Successional 

Reserve under other alternatives. 

The following figure (Figure 3-68) illustrates the differences in the proportion of forested acres in mature 

multiple canopy and structurally-complex conditions in 2013 and 2213. The BLM grouped the mature 

multiple canopy and structurally-complex structural stages 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 conditions in the LateSuccessional Reserve using non-commercial thinning only (Alternative A). However, 98 percent of stands 

develop into mature multiple canopy and structurally-complex forest in response to the uneven-aged 

management prescriptions in the OHTA in the Harvest Land Base in Alternative D.

Figure 3-68. Proportions of owl habitat management land use allocations in mature multiple canopy or 

structurally-complex structural stages in 2013 and 2223 by alternative. 

Figure 3-69 shows that the proportions of acres in mature multiple canopy and structurally-complex 

conditions in the Late-Successional Reserves, the UTA, and the OHTA would range between 60 percent 

and 81 percent in 100 years. In the HITA under Alternatives A and C, the acreage of mature multiple 

canopy and structurally-complex forest would decline to zero in 100 years due to the emphasis on 

relatively short-rotation clear-cutting harvest practices. The LITA and MITA would achieve moderately 

higher proportions in mature multiple canopy and structurally-complex forest than the HITA under 

Alternatives A and C, with around 10 percent, due the trend towards longer rotation lengths and variableretention regeneration harvest practices. 

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Owl Habitat LUAs Mature Multicanopy or Structurally-complex (%)

2013 2223
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Figure 3-69. Proportions of land use allocations in mature multiple canopy or structurally-complex 

structural stages through time. LSR, UTA, MITA, and LITA are only shown for alternative B since 

developmental trajectory within land use allocations is nearly identical between alternatives. 

The Harvest Land Base in the No Action alternative would contain 38 percent in these 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 would force the BLM to harvest stands less than 80-years-old for up to 100 years 

before transitioning completely to longer rotations. 

In summary, the mix of silvicultural systems and harvesting practices applied within the decision area will 

determine the future of the structural stage distribution 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 forests in the HITA in Alternatives A and C 

would not contain structural legacies. There is a substantial difference in the structural complexity of most 

future forests when comparing the even-aged management (which includes clear-cutting) practices in the 

HITA in Alternatives A and C to the two-aged practices (which include variable retention-regeneration 

harvest) in the No Action alternative, and the LITA and MITA in Alternatives B and Sub-alternative B, 

and the MITA in Alternative D. 

Even-aged management with clear-cutting would result in relatively simple structured forests lacking 

legacy structures, while two-aged harvesting would produce forests with multiple layered canopies and 

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legacy structures. Land use allocations dedicated to uneven-aged management regimes, the UTA and 

OHTA, would eventually produce mature multiple canopy forests and structurally-complex forests in 

proportions equal to or greater than Late-Successional Reserve management. The structural stage 

development of moist LSRs would be similar among all alternatives. Retention of cut trees in Alternative 

A versus commercial removal in other alternatives would not result in differences in structural stage 

development. Land use allocations implementing regeneration harvest in the action alternatives would 

contribute a relatively small proportion of acres to these older and more structurally-complex structural 

stage classifications. The Harvest Land Base in the No Action alternative would contribute a substantially 

higher proportion of mature multiple canopy and structurally-complex forests to the decision area. This is 

because the inclusion of substantial acreages of stands beyond CMAI of net timber volume in the Harvest 

Land Base would allow the BLM to implement long rotations right away, rather than the gradual trend 

towards longer rotations that would be required in the MITA and LITA in Alternative B and Subalternative B, and in the MITA in Alternative D. 

Inventory of Merchantable Timber 

The inventory of merchantable timber volume in the decision area has increased since 1940 (Table 3-57).

Table 3-57. The standing net timber inventory at each re-measurement period. 

Historic Estimates 1940 1960 1970 1980 1990 2006

Timber Volume MMbf (million 

board feet) 46,000 49,100 50,300 46,900 49,900 73,300

Acres Considered in Calculation 2,165,900 2,145,072 2,391,172 1,771,657 1,794,420 2,197,000

A combination of factors caused the large increase between the 1990 and 2006 inventory of timber 

volumes. These include: 

x The increase in acres included in the determination of volume 

x The increase in growth and volume resulting from the increase in faster growing, younger stands 

x Harvest levels below the maximum potential annual productive capacity (Tables 3-60 and 3-61).

Although these inventories were conducted using different inventory systems, different assumptions, and 

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 BLMadministered lands has exceeded harvest levels, especially in the last two decades. Current standing 

timber inventory based on 2013 data is roughly consistent with the 2006 estimate (Table 3-58).

Table 3-58. 2013 Scribner 16’ scale standing timber volume MMbf and forested acres by district or field 

office. 

District/Field Office Total BLM (Acres) Net Inventory (MMbf) Gross Inventory (MMbf)

Coos Bay 304,137 13,456 15,519

Eugene 297,222 13,735 16,623

Klamath Falls 48,011 757 930

Medford 740,119 15,345 20,003

Roseburg 399,163 12,270 15,590

Salem 374,541 16,569 20,739

Totals 2,163,193 72,132 89,404

The amount of current timber inventory within the Harvest Land Base varies primarily with the extent of 

the Harvest Land Base under each alternative. Alternative C contains the highest timber inventory within 
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the Harvest Land Base of any alternative, 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 from 13-33 percent of total timber inventory in 

the decision area among the alternatives. Conversely, reserve land use allocations in the alternatives 

contain between 66-87 percent of total timber inventory among the alternatives (Figure 3-70). 

Figure 3-70. 2013 net inventory broken out between Harvest Land Base and reserves by alternative. 

The timber inventory would increase under all alternatives. This is mostly due to timber volume 

accumulation in the reserve land use allocations. Timber volume would increase between 78-100 percent 

in the reserve over the next 100 years, since the BLM would only be harvesting timber to achieve 

restoration goals (Table 3-59). 

Table 3-59. Percent change in inventory between 2013 and 2113 broken out between Harvest Land Base 

and reserves. Positive numbers indicate inventory increase, while negative numbers indicate inventory 

decrease. 

Inventory No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D 

Reserve 100% 99% 88% 96% 86% 78% 86% 

Harvest Land Base 45% -13% 37% 56% -9% 6% 108% 

Overall 82% 83% 76% 91% 54% 66% 92% 

The timber inventories in the Harvest Land Base would slightly decline in Alternatives A and C, and 

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 sub-optimal timber 

production stands in the HITA into fully-stocked stands near the maximum timber production potential 

for the land. The BLM would only hold the minimum inventory on the Harvest Land Base to ensure longterm sustainability of the timber harvest regime (Table 3-59 and Figure 3-70). 

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Timber inventory would increase in the Harvest Land Base under the No Action alternative, Alternative 

B, Sub-alternative B, and, to the greatest 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, Sub B, and D, 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. 

Another contributing factor leading to the inventory increase in the Harvest Land Base in these 

alternatives is the implementation of uneven-aged management regimes The BLM would implement 

selection harvesting to achieve desired stand conditions in the UTA in all the action alternatives and in the 

OHTA 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 with 108 percent increase 

in net timber inventory in the next 100 years (Table 3-59 and Figure 3-70).

In summary, all alternatives would result in an overall increase in net timber inventory of between 54 

percent (Alternative C), and 92 percent (Alternative D) in the next 100 years. The net timber inventory in 

reserve land use allocations would increase more than 78 percent in all alternatives. 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 HITA land use allocation would transition into a fully regulated relatively shortrotation forest. Net timber inventories in the Harvest Land Base in the No Action alternative, Alternatives 

A, B, Sub-alternative B, and Alternative D would increase between 37 percent (Alternative B) and 108 

percent (Alternative D). The increase in net timber inventories is due to the combination of the modeling 

assumptions guiding the transition of younger forests to long rotations and the implementation of unevenaged management regimes in the action alternatives. The increase in inventory in the No Action 

alternative’s Harvest Land Base is explained primarily by the combination of the non-declining 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).47 The ASQ is the timber volume that a forest 

can produce continuously under the intensity of management described in each alternative for those lands 

47 The terms “annual productive capacity,” “annual sustained yield capacity,” and “allowable sale quantity” are 

synonymous. 
Chapter 3 – AE&EC – Forest Management

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allocated for sustained-yield timber production (i.e., the Harvest Land Base). The calculation of the ASQ 

for each alternative is a direct output from the vegetation modeling analysis for each alternative and 

would vary based on the timing and intensity of timber harvest, silvicultural practices, and restrictions on 

timber harvest in the Harvest Land Base under each alternative. 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 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 marbled murrelet sites and North Coast Distinct 

Population Segment (DPS) red tree vole sites, which, in some alternatives, would be removed from the 

Harvest Land Base and would therefore not be available for sustained-yield timber harvest. See the 

Wildlife section in this chapter for more detail on site management. The forecasting of future marbled 

murrelet sites required slightly different methodologies for the No Action alternative and the action 

alternatives and inherently includes substantial uncertainty. 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 long-term 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 shown in Table 3-62. 

The modeling of future marbled murrelet sites in the No Action alternative assumed that all stands 

currently 120-years-old and older in Matrix and Adaptive Management Areas within 35 miles of the coast 

would be occupied by marbled murrelets and would be reserved from timber harvest. The modeling 

assumed that stands in the Matrix and Adaptive Management Area that are currently less than 120-yearsold would not be occupied by marbled murrelets, even those stands that would become 120-years-old or 

older during the modeling period. The modeling also assumed that no stands greater than 35 miles from 

the coast would be occupied by marbled murrelets. The assumption that all stands currently 120-years-old 

and older within 35 miles of the coast would be 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 would be 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 for the No Action alternative, because the No Action alternative, in 
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contrast to all of the action alternatives, includes harvest of older, more structurally-complex forest, which 

provides the highest quality marbled murrelet nesting habitat. 

Because all of the action alternatives would reserve older, more structurally-complex forest, which 

provides the highest quality marbled murrelet nesting habitat, the forecasting of future marbled murrelet 

sites within the Harvest Land Base focused on younger stands than the No Action alternative. Therefore, 

this analysis used a different methodology for the action alternatives, which was based on extrapolating 

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 that would be reserved from timber 

harvest under an action alternative that would survey for marbled murrelet sites and reserve occupied 

sites. Estimating the acres of occupied marbled murrelet habitat is not the same as estimating the acres 

that would be 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 estimation 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 overestimation of ASQ 

in the alternatives that would require protection of future marbled murrelet sites. 

In order to calculate estimated reductions to ASQ levels from predictions of red tree vole in the action 

alternatives and marbled murrelet site occupancy and protection in all alternatives, the number of acres 

where timber harvest was precluded was determined using Geographic Information System (GIS) 

analysis. GIS analysis was then performed to determine which Harvest Land Base land use 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 ASQ contribution estimated for that land use 

allocation and region based on values derived for Figure 3-72. This methodology produced an estimated 

ASQ reduction for each alternative for predictions of site protection associated with red tree voles and 

marbled murrelets reported in Table 3-62. 

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 OHTA or LSR where needed to 

maintain spotted owl habitat around known, historic, and alternate sites. GIS analysis was used to 

determine how many acres of OHTA or LSR were mapped due to proximity of northern spotted owl sites, 

and the BLM estimated how many acres would have otherwise been mapped as either UTA or MITA. 

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 3-62. 

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-

62 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 area lost to road construction and 

detrimental soil disturbances, insects and disease, defect and breakage, snag and downed wood 

requirements, and other factors. The Vegetation Modeling section earlier in this chapter provides more 

information on the calculations of ASQ and non-ASQ timber volume. 
Chapter 3 – AE&EC – Forest Management

261 | Page

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 3-71). 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 

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 3-71. Assumed vs. implemented annual average sold timber volume (MMbf) levels and mix of 

harvest types, 1995 through 2012. 

The 1995 through 2010 data in Figure 3-71 comes from district data requests for the 2012 Resource 

Management Plan Evaluation Report. 2011 and 2012 data was generated from Forest Resource 

Information System (FRIS) data entered through 10-23-2014. Due to continual updates and data 

correction in FRIS, 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 RMP/EIS (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 (Table 3-60). 

Although there have been some changes in the decision area that would slightly alter these calculations, 

as a result of timber harvest and growth since the calculations in the 2008 RMP/EIS, 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 

(Million Board Feet) 

HLB (ASQ) Regeneration Harvest HLB (ASQ) Thinning Reserve (Non-ASQ) Thinning
Chapter 3 - AE&EC – Forest Management

262 | Page

Table 3-60. Reference analysis; “Manage Most Commercial Lands for Maximizing Timber Production,”

ASQ by district or field office. 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 3-60). 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 Reserves 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 RMP/EIS, which calculated the ASQ for the No Action alternatives 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, followed by Sub-alternative C, and the 

No Action alternative (Table 3-61). Major factors determining the ASQ under a given alternative are 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 3-61. First decade ASQ timber harvest (MMbf/year Scribner 16’ Scale).48

District/Field Office No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Coos Bay 46 46 23 14 82 66 22

Eugene 58 63 56 25 138 103 45

Klamath Falls 8 3 7 4 10 3 5

Medford 73 27 42 15 54 24 28

Roseburg 55 25 35 14 78 51 22

Salem 37 71 71 47 124 85 54

Totals 27749 234 234 120 486 332 176

Size of the Harvest Land Base 

The size of the Harvest Land Base is dependent on a number of factors including Riparian Reserve 

widths, the size of the Late-Successional Reserve, including the threshold for protection of older, more 

structurally-complex forest, and the protection of future sites for some wildlife species under some of the 

48 Reported ASQ volumes are rounded to the nearest MMbf, so there are minor errors associated with rounding. 

49 The BLM has made no deduction in the vegetation modeling for reductions due to management of future Survey 

& Manage sites. This and other issues place uncertainty around the expression of ASQ for the No Action alternative. 
Chapter 3 – AE&EC – Forest Management

263 | Page

alternatives. Chapter 2 contains a description of the design of each alternative and a description of the 

acreage in each land use allocation. The Harvest Land Base under Alternative C would be the largest 

among the alternatives (30 percent of the decision area) and smallest under Sub-alternative B (12 percent 

of the decision area). 

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. This 

difference in the size of the Harvest Land Base reduces the ASQ in Sub-alternative B by 114 million 

board feet 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 would be produced 

on a given acre of ground within a fixed unit of time. Figure 3-72 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. 

Figure 3-72. Timber production rates by management intensity (board feet per acre per year), broken out 

between coastal/north and interior/south areas. 

917 

719 686 

447 

280 

556 

332 

455 

209 

124

0

200

400

600

800

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 Unevenaged

Management

Timber Production 

(Board Feet per Acre per Year) 

Coastal/North Interior/South
Chapter 3 - AE&EC – Forest Management

264 | Page

The highest timber yields per acre would come from the HITA, because of even-aged management 

regimes including relatively short rotations, clear-cutting, rapid reforestation, fertilization, and control of 

competing vegetation. For every acre of HITA in the Harvest Land Base, the ASQ contribution would be 

approximately 917 board feet per year in the coastal/north area, or 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 Matrix50

and Adaptive Management Areas in the No Action alternative, the MITA in Alternatives B and D, and the 

LITA in Alternative B. The reduction in timber yield per acre in these land use allocations compared to 

the HITA 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 

HITA, 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 effects of varying retention levels in these land use allocations would also 

influence the timber yield per acre somewhat. 

Nevertheless, for every acre one of these land use allocations is in the Harvest Land Base in the action 

alternatives, the ASQ contribution would average 686 board feet per year in the coastal/north area, or 455 

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 when compared to the 

action alternatives is that dry forest stands in the Harvest Land Base in the action alternatives would be 

managed using uneven-aged management in the UTA, while these dry forest stands are contained in lands 

dedicated to regeneration harvesting regimes in the No Action alternative. 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. In the MITA 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 LITA in Alternative B, the BLM would rely on natural reforestation after 

regeneration harvest (i.e., natural seeding rather than planting). In all other alternatives, 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 MITA in Alternative B and 

prompt canopy closure in the other alternatives, including the MITA in Alternative D. The average delay 

in canopy closure in the MITA in Alternative B would be 10 to 15 years beyond what would typically 

occur with standard reforestation practices. This delay 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 MITA would be diluted by the trend towards longer rotation lengths that 

would occur in the MITA. Additionally, there are so many factors affecting the varying timber yield per 

acre among alternatives that it is not possible to isolate the effect of this single factor. 

50 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. 
Chapter 3 – AE&EC – Forest Management

265 | Page

The LITA would produce an average of 18 percent less timber yield per acre than the MITA 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 LITA 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 LITA, 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). 

The third-highest timber yields per acre would come from the uneven-aged management in the UTA, 

which is included in all action alternatives. In this land use allocation, 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 UTA in the Harvest Land Base, the ASQ contribution would be approximately 

447 board feet per year in the coastal/north area, or 209 board feet in the interior/south area. 

The lowest timber yields per acre would come from uneven-aged management in the OHTA in 

Alternative D. In this land use allocation, the continuous retention of substantial portions of the stand 

would reduce the timber yields, as in the UTA. However, timber harvest would be further limited in the 

OHTA 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 UTA. Appendix B contains more details on objectives and direction for each land use allocation. For 

every acre of OHTA, 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 land use 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, 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 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. The calculation of the ASQ in this analysis predicted the 

quantitative effects of some 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 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 & Manage protections, and the retention of old-growth fragments in 
Chapter 3 - AE&EC – Forest Management

266 | Page

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 & Manage Mitigation Measure Guidelines discussed 

the difficulties in evaluating the effect of the Survey and Manage protections 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 

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 3-61 for the No Action 

Alternative are 16.8 percent, or 47 MMbf/year too high (Table 3-62). 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 3-61 for the No Action Alternative are likely 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. 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 3-62. Estimated reductions to ASQ from wildlife surveys and site protection, million board feet per 

year.

Alternative Marbled 

Murrelet

Red Tree 

Vole

Northern Spotted 

Owl

Site Management

Survey and 

Manage Totals

No Action 4 4751 - Unknown > 5120

Alt. A - - - - -

Alt. B 6 6 - - 12

Sub. B 6 6 115 - 127

Alt. C 2 - - - 2

Sub. C - - - - -

Alt. D 29 4 57 - 90

The BLM deducted the values from the expression of ASQ in Table 3-62, with the exception of red tree 

vole management in the No Action Alternative. Potential reductions to ASQ in the No Action Alternative 

due to the management of future red tree vole sites were not included in the vegetation modeling. 

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 million board feet per year. 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 million board feet (Table 3-62). None of the other alternatives 

51 The potential 47 MMbf per year reduction in ASQ for the No Action Alternative due to future red tree vole site 

management shown in Table 3-62 was not deducted from the estimate of ASQ in Table 3-61. 
Chapter 3 – AE&EC – Forest Management

267 | Page

would require specific site management for known or historic northern spotted owl sites in the Harvest 

Land Base. 

All alternatives 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 1⁄2 mile around newly-discovered occupied sites, with an estimated 

ASQ reduction of 29 million board feet per year (Table 3-62). The effect of protection of future marbled 

murrelet sites on the ASQ is predicted to be relatively small in Alternative B, Sub-alternative B, and 

Alternative C, because these alternatives would require surveys in a smaller area and a protect a smaller 

amount of habitat around newly discovered sites than Alternative D. 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. 

Alternative B, Sub-alternative B, and Alternative D require surveys prior to habitat-disturbing activities 

and site protection for newly-discovered sites for the North Coast DPS red tree vole. This site protection 

in these alternatives 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 million board feet per year, and in Alternative D by 4 million 

board feet per year. Red tree vole surveys and protection are required across the decision area in the No 

Action alternative under Survey and Manage protections and the potential reductions to the ASQ were not 

built into the vegetation modeling (Table 3-62). 

The alternatives vary in the protection of wilderness characteristics outside of designated Wilderness 

Areas. However, the alternatives do not include the protection of 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. 

The corridors of rivers that are suitable for Wild and Scenic River designation overlap the Harvest Land 

Base in all alternatives, but in widely varying amounts: 18 acres in the No Action alternative, 4,140 acres 

in Alternative A, 9,215 acres in Alternative B, 11,317 acres in Alternative C, and 8,595 acres in 

Alternative D. In all alternatives, the inner portion of each river corridor would be within the Riparian 

Reserves. Which river segments would be recommended for inclusion in the Wild and Scenic River 

system varies by alternative, and the degree to which management in the outer portion of the river 

corridor (outside of the Riparian Reserve) would conflict with Harvest Land Base management would 

vary by alternative. The calculation of the ASQ did not attempt to account for restrictions in timber 

harvest in the outer portion of the corridors of rivers that would be recommended for inclusion in the Wild 

and Scenic River System. These restrictions would likely reduce but not preclude sustained-yield timber 

harvest contribution from these areas. Therefore, potential restrictions on timber harvest in the outer 

portion of corridors of rivers that would be recommended for inclusion in the Wild and Scenic River 

System adds some uncertainty to the ASQ calculations. In Alternative A, there would be no potential 

restrictions on timber harvest, because none of the eligible river segments would be recommended for 

inclusion. In Alternatives B and D, the harvest practices may be reconciled with river corridor 

management by modifying the arrangement, location, and target level of retention trees. The greatest 

potential for restrictions on timber harvest in the river corridors would be in Alternative C, because of the 

greatest acreage of overlap with the Harvest Land Base and difficulty of reconciling clear-cutting in the 

HITA with river corridor management. Potential mitigation measures, such as adjusting timber harvest 
Chapter 3 - AE&EC – Forest Management

268 | Page

practices to include or increase retention levels in regeneration harvests in these overlapping areas could 

reduce or avoid this conflict. 

Visual Resource Management (VRM) areas in Alternatives C and D would identify areas of VRM II or 

VRM III within the Harvest Land Base, which may limit intensity of timber harvest. In Alternatives A 

and B, all lands in the Harvest Land Base would be managed as VRM IV, which would not limit the 

intensity of timber harvest. In the UTA in Alternative C or D or in the OHTA in Alternative D, timber 

harvest may be reconciled with visual resource management in areas managed as VRM II or VRM III. In 

the MITA in Alternative D, timber harvest may be reconciled with visual resource management in areas 

managed as VRM III. However, there may be restrictions on timber harvest in the HITA in Alternative C 

in areas managed as VRM II or VRM III and in the MITA in Alternative D in areas managed as VRM II

(Table 3-63). The calculation of the ASQ did not attempt to account for restrictions in timber harvest in 

these areas in Alternatives C and D. 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 some uncertainty to the ASQ calculations for Alternatives C and D. 

Table 3-63. 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. 

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 all alternatives in widely varying amounts: 168,968 acres in the No Action alternative, 29,065 

acres in Alternative A, 24,972 acres in Alternative B, 59,046 acres in Alternative C, and 86,693 acres in 

Alternative D. In these areas of overlap, the BLM would not preclude sustained yield timber harvest, but 

management for recreational values could condition or reduce it. The calculation of the ASQ did not 

attempt to account for restrictions in timber harvest in these areas. In some areas of overlap, timber 

harvest under the alternatives may be compatible with recreation management. Where incompatible, 

recreation management would restrict timber harvest, but not preclude it. 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, this potential restriction on 

timber harvest presents an unquantified level of uncertainty in the ASQ calculations for all alternatives. 

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. The quantified effects on the ASQ would be substantial for protection of future marbled 

murrelet sites in Alternative D, and the management of known and historic northern spotted owl sites in 

Sub-alternative B and Alternative D. Although the effect is quantified here, the potential restrictions 

related to future marbled murrelet sites in the No Action alternative, Alternative B, Sub-alternative B, and 

Alternatives C and D present uncertainty, and the effects on timber harvest are likely underestimated here. 
Chapter 3 – AE&EC – Forest Management

269 | Page

Unquantified 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 

protections and forest management within Adaptive Management Areas. Areas of overlapping 

designations could result in potential restrictions on timber harvest in some alternatives, most notably 

where the HITA in Alternative C would overlap with designations for Wild and Scenic Rivers, VRM II, 

VRM 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 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 Reserves and 

Riparian Reserves 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 million board feet 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 million board feet of non-ASQ timber annually, out of an average total timber volume sold 

of 201 million board feet. In 2011 and 2012, non-ASQ volume averaged 38 percent of total timber 

volume sold in the decision area (Figure 3-73). 
Chapter 3 - AE&EC – Forest Management

270 | Page

Figure 3-73. Total ASQ vs. Non-ASQ timber volume sold in the decision area between 1995 and 2012. 

In Figure 3-73, 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 (FRIS) data entered through 10-23-2014. Due to continual updates and data 

correction in FRIS, 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 million board feet per year during the 

first decade, while Alternative D would have the least, with 180 million board feet per year (Figure 3-74 

and Table 3-64).52 The No Action alternative would provide the most non-ASQ volume in the first 

decade, followed by Alternative B and Sub-alternative B. Alternatives A and D would provide the least 

non-ASQ volume. The amount of non-ASQ volume under the alternatives would be heavily influenced by 

management direction for reserve thinning and the forest conditions within the reserve. 

52 Both Figure 3-74 and Table 3-64 contain minor errors associated with rounding. 

0

50

100

150

200

250

300

1995 1997 1999 2001 2003 2005 2007 2009 2011

Timber Volume (Million Board Feet)

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
Chapter 3 – AE&EC – Forest Management

271 | Page

Figure 3-74. Total annual timber harvest for the first decade by alternative (MMbf), broken out between 

ASQ and non-ASQ sources. 

277 234 234 

120 

486 

332 

176 

122 

15 97 

98 

69 

67 

4 

0

100

200

300

400

500

600

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Timber Harvest (Million Board Feet) 

ASQ Non-ASQ

Chapter 3 – AE&EC – Forest Management

273 | Page

The non-ASQ timber volume under Alternative D would be very low (4 million board feet 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 million board feet 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 specify 

an age limit for determining treatment eligibility. Alternative B and Sub-alternative B limit timber harvest 

in Late-Successional Reserves in the moist forest to stands no more than 120-years-old. None of the other 

action alternatives would specify an age limit for silvicultural treatments in the reserve land use 

allocations in the moist forest. Instead, treatment eligibility for Reserves in the action alternatives 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 that alternative 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, the BLM assumed that management in the LateSuccessional Reserve in the dry forest would include stand density reductions, cultivation, release of large 

trees with old-growth characteristics, and introductions of heterogeneity into increasingly uniform stands. 

As described in more detail in the Fire and Fuels section, 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 LateSuccessional Reserves would not taper off to zero in any alternatives except the No Action alternative and 

Alternative D (Table 3-65). 

 
Chapter 3 - AE&EC – Forest Management

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Table 3-65. Annual non-ASQ timber harvest by decade: coastal/north vs. interior/south. 

Alternative 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 -

* This table has minor errors associated with rounding 

In summary, all alternatives would result in higher total harvest volumes in the first decade than the 

average annual timber sale volumes from the decision area since 1995. Although Sub-alternative B has 

the lowest ASQ volume out of any alternative, the total harvest volume would be 218 million board feet 

per year compared to 180 million board feet per year under Alternative D. Alternative C would have the 

highest total annual harvest in the first decade with 555 million board feet per year followed by the No 

Action alternative with 400 million board feet per year. 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 3-66). The BLM based these groupings on small end diameter inside bark 

from harvest tables, including taper assumptions by species group. 

Table 3-66. Log size groups by diameter class. 

Size Group Timber Diameter Class (Inches)

1 >20”

2 12” to 20”

3 8” to 11”

4 <8”
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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. However, the alternatives 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-yearsold. 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 (Table 3-67). 

Table 3-67. Percentage of total timber harvest volume by log size group; first 5 decades. 

Log 

Size 

Group 

No Action 

(% Harvest 

Volume) 

Alt. A 

(% Harvest 

Volume) 

Alt. B 

(% Harvest 

Volume) 

Sub. B 

(% Harvest 

Volume) 

Alt. C 

(% Harvest 

Volume) 

Sub. C 

(% Harvest 

Volume) 

Alt. D 

(% Harvest 

Volume) 

1 14% 10% 10% 9% 14% 5% 11% 

2 50% 52% 50% 48% 51% 47% 47% 

3 22% 23% 23% 24% 21% 28% 24% 

4 15% 16% 16% 18% 14% 20% 18% 

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: 

x Commercial thinning 

x Selection harvest 

x Variable-retention regeneration harvest 

x Clear-cutting 

x Salvage 

Non-commercial thinning in the Late-Successional Reserve in Alternative A would generally not include 

timber harvest, as the BLM would fell the timber and leave it on site. Non-commercial thinning it is not 

reported in the timber harvest categories, but it is included in the report on silvicultural treatments (Table 

3-68). Timber harvest implemented in the Late-Successional Reserve in the dry forest is categorized as 

selection harvest in the action alternatives, 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 MITA and LITA in Alternative B and Sub-alternative B, and regeneration 

harvest in the MITA in Alternative D. All timber harvesting in the UTA in all action alternatives and in 

the OHTA in Alternative D is in the selection harvest category, with the exception of salvage. 
Chapter 3 - AE&EC – Forest Management

276 | Page

The Woodstock model predicted the acreage of silvicultural treatments associated with timber harvest for 

each decade under each alternative. These silvicultural treatments include fuels reduction, site 

preparation, planting, stand maintenance and protection, pruning, stand conversion, pre-commercial 

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 

fertilization would be implemented under Alternative B, Sub-alternative B, and Alternative D, because of 

the forest management practices in those alternatives. Modeling assumptions about post-fire 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, except for 

the OHTA in Alternative D, the BLM assumed that timber salvage would occur after high- and moderateseverity fire events. In the OHTA 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. Alternative C is 

the only alternative in which the BLM modeled timber salvage volume from Reserves. The BLM did not 

simulate the occurrence of other natural disturbance 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 because of 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 3-68) 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 where it is the most similar. The levels of 

reforestation treatments have been directly affected by the timber harvest activities that the BLM 

implemented. The lack of anticipated regeneration harvest levels and the shift to commercial thinning 

reduced the extent of reforestation activities since 1995. 

Table 3-68. Average decadal silvicultural treatment accomplishment acres 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
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Alternative C would have the largest acreage of clear-cutting of any alternatives and the largest acreage of 

regeneration harvest overall. 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 (359 acres per year or less). Alternative C would have the largest 

salvage harvest acreage of all alternatives, in part because Alternative C would direct the salvage in the 

Late-Successional Reserve after natural disturbances to recover economic value (Figure 3-75). Since the 

BLM did not simulate the occurrence of other natural disturbances besides wildfire in the vegetation 

modeling, these salvage figures are likely an underestimate. 

Figure 3-75. Harvest acres per decade by harvest type and by alternative; 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 (Figures 3-76 and 3-77). For example, Alternative A would harvest the fewest total acres of 

all alternatives, but would harvest the fifth-highest timber volume out of the seven alternatives presented. 

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. 

42,200 

83,691 

58,454 

110,570 15,315 

71,700 59,369 

45,748 

73,013 

14,901

26,757 

68,580 

42,147 

45,403 34,063 

103,059 

43,932 

30,711 

17,379 

19,957

2,539 

884 (Salvage) 

2,642 

1,498 

3,587 

2,308 

1,640

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Harvest Per Decade (Acres) 

Clearcut Commercial Thinning Selection VRH Salvage
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278 | Page

Figure 3-76. Harvested timber volume (MMbf) per decade by harvest type and by alternative; 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. Total annual harvest acreage in the 

other alternatives is relatively comparable between the coastal/north and the interior/south (Figure 3-77). 

However, total harvested timber volume per year is substantially higher in the coastal/north area than the 

interior/south in all alternatives (Figure 3-78).

1,996

4,234

2,436 2,066

262

1,427 1,165

838

1,303

252

189

642

338

398

162

745

1,846

1,170

615

773

44

15 (Salvage)

34

13 (Salvage)

66

32

30

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

Timber Volume Per Decade (MMbf)

Clearcut Commercial Thinning Selection/Uneven-aged VRH (Two-aged) Salvage
Chapter 3 – AE&EC – Forest Management

279 | Page

Figure 3-77. Total timber harvest acreage per year; average of first two decades, broken out between 

coastal/north and interior/south areas. 

Figure 3-78. Total timber harvest volume (MMbf) per year; average of 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 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 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 highest acreage of most silvicultural treatments and Alternative D would 

have the least acreage (Table 3-69). 

9,332 

3,941 

8,035 

6,300 

9,230 9,295 

6,836 6,372 

4,575 

9,329 

5,739 

8,613 

7,489 7,120 

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

Timber Harvest Acres/Year 

Coastal/North Interior/South

230 

179 

218 

155 

391 

300 

123 

165 

67 

109 

58 

163 

93 

57 

0

50

100

150

200

250

300

350

400

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Timber Harvest Volume (MMbf/Year) 

Coastal/North Interior/South
Chapter 3 - AE&EC – Forest Management

280 | Page

Table 3-69. Treatment acreages per decade by alternative; average of 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)

Non-Commercial Thinning - 12,957 - - - - -

Under Burn 8,907 16,760 16,571 9,871 33,152 23,792 10,410

Hand Pile and Burn 24,734 23,309 35,349 21,950 45,751 36,590 25,822

Landing Pile and Burn 5,402 3,089 6,313 3,926 6,479 7,158 4,955

Machine Pile and Burn 14,780 7,429 13,353 9,874 17,907 17,197 10,313

Slash and Scatter 20,201 14,231 30,092 18,390 27,437 22,248 22,280

Mastication 3,010 4,669 3,902 2,129 10,664 7,488 2,352

Planting 55,999 57,223 44,750 27,154 117,004 82,669 38,064

Stand Maintenance and 

Protection 82,573 89,061 77,213 45,432 181,801 130,114 60,578

Pre-commercial Thinning 54,366 49,570 43,778 25,429 97,420 69,758 26,148

Fertilization 10,989 15,606 - - 19,139 36,222 -

Pruning 3,498 4,362 3,878 2,119 9,474 6,516 2,740

Stand Conversion 114 295 216 164 555 436 139

Totals 284,573 298,561 4,094 2,283 566,783 440,188 2,879

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 Alternative B. Alternative D would have the most 

acres of selection harvest followed by Alternative B. 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. Annual acreage 

of timber harvests is relatively comparable between the coastal/north and the interior/south areas in the 

alternatives, with the exception of the No Action alternative, Sub-alternative C, and Alternative B. 

However, total annual timber harvest is substantially higher in the coastal/north areas in all alternatives. 

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:53

x Category I- disturbance-associated special forest products- Christmas trees, wood products, some 

transplants (manzanita), some edibles and medicinals (huckleberries), some floral and greenery 

(beargrass), some seeds and seed cones (pine cones), and some mushrooms (morels) 

x Category II- disturbance-averse special forest products- some transplants (ferns), some edibles 

and medicinals (wild ginger), some floral and greenery (mosses), some seeds and seed cones 

(hemlock cones), some mushrooms (chanterelles), coniferous boughs, and burls 

53 These categories are not a formal designation and are simply labeled here for the purpose of analysis. 
Chapter 3 – AE&EC – Forest Management

281 | Page

The BLM assumed for the analysis that disturbances such as timber harvesting, prescribed fire, and 

wildfire would produce the conditions that would support Category I special forest products, and areas 

that did not experience these disturbances would support Category II special forest products. The BLM 

assumed that less intensive treatments such as pre-commercial thinning, fuel reduction, and fertilization, 

would have no effect on conditions for either category of special forest products. The more acres that 

would be disturbed by timber harvest, prescribed fire, and wildfire 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 that received no timber harvest, prescribed fire, or wildfire 

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. 

This analysis only addresses broad characterizations of the supply of special forest products. The BLM 

lacks information on the extent to which supply 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. 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 this scale of analysis to refine 

this analysis beyond the broad categories of special forest products and the broad characterizations of 

disturbance. 

Background 

Special forest products is a term used to describe some of the vegetative material found on public lands 

that can be harvested for recreation, personal use, or as a source of income. They include grasses, seeds, 

roots, bark, berries, mosses, greenery (e.g., fern fronds, salal, and huckleberry), edible mushrooms,

boughs, tree seedlings, transplants, poles, posts, and firewood. Trees or logs that contain saw timber are 

not considered SFP.

Management of special forest products (SFP) is an important component of resource management in 

Oregon/Washington BLM. SFPs are commonly referred to as “minor forest products” and are restricted to 

vegetative material. The SFP program benefits the Oregon/Washington BLM and the public in many 

ways. Some of these benefits are to contribute to the economic stability in local communities, provide 

critical cultural and subsistence benefits, support of a variety of cottage industries, form partnerships with 

groups concerned with the harvest of management of these products, and provide educational 

opportunities regarding the value of our natural, renewable resources. 

Commercial, personal, and incidental uses are distinct categories for public users on BLM-administered 

lands, although the boundaries between personal and incidental 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 high 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 a smaller spatial scale. Some personal use special 

forest products also require permits, such as Christmas trees and firewood. Incidental use includes 

collection and gathering of berries and mushrooms for immediate use and firewood for campfires. 

Although most commercial harvesters in the Pacific Northwest do not rely on special forest products for 
Chapter 3 - AE&EC – Forest Management

282 | Page

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 some types of personal use for special forest products may include 

restrictions to help meet ecological and renewable resource standards and to protect other sensitive 

resource values. Permits may restrict the type of species, quantity harvested, 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 Effects 

Currently, 11 percent of the forested lands in the coastal/north area are suitable for the collection of 

Category I special forest products, while 16 percent of forested lands in the interior/south area are 

currently available for collection of these products. Conversely, almost 89 percent of the coastal/north 

area and 84 percent of the interior/southern area are currently suitable for the collection of disturbanceaverse 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, the interior/south area would consistently have a higher proportion of the forested 

land available for the harvesting of Category I special forest products than the coastal/north area (Figures 

3-79 and 3-80).

Figure 3-79. Percentage of forested acres suitable for the collection of Category I special forest products;

coastal/north area. 

10%

12%

14%

16%

18%

20%

22%

24%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Coastal/North Cat 1 SFPs (%)

2013 2023 2033 2043 2053 2063
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283 | Page

Figure 3-80. Percentage of forested acres suitable for the collection of Category I special forest products; 

interior/south area. 

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 3-79). 

In the interior/south, Alternative B would have the largest acreage suitable for the collection of Category I 

special forest products, followed by Alternative C and Alternative D. As in the coastal/north, Alternative 

A would have the smallest acreage suitable 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 3-80). 

Conversely, the coastal/north would consistently have more acreage available for the collection of 

Category II special forest products. Regardless of alternative, decade, or region, the proportion of the 

forested area available for the collection of Category II special forest products would be above 75 percent 

of forested acres in the decision area (Figures 3-81 and 3-82). 

10%

12%

14%

16%

18%

20%

22%

24%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Interior/South Cat 1 SFPs (%) 

2013 2023 2033 2043 2053 2063
Chapter 3 - AE&EC – Forest Management

284 | Page

Figure 3-81. Percentage of forested acres suitable for the collection of Category II special forest products;

coastal/north area. 

Figure 3-82. Percentage of forested acres suitable for the collection of Category II special forest products;

interior/south area. 

In summary, the acreage of forests available for the harvesting of Category II (disturbance-averse) special 

forest products would remain abundant in all alternatives, 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 both prescribed fire and 

wildfire. Availability of these forest conditions in the coastal/north areas would be almost completely 

dependent on harvesting practices. Therefore, the alternatives that include the most 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 D. 

70%

75%

80%

85%

90%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Coastal/North Cat 2 SFPs (%)

2013 2023 2033 2043 2053 2063

70%

75%

80%

85%

90%

No Action Alt. A Alt. B Sub. B Alt. C Sub. C Alt. D

Interior/South Cat 2 SFPs (%)

2013 2023 2033 2043 2053 2063
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285 | Page

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USDA FS and USDI BLM. 2000. Final Supplemental Environmental Impact Statement for Amendment to the Survey & 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. 

 
Chapter 3 - AE&EC – Hydrology

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Hydrology 

Key Points 

x The BLM analyzed stream shading using two methods. By one method, all alternatives would 

avoid any measurable increases in stream temperature. The other method identified a small 

percentage of streams where forest management in the outer Riparian Reserve under Alternatives 

B and C would potentially affect stream temperature. 

x Less than 2 percent of the decision area would susceptible to peak flow increases over time under 

any alternative. The No Action alternative and Alternatives A and D 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 over time. 

x Less than 1 percent of the Harvest Land Base would be have susceptibility to landsliding with the 

potential to deliver sediment to streams over time under any alternative. Alternative C would 

have the highest acreage of regeneration harvest in areas with susceptibility to landsliding, and 

Alternative D would have the lowest acreage. 

x Under all alternatives, potential sediment delivery to streams from new road construction would 

constitute less than a one percent increase above current levels of fine sediment delivery from 

existing roads. 

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 fish-bearing and perennial 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 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 (see Background section). 

Each action alternative defines overall Riparian Reserve widths, divided into an inner zone and an outer 

zone. Management direction for the inner and outer zones addresses a variety of actions and varies by 

action alternative. This analysis assumed that the defined inner zone would be maintained unthinned and 

that restoration thinning would occur in outer zones under all action alternatives. In light of the 

differences in management direction for the outer zone, the analysis assumed that riparian restoration 

thinning would occur over a greater percentage of stands suitable for thinning and would thin stands to a 

lower density in Alternatives B and C than in Alternatives A and D. 

The No Action alternative defined interim Riparian Reserve widths that could be modified after 

watershed analysis. For this analysis, the BLM assumed that Riparian Reserves under the No Action 

would remain at the interim widths, two site-potential tree heights for fish-bearing streams and one sitepotential tree height for perennial streams. Under the No Action alternative, riparian thinning 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. 

Although not explicitly stated in the 1995 RMPs, this analysis assumed that an inner zone 60-foot width 

along each side of a stream would be retained unthinned under the No Action alternative because of 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 
Chapter 3 – AE&EC – Hydrology

287 | Page

gorges must be protected to prevent landsliding. This analysis assumed that where young forest stands in 

the Riparian Reserves are overstocked, thinning would occur in the outer portion of the Riparian Reserves 

for a variety of restoration objectives. 

In this analysis, the BLM used two different methodologies to evaluate stream shade. Method A 

determines the width of Riparian Reserves by empirical relationships necessary to provide 80 percent 

effective shade and relies upon previous work in the 2008 RMP/EIS (USDI BLM 2008). Effective shade 

is the percentage of sun blocking by topography, forest trees, and vegetation during a solar day. Effective 

shade reaches an upper limit in the 80 to 90 percent range for normally-stocked young to mature forest 

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, diminishing with blocking by topography 

and reflection or adsorption 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 

water body (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 forest stands, 

forest shade tends to reach a maximum near 80 percent effective shade, where increasing the width of the 

Riparian Reserve further only marginally improves effective shade. Gaps in forest vegetation as well as 

the quality of shade from needles, leaves, tree-branches and boles, even in mature forest 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 to a 60-foot width inner area and 

50 percent canopy closure zone to one site-potential tree height width54 (USDI BLM 2008, Appendix I –

Water, pp. 250-253) along each side of perennial and fish-bearing streams. Analytical conclusions 

determine the miles of perennial and fish-bearing streams that are not substantially similar by HUC 12 

watershed. Streamside forests reach a shade limit in the range of 60- to 100-feet width. Wider Riparian 

Reserves would provide no further shade benefit, because the solar path lengths through forest vegetation 

are sufficiently long, where direct beam 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 significantly 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 basis does not crosswalk with water quality studies and models to determine if temperature 

changes are occurring from before-after 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, presents a mechanistic modeling approach 

that uses the ODEQ shade model to develop shade loss tables for each alternative Riparian Reserve 

design. The rationale uses a beforeǦafterǦcontrolǦimpact design, where observed changes in stream 

 

54 Site-potential tree height generally varies from 140 to 240 feet width in the planning area. 
Chapter 3 - AE&EC – Hydrology

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temperature are due to the difference between pre-harvest and post-harvest monitoring (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 levels less than six percent 

shade loss would have no statistical effect on raising stream temperatures, the EPA has proposed an 

analytical threshold of no greater than three percent shade loss level, to allow for a factor of safety. In this 

analysis, shade loss levels greater than three percent would represent 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. 

BLM cross-walked shade density from the ODEQ shade model to canopy cover in the Woodstock model 

to provide a common attribute in addition to riparian area width to evaluate the alternatives using the EPA 

shade loss tables. The change is necessary because modeled canopy cover measures have removed treeto-tree overlap that influences canopy density and shade. Results from modeled canopy density 

underestimate field measured canopy cover. Fiala et al. (2006) found that modeled canopy cover is 

consistently lower when compared to field measurement 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 of canopy cover and reported that equations 

underestimated 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 3-83) between preharvest vegetation density (shown in the EPA shade loss tables) and 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). 

Figure 3-83. Canopy cover and angular canopy density in forest stands. 

In this analysis, the BLM and EPA calculated shade lost from the combination of the existing canopy 

density of the inner zone and the outer zone with an alternative’s management direction to retain a 

specific threshold of canopy cover (Table 3-70). In this analysis, the BLM and EPA divided fish-bearing 

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 (%)

Canopy Cover (%) (Organon)

Includes Effective Shade Calculated from Solar Pathfinder and Hemiview 

Photography. Data from Coos Bay, Roseburg and Medford Districts. N=12.
Chapter 3 – AE&EC – Hydrology

289 | Page

and perennial streams into 0.25-mile segments and then merged with the Woodstock model canopy cover 

by decade until 2063 for each alternative’s Riparian Reserve design. 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 fishbearing and perennial streams for each decade until 2063, and applied the outer zone canopy cover for 

purposes of reading the EPA shade loss tables. In this way, the BLM calculated the miles of fish-bearing 

and perennial streams that would exceed 3 percent shade loss until 2063 for each alternative. This is 

modification of the analytical methodology described in the Planning Criteria (USDI BLM 2014, pp. 73-

75). 

Table 3-70. 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 (EPA 2014). 

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 

Modeling design and constraints over a large plan area prevent 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 old-growth forest stands. The BLM and EPA 

calibrated Method B with tree heights for forest stands 50- to 70-years-old. Neither method considers 
Chapter 3 - AE&EC – Hydrology

290 | Page

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 set 

back 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 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 such a reduction in stream shading if the BLM were to thin the outer zone 

along certain streams. 

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 3-71. 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 and the difference is likely due to differences in the mapping methods of other

landowners. 

Table 3-71. Miles of streams with BLM ownership within the planning area. 

Stream Periodicity Planning Area Streams

(Miles)

BLM Streams

(Miles)

BLM Stream Miles

(Percent)

Perenniala 57,893 6,711 12%

Intermittentb 86,990 13,311 15%

Totals 144,884 20,023 14% a Perennial streams have varying but continuous discharge year round. Their base level is at, or below, the water table.

b 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). 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 to August, when clear sky days and solar 

radiation approach maximum levels. Direct solar radiation is the most important source of the energy 

budget affecting stream temperature gain at the water and streambed surfaces (Brown 1969, Beschta

1997, Moore and Wondzell 2005, Caissie 2006). During July to August, the sun’s altitude is high 

(following the second horizontal green line from the top), as only the portion of forest canopy to the south 
Chapter 3 – AE&EC – Hydrology

291 | Page

in line with the suns daily path is involved. Sun blocking by stream banks or hill slopes in the path of the 

sun as well as understory brush and forest 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 the 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 well-shaded because the tree-to-tree spacing is close and 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 among stream direction (azimuth), topography, 

tree height, and density in blocking solar radiation. The natural environment poses an array of 

possibilities in assessing the transmission of solar radiation to the stream. Shade-blocking forest 

vegetation involves duration and quality. 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 RMP/EIS provides additional detailed background information on the effects of riparian forests 

on stream shading and is incorporated here by reference (USDI BLM 2008, pp. 336-34; Appendix IWater, pp. 250-252). 

Affected Environment 

Proportions of riparian forests in the decision area by structural stage within 100-feet of fish-bearing and 

perennial streams are shown in Figure 3-84.

55

 

55 USDI BLM FEIS 2008 Ch. 3-341 
Chapter 3 - AE&EC – Hydrology

292 | Page

Figure 3-84. Proportions of riparian forests within 100-feet of fish-bearing and perennial streams in the 

decision area. 

More than half of the near-stream riparian forest is currently mature or structurally-complex conifer. 

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 

four percent. Some portion of the early-successional and stand establishment forest near streams has 

resulted from natural perturbations, such as wildfire, flood, or disease. Under the 1995 RMPs, the BLM 

has thinned in the Riparian Reserve in young forest stands along fish-bearing and perennial streams, but 

often has left a 50- to 60-foot unthinned zone along each side of the stream channel. 

Figure 3-85 shows the proportions of the current full width Riparian Reserve forest by structural stage 

that includes the 100-foot inner stream zone. 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 forests 

more than 100 feet to the edge of streams.56

56 This assumed that the No Data 8 percent area does not skew the current structural stage proportions. 

4%

41%

28%

27%

Stand Establishment

Young

Mature

Structurally-complex
Chapter 3 – AE&EC – Hydrology

293 | Page

Figure 3-85. Proportion of Riparian Reserve by structural stage. 

Monitoring results have documented a decrease in average maximum stream temperatures in the last 20 

years. Varying atmospheric conditions and antecedent precipitation result in substantial year-to-year 

variation in stream temperatures. However, as shown in Figure 3-86, average maximum summertime 

stream temperatures are clearly declining by as much as 4 °F in a coastal Oregon stream. Similar patterns 

are observed on other districts such as Roseburg shown in Figure 3-87. 

Figure 3-86. Seven day average maximum stream temperatures (°F) Vincent Creek Gaging Station, Coos 

Bay District, for years 1990-2013. 

1% 

17% 

27% 

22% 

25% 

8% 

Early-successional

Stand Establishment

Young

Mature

Structurally-complex

No Data

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

7-Day Average Maximum Stream 

Temperature, Fahrenheit 

Year 

Vincent Creek

Chapter 3 – AE&EC – Hydrology

295 | Page

Figure 3-88. Total acres of the Riparian Reserve by alternative compared to total acres of the Riparian 

Reserve along fish-bearing and perennial streams. 

There are 6,970 miles of fish-bearing and perennial streams, where forest management in the outer 

Riparian Reserve would potentially affect stream temperature. On fish-bearing and perennial streams, the 

outer management zone width varies from two site-potential tree heights under the No Action alternative 

(i.e., the entirety of the Riparian Reserve), between 120 feet and one site-potential tree height under 

Alternatives A and D, between 60 feet and one site-potential tree height under Alternative B, and between 

60 feet and 150 feet under Alternative C. 

Method A 

Alternatives A and D and Alternatives B and C would be very similar in shading effects and are grouped 

together for discussion. 

Alternatives A and D would maintain an unthinned 120-foot width inner zone. This 120-foot width would 

overlay the primary shade zone and the secondary shade zone plus an additional 20-foot retention. The 

inner zone alone would be sufficient to avoid reduction in stream shading under Method A. Nevertheless, 

Alternatives A and D also include an outer zone to one site-potential tree height in which any thinning 

would maintain at least 30 percent canopy cover and 60 trees per acre. The outer zone would provide a 

high protection to the inner zone for blowdown at the edge of the Riparian Reserve. 

Alternative B and C Riparian Reserve design involves an unthinned 60-foot width inner zone, which 

would match the primary shade zone. This is the minimum width found necessary to maintain high levels 

of shade quality, when taken together with an outer managed (secondary) zone to 100-feet with 50 

percent canopy cover. Alternatives B and C would maintain at least 50 percent canopy cover and 80 trees 

per acre in the outer zone, out 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 under Method A by 50 feet 

for Alternative C and an average of 80 feet for Alternative B. Therefore, Alternatives B and 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, 

938,467 

676,917 

382,805 372,739 

714,629 

594,115 

289,695 288,195 244,097 289,695 

0

200,000

400,000

600,000

800,000

1,000,000

No Action Alt. A Alt. B Alt. C Alt. D

Forest (Acres) 

Riparian Reserve Riparian Reserve-Fish-bearing and Perennial
Chapter 3 - AE&EC – Hydrology

296 | Page

there is an element of uncertainty related to stream shading under the No Action alternative compared to 

the action alternatives. As explained in analytical methods above, 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 a “no-thinning” inner zone, which 

makes the effects on stream shading less certain than under the action alternatives. 

In summary, all alternatives exceed Method A criteria for stream shading and are substantially similar in 

their ability to provide high quality shade and would avoid any measurable increases in stream 

temperature at this scale of analysis. 

Method B 

As in Method A, the results are clustered: No Action and Alternatives A and D would have similar effects 

on stream shading, and Alternatives B and C would have similar effects on stream shading (Figure 3-89). 

For the No Action alternative and Alternatives A and D, there would be three to 33 miles of fish-bearing 

and perennial streams that would currently be susceptible to shade reductions that could affect stream 

temperature if the BLM applies thinning in the outer zone of the Riparian Reserves. This is less than 0.5 

percent of the total fish-bearing and perennial stream miles as shown in Figure 3-90. 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. 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. This limited stream mileage 

susceptible to shade reductions would decline over time as the stands in the inner zone increase in canopy 

cover over time. The stream mileage susceptible to shade reductions would decline to almost zero in 20 

years under Alternatives A and D and in 30 years under the No Action alternative. 

Figure 3-89. Fish-bearing and perennial stream miles exceeding 3 percent shade loss. 

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
Chapter 3 – AE&EC – Hydrology

297 | Page

Figure 3-90. Fish-bearing and perennial stream miles in the decision area compared to fish-bearing and 

perennial stream miles exceeding 3 percent shade loss. 

For Alternatives B and C, there would be 275 to 372 miles of fish-bearing and perennial streams that 

would currently be susceptible to shade reductions that could affect stream temperature if the BLM 

applies thinning in the outer zone of the Riparian Reserves, amounting to approximately 5 percent of the 

total fish-bearing and perennial stream miles. The No Action alternative is very similar to Alternatives A 

and D, with the exception of a slight difference in the 2033 period. 

Using Method B, the shade loss thresholds are exceeded most frequently where the forest canopy density 

is < 60 percent in the 60-foot no harvest zone under Alternative B and C, and where the forest canopy 

density is < 40 percent in the 120-foot no harvest zone under Alternative A and D. If forest treatments do 

not occur in the outer zone in the relatively few miles of low canopy density forests under Alternatives B 

and C, then all alternatives would be substantially similar in their effect on stream shading. Even if the 

outer zone adjacent to inner zone with low canopy cover were to be thinned, not all of the susceptible 

reaches would be treated in a given year and as some reaches are treated other 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 in 

future decades. 

Method A and Method B yield generally similar results about the effects of the alternatives on stream 

shading, though they show some slight difference concerning Alternatives B and C. While all alternatives 

would be beneficial in maintaining shade quality along fish-bearing and perennial streams, the No Action 

alternative and Alternatives A and D would provide slightly better stream shading, in part as a result of 

wider inner zones for Alternatives A and D and management direction for forest management activities in 

the outer zone. However, the difference among the alternatives in areas that provide sufficient stream 

shading would be small when considered as a percentage of the total miles of fish-bearing and perennial 

streams on BLM-administered lands. 

6,970 30 30 

30 

33 33 

5 

4 

5 

4 4 

3 

3 

372 

372 

361 

361 

285 

285 

293 

293 

275 

275 

299 

299 

30 

33 

5 5 

4 

3 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

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
Chapter 3 - AE&EC – Hydrology

298 | Page

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 and 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 

associated activities alter the amount and timing of peak flows by changing site-level hydrologic 

processes (e.g., surface flow, sediment movement) (Keppeler and Ziemer 1990, LaMarche and 

Lettenmaier 1998, Wemple and Jones 2003, Wright et al. 1990). Grant et al. (2008) concluded that field 

reviews do not provide evidence that timber harvesting 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 3-91 for the planning area. Hydroregions in western Oregon distinguish predominant 

precipitation type during the winter months that generally correspond to elevation and latitude. Within the 

planning area, there are three hydroregions: rain, rain-on-snow (or transient snow zone), or snow 

hydroregions. The rain hydroregion is generally below 2,000 feet in elevation in the Coast Range. This 

hydroregion includes valleys up to 1,200-3,600 feet in elevation from north to south along the western 

Cascades, from the Columbia River to the California border. 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 it is centered along the 

Cascades crest. 

Chapter 3 - AE&EC – Hydrology

300 | Page

The BLM addressed effects on peak flows at the subwatershed level (Hydrologic Unit Code 12, 

previously termed “sixth-field” watershed).58 Subwatersheds are generally 10,000-40,000 acres in size 

and have a single outlet. The BLM selected the subwatershed scale for this analysis, because it better 

captures the BLM forested land pattern at closer to a site scale. The subwatershed scale is more sensitive 

to vegetation and runoff-related changes. In this analysis, the BLM addresses subwatersheds that meet the 

following three criteria: 

x BLM-administered lands are more than 1 percent of the subwatershed; 

x The subwatershed has more than 100 acres of BLM-administered lands in the rain-on-snow 

hydroregion; and 

x 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 forest harvest and roads for all lands in rainon-snow subwatersheds as a percent of the total subwatershed area by decade for the alternatives. The 

BLM then refined open area percentage by factoring harvest unit opening percentages based on treatment 

type in these rain-on-snow hydroregion and compared these to the response curve (Grant et al. 2008). 

Total open area in this analysis was comprised of—

x Early-successional structural stage from the Woodstock model for BLM-administered lands, 

x Early-successional forest from the Landscape, Ecology, Modeling, Mapping and Analysis 

(LEMMA) for non-BLM-administered lands 

x 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 rule set described in Step 3 in the Planning 

Criteria to calculate the early-successional forest on non-BLM-administered lands. Using the Landscape, 

Ecology, Modeling, Mapping, and Analysis (LEMMA) satellite imagery and vegetation classification the 

BLM identified new regeneration harvest areas on non-BLM-administered lands for the base period with 

available imagery, 1996 to 2006, for each identified rain-on-snow subwatershed. The BLM projected this 

rate of regeneration harvest forward in 10-year increments for 50 years. 

Third, the BLM added the acres of roads in rain-on-snow sub-watersheds to the acres of earlysuccessional 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. 

58 Hydrologic Unit Codes are a U.S Geological Survey classification based on a national standard to define systems 

through hierarchy. 
Chapter 3 – AE&EC – Hydrology

301 | Page

The BLM compared the total open area for each rain-on-snow subwatershed for each alternative and time 

period to the rain-on-snow response curve from Grant et al. (2008) that were constructed from data at the 

site scale (few to hundreds of acres). Response curves for the rain-on-snow hydroregion developed by 

Grant et al. (2008) 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 harvest, but 

also by the age and pattern of forest stands within a larger watershed, location, and extent of roads, area 

extent of riparian areas and 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. These studies have shown that peak flow increase from forest 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 to 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 already adjusted to a range of peak flows that is greater than a land use 

variation. 

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 inches 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 to 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 forest harvest (Figure 3-92), 

particularly within rain-on-snow watersheds (Grant et al. 2008). As the proportion of forest stand 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, but is 

also susceptible to elevated snowmelt rates compared to a forest (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 runoff into stream channels during storms 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 peakflows (Megahan and Kidd 

1972, LaMarche and Lettenmaier 2001, Luce 2002, Wemple and Jones 2003). 
Chapter 3 - AE&EC – Hydrology

302 | Page

Figure 3-92. 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 building. The 2008 RMP/EIS 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 3-93 shows the proportion of 

subwatersheds by hydroregions in the planning area. 

Figure 3-93. Proportions of hydroregions in the planning area. 

Gravel bed channel types with a 1 to 2 percent gradient are most likely to be affected for any detected 

peak flow increase from forest management and roads shown in Figure 3-94. 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 

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


Chapter 3 – AE&EC – Hydrology

305 | Page

all ownerships are analyzed together. All alternatives would increase the open area in recent harvest areas 

and roads through 2023 and decrease slowly until 2063, although a near constant 35,000 acres would 

continue to be susceptible to peak flow increases. Generally, Alternative B would have the highest peak 

flow susceptibility and Alternative D the lowest peak flow susceptibility through 2063. Less than 2 

percent of the entire decision area would exceed the Grant et al. (2008) screen that would be susceptible 

to a peak flow increase under any alternative through 2063. 

Figure 3-96. Subwatershed area (acres) on BLM susceptible to peak flow increases by decade by 

alternative. 

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

Acres 

Year 

No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 - AE&EC – Hydrology

306 | Page

Figure 3-97. Subwatershed area (acres) for all lands susceptible to peak flow increases by alternative. 

The affected harvest area on BLM-administered lands varies from 1,180 to 10,173 acres under any 

alternative and time period, which is less than 0.4 percent of the BLM-administered lands in the decision 

area and less than 1 percent of the Harvest Land Base under any alternative. 

Issue 3 

How would timber harvest affect the risk of landslides that would deliver to stream channels under the 

alternatives? 

Summary of Analytical Methods 

Shallow translational landslide 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 predict 

landslide occurrence. Instead, this analysis presents a depiction of risk and the effect of timber harvest 

under the alternatives on that risk. 

In this analysis, the BLM evaluated the risk of landslides by measuring relative landslide density using 

the geographic information system 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 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. 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. 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

2013 2023 2033 2043 2053 2063

Acres

Year

No Action Alt. A Alt. B Alt. C Alt. D
Chapter 3 – AE&EC – Hydrology

307 | Page

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 densities and size in the Coast Range were the 

highest for forest stands less than 10 years old, lower for mature forests, and lowest for forested areas 

between 10 to 100 years (Miller and Burnett 2007a, Robison et al. 1999). 

The BLM added forecasts of future timber harvest under each alternative to the NetMap model outputs. 

In this analysis, the BLM assumed that regeneration 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 regeneration 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 various regeneration 

harvest methods: clearcuts in the HITA in Alternatives A and C, and variable retention harvests in the 

Matrix and Adaptive Management Areas in No Action alternative, in the MITA and LITA in Alternative 

B, and in the MITA in Alternative D. It is possible that retention trees in variable retention harvests would 

reduce the effect of regeneration harvest on landslide risk compared to clearcuts. 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 from the 

Woodstock model outputs. The Vegetation Modeling section earlier in this chapter contains a discussion 

of the vegetation modeling. 

The BLM evaluated relative landslide density only within the Harvest Land Base under each alternative, 

because the BLM would implement regeneration harvest only within the Harvest Land Base. This is a 

change from the methodology described in the Planning Criteria and streamlines the analytical procedure 

to focus 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 regeneration harvests that the 

BLM has conducted within the past ten years. As described in the Forest Management section in this 

chapter, the BLM has conducted only a very small acreage of regeneration harvests in the past ten years. 

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 system as unsuitable for sustained yield 

timber production, such as low-productivity woodlands, unstable landforms, rock bands, talus slopes, 

meadows, and water-logged 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 timber production capability 

classification system, when examinations indicate that an area meets the criteria for reservation. 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 failure of the 

modeling to account for these areas would not alter the relative outcomes for the alternatives. 

In regeneration harvest areas under each alternative, 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 

three times the average of stands over 10 years old (Miller and Burnett 2007a). 

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. 
Chapter 3 - AE&EC – Hydrology

308 | Page

81). Roads do have the potential to increase landslide risk (Miller and Burnett 2007a, Weaver and Hagans 

1996). However, under all alternatives, 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 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 under the alternatives and provide basis for 

meaningful comparison of the effects of the alternatives. 

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 traversal 

proportion grid in NetMap to determine the top 80 percent of debris flow risk 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 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 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 rapid landsliding 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 lateral-horizontal 

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: from 30 to 70 percent of landslides deliver sediment and 

other material to streams (Miller and Burnett 2007a). A channelized debris flow (also called debris torrent 

or sluice-out) is a rapidly moving slurry of soil, rock, vegetation debris and water that can travel long 

distances from an initiation site through steeply confined mountain channels. Travel distance of stream 

debris flows depends upon slope gradient, valley width, and high angle tributary junctions encountered. 

As debris flows 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 flows lose energy and terminate at high angle stream tributary junctions and low 

gradient valley floors. 
Chapter 3 – AE&EC – Hydrology

309 | Page

Affected Environment and Environmental Effects 

Figure 3-98 shows the proportion of slopes that are greater than 70 percent by alternative in the Harvest 

Land Base. These steep slopes occur on 2.5 to 5.5 percent of the Harvest Land Base (14,000 to 42,000 

acres) among the alternatives. Not all steep slopes are at high risk of landslides, as discussed above under 

Analytical Methods and Background. 

Figure 3-98. Proportion of the Harvest Land Base with steep slopes, > 70%. 

The naturally occurring relative landslide density within the Harvest Land Base is similar among the 

alternatives, although not identical (Figure 3-99). The differences are a result of the alternatives 

allocating different portions of the decision area to the Harvest Land Base. Among all alternatives, almost 

half of the Harvest Land Base would have a relative landslide density of zero, meaning there would 

effectively be no risk of landslides. Alternative A would have a slightly higher percentage of the Harvest 

Land Base with a relative landslide density of zero, compared to the other alternatives. The alternatives 

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 RMP/EIS, 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 non-forest land use allocations have more than twice the area 

where modeled naturally occurring landslides exceed 1 per square mile (USDI BLM 2008, p. 349). 

2.41 

3.89 

4.31 

5.69 5.58 

0

1

2

3

4

5

6

No Action Alt. A Alt. B Alt. C Alt. D

Steep Slopes >70%, 

Percent of Harvest Land Base 
Chapter 3 - AE&EC – Hydrology

310 | Page

Figure 3-99. Cumulative area of naturally-occurring modeled landslide density within the Harvest Land 

Base by alternative, number/sq. mi.

Over 50 years, the average landslide density in the Harvest Land Base would increase by varying amounts 

among the alternatives. Alternative C would have the highest average landslide density among all 

alternatives, and Alternative A would have the least (Figure 3-100). However, Alternative A 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 C, the No Action alternative, and 

Alternative B would have less increase in average relative landslide density from the naturally occurring 

landslide density than Alternative A, but more than Alternative D. 

46.4 52.2 47.8 45.0 45.5

37.8

34.9 37.6 38.0 37.9

14.1 11.5 13.0 14.8 14.7

1.8 1.4 1.6 2.1 1.9

0

20

40

60

80

100

No Action Alt. A Alt. B Alt. C Alt. D

Naturally-Occurring Modeeled Landslide 

Density in Harvest Land Base, %

0/sq. mi. 0.01-0.25/sq. mi. >0.25 to <1/sq. mi. 1 - 5 sq. mi.
Chapter 3 – AE&EC – Hydrology

311 | Page

Figure 3-100. Relative landslide density in the Harvest Land Base compared to intrinsic potential at 

2013. 

The alternatives would vary in the amount of regeneration harvest, and consequently in the potential 

effect on landslide density. Over 50 years, Alternative A would implement regeneration harvest on the 

largest percentage of the Harvest Land Base at 11 percent, followed by Alternative C at 9 percent, the No 

Action alternative at 7 percent, Alternative B at 5 percent, and Alternative D at 3 percent. 

The differences in relative landslide density differences among the alternatives are a result of a 

combination of the naturally occurring relative landslide density that is included in the Harvest Land Base 

by alternative, and the amount and specific locations of regeneration harvest under each alterative. Within 

the Harvest Land Base, Alternatives C and D have approximately twice the acres of steep slopes (Figure 

3-98), compared to Alternatives A and B, and a corresponding higher natural relative landslide density. 

As noted under Analytical Methods, regeneration harvest under Alternatives B and D and the No Action 

alternative would retain live trees within the harvest units, in contrast to regeneration 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 one per square mile. The average relative landslide 

density differences among the alternatives in Figure 3-100 are slight and similar to what would naturally 

occur. Contrasted to regeneration harvest areas, a small percentage of young, mature, and structurallycomplex forested areas 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 3-100, Alternatives A, and B would have lower average landslide 

density with regeneration harvest than the naturally occurring landslide density of the 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 Timber Productivity 

Capability Classification. 

0.1

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/Mile2 

Year 

No Action Alt A Alt B Alt C Alt D
Chapter 3 - AE&EC – Hydrology

312 | Page

Under all alternatives, 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 

eight percent of the regeneration harvest areas under all alternatives (ranging from four 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 3-101 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 would be approximately one-half the acreage under the No 

Action alternative. The acres of channelized debris flow susceptibility by decade under Alternative D 

would be approximately one-quarter of the acreage under the No Action alternative. 

Figure 3-101. 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 

period, the susceptibility of landsliding would be increased compared to forests where basal area would 

be maintained. Under all alternatives 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 one percent (0.63 percent) of the Harvest Land Base. 

No Action

Alt. A

Alt. B

Alt. C

Alt. D

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
Chapter 3 – AE&EC – Hydrology

313 | Page

Issue 4 

How would new BLM road construction and road decommissioning under the alternatives affect 

disturbance and sources of fine sediment that may deliver to stream channels? 

Summary of Analytical Methods 

The analysis compares surface erosion from roads for existing roads and the projected new roads under 

each alternative. 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 large 

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) Manual 

(Dube et al. 2004). In this analysis, the BLM used the WARSEM methodology combined with BLM 

spatial 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 including winter haul. In this analysis, the BLM 

evaluated watersheds (approximately 60 to 300 mi2

) (USGS hydrologic unit code 10, which had 

previously been termed “fifth-field” watersheds). 

In this analysis, the BLM used projected timber volume by alternative and road ratios by harvest type 

described in the Planning Criteria (USDI BLM 2014, pp. 127-128, Tables 28-31) to determine miles of 

new temporary and permanent road construction for natural and aggregate surfaced road by forest 

treatment type. The BLM used these road ratios from analysis in the 2008 RMP/EIS and calculated 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) 

and the 2008 RMP/EIS 10-Year Scenario (USDI BLM 2008, Appendix I, Water, pp. 239-240). 

This analysis calculated potential fine sediment delivery (tons/year) from new temporary and permanent 

roads by alternative 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, 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 and 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. 

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, and 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 
Chapter 3 - AE&EC – Hydrology

314 | Page

floods. Sediment sources from roads are described in more detail in the 2008 RMP/EIS, 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). Newer roads built in the last 30 to 40 years typically use ridge top locations, 

full bench construction practices across steep slopes removing excess soil material to offsite waste areas, 

and manage drainage more effectively. In general, modern road construction practices produce less 

sediment delivered to streams 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 is 40 feet, with a range of zero 

to 639 feet. Sediment travel distances from roads are described in more detail in the 2008 RMP/EIS, 

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, distributed as 1,390 

miles paved (10 percent), 10,242 miles gravel surface (71 percent), and 2,698 miles 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 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 3-72 (USDI BLM 2008, p. 347, Table 3-71). The 

highest potential fine sediment yield is from natural surface roads, while the lowest potential fine 

sediment yield is from paved roads. 

Table 3-72. Potential fine sediment delivery from existing roads. 

Existing 

Roadsa

Roads Within Fine 

Sediment Delivery 

Distance (Miles)b

Potential Fine Sediment 

Delivery

(Tons/Year)c

Watershed Potential Fine 

Sediment Delivery

(Tons/Mile2/Year)c

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 a

 Includes BLM-controlled roads and private roads within the decision area from BLM GIS GTRN (roads) coverage. 

b

 Includes road segments within 200 feet of a stream channel where ditch flow, carrying fine sediment, could enter streams. 

c

 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 is a primary reason that BLM roads currently result in a 

minor portion of the total sediment delivery to streams from roads. In addition, the existing BLM road 

system has approximately 900 miles of road within the 200-foot sediment delivery distance not used or 

maintained, or decommissioned. The process of decommissioning includes the application of Best 

Management Practices, including blocking the road, out-sloping and adding waterbars for drainage 

control, applying erosion control and ensuring stream hydrologic conductivity, thereby reducing potential 

sediment delivery from roads. 
Chapter 3 – AE&EC – Hydrology

315 | Page

Forest management activities require Best Management Practices in designing and constructing 

permanent and temporary roads under all alternatives to maintain or improve water quality. The Best 

Management Practices include methods that either avoid or minimize the delivery of sediment to streams. 

Specific Best Management Practices have been developed for timber harvesting, road construction and 

maintenance, road decommissioning, energy and mineral development, fuel treatments, and other forest 

activities. Examples of the important Best Management Practices that involve road construction and use 

include are shown in Table 3-73 (Appendix I has a complete listing). 

Table 3-73. Best Management Practices for road and landing construction. 

Best Management Practice

Oregon Dept. of Forestry/ 

Oregon Administrative Rules59

Forest Roads - Division 625 

Locate temporary and permanent roads and landings on stable 

locations, e.g., ridge tops, stable benches, or flats, and gentle-tomoderate 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 

Affected Environment and Environmental Effects 

The 5,096 miles existing BLM-controlled roads within the 200-foot sediment delivery distance produce 

60,265 tons/year of potential fine sediment delivery. 

All alternatives 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 50 tons/year under Alternative D to 367 

tons/year under the No Action alternative, as shown in Figure 3-102. Under all alternatives, this increase 

would constitute less than one percent increase above current levels of fine sediment delivery from 

existing roads (note the logarithmic scale of Figure 3-102). Although the absolute values for increased 

potential fine sediment delivery through 2023 vary by alternative, these differences do not represent a 

substantial difference in the effects of the alternatives, because the increases in sediment delivery and the 

differences among the alternatives in future increases in sediment delivery are so small in comparison to 

the existing sediment delivery. 

 

59 BLM BMP’s are cross-walked to applicable Oregon Forest Practices and Oregon Administrative Rules. 
Chapter 3 - AE&EC – Hydrology

316 | Page

Figure 3-102. Potential fine sediment delivery to streams from new roads by 2023.60

This increase in potential fine sediment delivery would vary under the alternatives with the amount of 

new road construction within the sediment delivery distance as shown in Figure 3-103. Under all 

alternatives, fewer new roads would be located inside a 200-foot sediment delivery distance than in 

upslope areas , because many transportation routes that parallel streams within a sediment delivery 

distance to streams are existing, permanent roads. Under all alternatives, there would be an average of 

less than 1 percent increase in roads within a sediment delivery distance to streams channels, compared to 

an average 6 percent increase in upland areas outside a sediment delivery distance for planned permanent 

and temporary roads, as shown in Figure 3-103.

61

60 The vertical axis is logarithmic to view the range of data. 61 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. 

51,988

367

120

267 294

50

1

10

100

1,000

10,000

100,000

Existing

Roads

No Action Alt. A Alt. B Alt. C Alt. D

Potential Fine Sediment Delivery, 

Tons/Year
Chapter 3 – AE&EC – Hydrology

317 | Page

Figure 3-103. Projected newly constructed roads within a sediment delivery distance compared to newly 

constructed roads by 2023.62

Under all action alternatives, management direction in the inner zone of the Riparian Reserves would 

reduce the need for road construction in the sediment delivery distance and ensure that riparian forests 

maintain an effective sediment filtration area along streams. All action alternatives define a near-stream 

inner zone, in which the BLM would not thin stands. This inner zone would vary in width by stream type 

and by alternative, from 50 to 120 feet on either side of streams. New road locations would not be needed 

under any of the action alternatives to provide access for thinning riparian stands in the inner zone, and 

would therefore intrude into the 200-foot sediment delivery distance only where there would be no other 

reasonable routes to access upslope forest stands. Within the sediment delivery distance (200 feet), newly 

constructed roads would primarily be constructed to provide access for forest thinning within the Riparian 

Reserve. In the action alternatives, this thinning would be limited to the outer zone of the Riparian 

Reserve. Except for roads very near the stream channel or stream crossings (with connected ditches to the 

first upslope cross-drain), this unthinned, inner zone riparian forest near streams 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). Additionally, under Alternative A, no commercial thinning would be conducted within 

the Riparian Reserves in moist forests (inner or outer zone) and only for the purpose of fuels reduction in 

the dry forests (outer zone only), 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. As explained in analytical methods in 

the Fisheries section, 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 a “no-thinning” inner zone, which makes the estimation of road construction 

related to riparian thinning under the No Action alternative less certain than under the action alternatives. 

 

62 Includes permanent and temporary roads 

150 

947 

49 

310 

109 

687 

121 

754 

19 

136 

0

200

400

600

800

1,000

Constructed Roads (Miles) 

No Action Alt. A Alt. B Alt. C Alt. D

Inside Sediment Delivery Boundary Outside Sediment Delivery Boundary 
Chapter 3 - AE&EC – Hydrology

318 | Page

This greater uncertainty related to riparian thinning under the No Action alternative would result in 

greater uncertainty about the effectiveness of riparian forests in providing a sediment filtration area along 

streams. 

Under all alternatives, the BLM would decommission 372 miles of permanent road by 2023, bringing the 

total road 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 road bed. The BLM estimates that approximately one-quarter of the roads 

decommissioned would be “fully decommissioned,” which would typically reduce potential fine sediment 

delivery by 11 to 13 tons/mile/year, based on the data used to derive Table 3-72 in the Background 

section. 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 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. 

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Chapter 3 – AE&EC – Invasive Species

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Invasive Species 

Key Points 

x 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. 

x In the Coos Bay and Medford Districts, and the Klamath Falls Field Office, the overall relative 

risk for the introduction and spread of invasive aquatic species would be lowest under Alternative 

D and highest under the No Action alternative and Alternative C. 

x In the Eugene, Roseburg, and Salem Districts, the overall relative risk for the introduction and 

spread of invasive aquatic species would be lowest under Alternatives A and B and highest under 

Alternative C. 

x Sudden oak death infestations would occupy 100 percent of the Riparian Reserve in Infestation 

Zone 2 and almost 90 percent in Infestation Zone 3 by 2033 under Alternatives A and B. 

Issue 1 

How would alternatives affect invasive plant introduction and spread? 

Summary of Analytical Methods 

The BLM compared the relative risk of introducing and spreading invasive species resulting from the 

alternatives’ varied land use allocations and planned management activity levels, while 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 chosen species 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’ differing 

approaches to land use allocations (including off-highway vehicle designations), timber harvest levels, 

harvest methods, Riparian Reserve widths and direction, new road construction, and livestock grazing 

drives the variation in the effects on invasive species. 

The Planning Criteria provides detailed information on the invasive plant analysis and assumptions, 

which the BLM incorporates here by reference (USDI BLM 2014, pp. 90-98). 

The BLM measured the effects of timber harvest, road management activities, off-highway vehicle 

(OHV) use, and livestock grazing on the introduction and spread of invasive plant species in terms of 

susceptibility and risk at the scale of HUC 10 watersheds (formerly known as 5th-field watersheds). 

Susceptibility is the extent to which an area is vulnerable to the introduction and spread of invasive 

species; risk accounts for both susceptibility and the existing distribution and abundance of invasive 

species in a given area. The higher the susceptibility and the higher the distribution and abundance in a 

particular area the more at risk it is. Timber harvest, road management activities, and OHV use can create 

susceptibility for invasive plant species introduction and spread.

In this analysis, the BLM assumed that OHV users would operate vehicles consistent with BLM decisions 

about OHV use. Although the BLM has some site-specific and anecdotal information about illegal OHV 

use, the BLM does not have a basis for predicting the location or effects of any widespread or systematic 

illegal OHV use. In addition, much of the decision area has physical limitations to potential illegal OHV 

use, including dense vegetation, steep slopes, and locked gates. In most of the interior/south, the ability to 

track numerous different routes across the open spaces can lead to degradation and erosion in a greater 
Chapter 3 - AE&EC – Invasive Species

322 | Page

proportion than most of the coastal/north. However, the BLM lacks a basis for characterizing current 

illegal OHV use or forecasting such potential illegal OHV use in the future under any of the alternatives 

at this scale of 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: 

x Distribution and abundance of invasive plant species 

x Types of timber harvest and logging methods 

x Proximity of harvest activity to streams 

x Intensity and distribution of management activities 

x Designations for OHV use 

x Availability for livestock grazing 

The analysis assumed that actions on other ownerships and actions other than timber harvest, road 

management activities, OHV use, 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. 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. 

Determining Species Distribution Categories 

The BLM pooled representative invasive plant species occurrence data from BLM corporate datasets and 

iMapInvasives (OBIC 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. Invasive 

plant species distribution categories of Abundant, Limited, and Low are based on the known 

representative species’ distribution in the HUC 8 (4th-field) and HUC 10 (5th-field) watersheds, depending 

on the issue being analyzed: 

x Abundant – the representative invasive species reported from more than 25 percent of the 

square miles within the watershed 

x Limited – the representative invasive species reported from more than one percent and less 

than 25 percent of the square miles within the watershed 

x Low – the representative invasive species reported in no more than one percent of the square 

miles within the watershed 

HUC 10 watersheds 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 relatively more infestations 

within them. 

Figure 3-104 visually presents reported infestations of representative invasive plant species within the 

planning area. 

Chapter 3 - AE&EC – Invasive Species

324 | Page

soil, and aerial logging systems would disturb the least amount of soil. Logging methods are not 

generally prescribed in the draft alternatives; the BLM used logging method assumptions for this 

analysis that are based on assumptions developed for the 2008 RMP/EIS. 

The BLM determined the susceptibility of watersheds to invasive species introduction associated with 

timber harvest by analyzing the alternatives’ estimates of timber harvest volumes from the Woodstock 

vegetation model and the timber harvest type and harvest method coefficients developed for the 10-year 

scenarios in the 2008 RMP/EIS (Appendix C). The geographic arrangement of timber harvests is a 

modeling product and not a product of actual site-specific project planning. 

For each alternative, the BLM estimated the acres of timber harvest activities for HUC 10 watersheds in 

the planning area for the next 10 years using the harvest volumes generated from the Woodstock 

vegetation model. Each timber harvest type, based on their respective post-harvest light levels, received 

a relative weight of 1 or 5. Each logging method, based on their respective levels of soil disturbance 

received a relative weight of 1, 3, or 5. The BLM assumed the non-commercial restoration thinnings in 

the moist forests reserves under Alternative A 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 HUC 10 watersheds’ estimated acres for the timber harvest types and methods over the 

next 10 years allowed the BLM to generate combined timber harvest activity weighted value for each 

HUC 10 watershed. 

Dividing these combined timber harvest values into three groups of Low, Moderate, and High allowed 

the BLM to assign each HUC 10 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. HUC 10 

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 HUC 10 

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 BLM-administered lands, or no timber harvest activity susceptibility category in the 

first ten years do not have an assigned risk category. 

Assessing Risk of Invasive Plant Species Introduction and Spread 

into Riparian Habitats Associated with Riparian Reserve-Adjacent 

Timber Harvest and Thinning in Riparian Reserves 

The BLM assessed the susceptibility of invasive species introduction into riparian habitats associated with 

each alternative by considering the relative impact of the widths of Riparian Reserves, management 

direction within the Riparian Reserve, and levels of restoration 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 that the light levels of areas within 100 feet of timber harvest would increase and that the 

light levels farther than 100 feet from timber harvest would remain unaffected. 

The effects of Riparian Reserve-adjacent timber harvest activity on invasive species in riparian habitats 

over the next ten years were analyzed using spatial analysis to determine susceptibility values for 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 
Chapter 3 – AE&EC – Invasive Species

325 | Page

combination of factors below provides a range of HUC 10 watershed riparian susceptibility values and 

subsequent susceptibility categories of High, Moderate, and Low: 

x Light generated by timber harvest types 

x Soil disturbance from different timber harvest methods 

x Shade reduction in stands adjacent to timber harvest activities 

The BLM uses riparian susceptibility and species distribution categories to determine the risk by 

alternative of introducing invasive plant species into riparian habitats over the next 10 years. 

Probable restoration thinning acres in the outer zones of the Riparian Reserve from the Woodstock 

model’s pivot tables provide a basis to compare the susceptibility of introducing invasive plant species 

into riparian habitats through such restoration thinning across the alternatives over the next 10 years for 

each office. For the purposes of this analysis, the risk of introducing invasive plants into riparian habitats 

from restoration thinning activities matches the level of susceptibility. 

As described in Fisheries, there is an element of uncertainty related to riparian thinning under the No 

Action alternative compared to the action alternatives. 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 a “no-thinning” inner zone, which makes the 

implementation of riparian thinning less certain than under the action alternatives. 

Assessing Risk of Invasive Plant Species Introduction and Spread 

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. New infestations start when invasive plant species seed or vegetation hitchhike on road 

construction equipment to a project area. 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 by prorating each HUC 10 watershed with the road construction estimates for 

each alternative produced in the Trails and Travel Management section. These susceptibility values fall 

into relative susceptibility categories allowing the BLM to compare the susceptibility of the HUC 10 

watersheds to invasive plant species introduction and spread. The geographic arrangement of timber 

harvests is a modeling product and not a product of actual site-specific project planning so the actual 

location of new road construction is just an estimate. 

The BLM used the susceptibility categories and species distribution categories for the HUC 10 

watersheds to determine each alternative’s relative risk of invasive plant introduction associated with 

road construction. 

Assessing Risk of Invasive Plant Species Introduction and Spread 

Associated with Off-Highway Vehicle Use 

New infestations can start when invasive plants and seeds hitchhike to uninfested areas on OHVs. 
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Infestations associated with OHV use tend to spread along road and trail corridors. OHV use along 

roads and trails disturb soil, especially along new trials. The combination of disturbed soil conditions 

from OHV use and OHVs serving as inadvertent invasive plant vectors create susceptibility. 

The BLM assessed the susceptibility of BLM-administered lands in the planning area to invasive 

species introduction associated with OHV use by comparing each alternative’s acres of open, closed,

and limited OHV designations. The BLM assumed that areas designated as open to OHV use would be 

more susceptible to having new introductions of invasive plant species and infestation spread than areas 

designated as limited or closed to OHV use. The BLM assumed that all closures would be respected and 

that areas designated closed to OHV use would not be susceptible to new introductions and spread of 

invasive plant species associated with OHV use. 

The BLM assigned OHV designation weights to each part of the HUC 10 watershed having a different 

OHV designation under each alternative. OHV designation susceptibility weights are the following: 

x Open = 5 

x Limited = 3 

x Closed = 0 

For each alternative, 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 HUC 10 watersheds and then 

divided them into three categories: High, Medium, and Low. 

The BLM used the susceptibility weights and species distribution categories for the HUC 10 watersheds 

to determine each alternative’s relative risk of invasive plant introduction associated with OHV 

designation. 

Assessing Risk of Invasive Plant Species Introduction and Spread 

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 grazing under each alternative. Livestock grazing 

creates ground disturbance, which creates susceptibility for the introduction and spread of invasive plants. 

The BLM assumed invasive plants occur in the areas available for livestock grazing. Therefore, areas that 

the BLM determined would be susceptible for introduction and spread of invasive plants associated with 

livestock grazing would be at risk. Comparing each district’s acreage available for livestock grazing 

provides a relative assessment for the introduction and spread of invasive plants across the alternatives. 

Assessing Risk of Long-Term Introduction and Spread of Invasive 

Plant Species 

The analysis used a 10- to 20-year period after the first 10 years of implementation for the discussion 

of long-term effects of inadvertent introduction and spread of invasive plants because of BLM 

management activities across the planning area. The effectiveness of prevention practices, treatment 

effectiveness, and new introductions of invasive plants over time are too uncertain to allow for a useful 

analysis beyond 30 years. 

Over the long-term, the BLM assumed that the potential for the introduction and spread of invasive plant 

species would be higher in the Harvest Land Base than in the reserves under all alternatives. Although 

some restoration thinning would occur in reserves, the contribution of thinnings toward invasive plant 

introduction and spread would be less than the contribution from the sustained yield timber harvest in the 
Chapter 3 – AE&EC – Invasive Species

327 | Page

Harvest Land Base. 

The BLM determined the long-term risk for invasive species introduction into riparian habitats associated 

with timber harvest activities by considering the relative amount of Riparian Reserve under each 

alternative, the Riparian Reserve widths, and the management direction for timber harvest activities 

within 100 feet on either side of streams. 

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 

(online at www.imapinvasives.org). While this data is more robust then that available in 2008, the fact 

that there is no requirement for county, private, or corporate landowners to report invasive plant 

information still limits the data. 

Figures 3-105 and 3-106, and Table 3-74 show that the representative invasive plant species are common 

throughout the planning area and demonstrate the relative density of the reported infestations. 

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The BLM can reasonably conclude that invasive plants commonly occur throughout the planning area. 

Reported infestations of the representative invasive plant species are less than the total amount of all 

invasive plant species infestations occurring within the planning area, but provide a sense of how invasive 

species are distributed. Almost all of the HUC 10 watersheds currently fit the Limited or Abundant 

species distribution categories. Only one HUC 10 watershed fits the Low species distribution category 

and one HUC 10 had no reported sites. Neither of these watersheds contains BLM-administered lands. 

Environmental Effects 

This analysis examines timber harvest, road management activities, and OHV use for the potential to 

introduce and spread invasive plant species would result from the alternatives. 

Introduction of and Spread of Invasive Plant Species Associated 

with Timber Harvest

Figure 3-106 shows a comparison of the relative susceptibility associated timber harvest among HUC 

10 watersheds by alternative.


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Table 3-75. Risk comparison for the introduction and spread of invasive plant species associated with 

timber harvest in the HUC 10 watersheds across the alternatives over the next 10 years. 

Risk Ranking

No Action

(# of 

Watersheds)

Alt. A

(# of 

Watersheds)

Alt. B

(# of 

Watersheds)

Alt. C

(# of 

Watersheds)

Alt. D

(# of 

Watersheds)

Highest 42 30 30 52 26

High 33 43 56 46 57

Moderately High 11 12 16 11 11

Moderate 24 32 28 16 26

Moderately Low 33 19 26 19 26

Low - - - - -

Total at Risk 143 136 156 144 146

Total Not at Risk 132 139 119 131 129

Total Watersheds 275 275 275 275 275

Over the next 10 years, Alternative B would have the most HUC 10 watersheds at some level of risk 

(156) and Alternative A would have the least HUC 10 watersheds at some level of risk (136). Under 

all alternatives, between 50-60 percent 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. 

Intermediate levels of risk intensity associated with timber harvest in the HUC 10 watersheds over the 

next 10 years would occur under Alternatives D, B, and the No Action alternative as shown in Table 

3-75. Between 13-21 percent of the HUC 10 watersheds would experience moderate to moderately 

low risk of invasive plant species introduction associated with timber harvest activities over the next 

10 years. 

Invasive Plant Species Introduction into Riparian Habitats 

Associated With Riparian Reserve-adjacent Timber Harvest 

The Riparian Reserve is wide enough (i.e., more than 100 feet) to leave the riparian habitat light levels 

unchanged from adjacent timber harvest activities (including regeneration harvest where the Riparian 

Reserve is surrounded by Harvest Land Base and thinning where they are surrounded by LateSuccessional Reserves) under the following alternatives and stream types: 

x No Action alternative, Alternatives A and D – all streams 

x Alternative B – fish-bearing and perennial streams and debris-flow-prone, non-fish-bearing, 

intermittent streams 

x Alternative C – fish-bearing streams 

However, the shade levels associated with riparian habitats along the non-debris-flow-prone, non-fishbearing intermittent streams under Alternative B and non-fish-bearing streams under Alternative C 

would be more susceptible to increases in light levels associated with adjacent timber harvests because 

these reserves are narrower at 50 feet on either side of the streams. 

Figure 3-108 shows the susceptibility comparison for the introduction and spread of invasive plant 

species into riparian habitats associated with Riparian Reserve associated timber harvest activities of 

the next 10 years. 
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Figure 3-108. Susceptibility comparison for the introduction of invasive plant species into riparian 

habitats associated with Riparian Reserve-adjacent timber harvest activities over the next 10 years. 

Under Alternative C, 145 of the 260 HUC 10 watersheds in the planning area would be susceptible to 

invasive plant introduction into riparian habitats associated with Riparian Reserve-adjacent timber 

harvest activities over the next 10 years. Nine watersheds would have Moderate to High susceptibility. 

Under Alternative B, 150 HUC 10 watersheds would have a Low susceptibility and no watersheds 

would have Moderate to High susceptibility. Under the No Action alternative, and Alternatives A and 

D, there would be no susceptibility for invasive plant introductions into riparian habitats associated 

with Riparian Reserve-adjacent timber harvest activities. Under Alternatives B and C, no more than 58 

percent of the HUC 10 watersheds would be susceptible for invasive plant introductions into riparian 

habitats associated with Riparian Reserve-adjacent timber harvest activities over the next 10 years. 

Riparian Reserve-adjacent timber harvest activities would only generate susceptibility for the 

introduction and spread of invasive plants into riparian habitats under Alternatives C and B. 

Alternative C would have a slightly higher level of risk than Alternative B. 

The highest overall risk of the introduction of invasive plant species into riparian habitats that are 

associated with adjacent timber harvest activities over the next 10 years would occur under Alternatives C 

and B. Under Alternative C, nine of the HUC 10 watersheds would have relatively higher levels of risks 

than any other alternative. Under Alternative B, 150 at risk HUC 10 watersheds compared to 145 at risk 

HUC 10 watersheds under Alternative C and no HUC 10 watersheds at risk under the No Action 

alternative and Alternatives A and D. Figure 3-109 shows the risk to watersheds from the introduction of 

invasive plant species in riparian habitats. 

260 260 

110 115 

260 

150 136 

3 

6 

0

50

100

150

200

250

300

No Action Alt. A Alt. B Alt. C Alt. D

Number of Watersheds 

No Low Moderate High

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335 | Page

Table 3-76. Risk comparison for introduction of invasive plant species into riparian habitats associated 

with adjacent timber harvest in the HUC 10 watersheds across the alternatives over the next 1- years. 

Risk Ranking 

No Action 

(# of 

Watersheds) 

Alt. A 

(# of 

Watersheds) 

Alt. B 

(# of 

Watersheds) 

Alt. C 

(# of 

Watersheds) 

Alt. D 

(# of 

Watersheds) 

Highest - - - 6 - 

High - - - 3 - 

Moderate - - 102 91 - 

Moderately Low - - 48 45 - 

Total at Risk - - 150 145 - 

Total Not at Risk 260 260 110 115 260 

Total Watersheds 260 260 260 260 260 

Invasive Plant Species Introduction into Riparian Habitats 

Associated With Restoration Thinning 

Under all alternatives, restoration thinning activities would occur within the Riparian Reserve at 

varying levels in the next 10 years. Restoration thinning would be limited to outside of the inner zone 

of the Riparian Reserve under all action alternatives and could occur anywhere in the Riparian 

Reserves under the No Action alternative. 

Under Alternative D, the inner zone Riparian Reserve boundaries are greater than 100 feet from the 

streams and are broad enough to prevent thinning activities in the outer zone from reducing shade 

levels in riparian habitats. 

Under Alternative A, the restoration-thinning activities in the moist forests would include snag and 

coarse woody debris creation (no commercial thinning would be allowed). 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. Dry forest restoration-thinning activities to reduce fire hazards 

would create lower shade levels within 50 feet on either side of non-fish-bearing, intermittent streams. 

These dry forest restoration-thinning activities would alter the resulting shade levels and disturb the 

soil, making the riparian habitats more susceptible to the introduction and spread of invasive plants. 

The inner zone Riparian Reserve boundary is greater than 100 feet on all other types of streams, 

leaving the riparian habitats protected from restoration-thinning associated invasive plant infestation 

introductions. 

Under Alternatives B and C, the boundaries of the inner zone of the Riparian Reserve are the same 

widths and are less than 100 feet from either side of all streams. The Riparian Reserve restorationthinning activities would create susceptibility for the introduction of invasive plant species into 

riparian habitats over the next 10 years. 

Under the No Action alternative, there is no defined area excluding restoration-thinning activities 

within the Riparian Reserve, which leaves all riparian habitats susceptible to invasive plant 

introductions associated with restoration-thinning activities. 

With respect to restoration thinning in the Riparian Reserve, of all of the alternatives, Alternative D 

would have the lowest level of susceptibility for introducing invasive plants into riparian habitats. 

Alternative A would have the second lowest level of susceptibility for introducing invasive plants into 

riparian habitats and Alternatives B and C would have a moderate level of susceptibility. The No 
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336 | Page

Action alternative would have the highest level of susceptibility for the introduction of invasive plants 

into riparian habitats from restoration-thinning activities. 

Risk of invasive plant introductions into riparian habitats from restoration-thinning activities varies 

over the next 10 years between the alternatives based on their relative susceptibility. Probable 

restoration thinning acres for the outer zones of the Riparian Reserve over the next 10 years, 

generated by the Woodstock vegetation model provides the values used and the basis for determining 

susceptibility and risk for this part of the analysis. Restoration-thinning activities reduce shade levels 

and disturb the soil. Both of these changes in a project area would create opportunities for invasive 

species introductions to a project site and for resident infestations to flourish. 

Under the No Action alternative, more than 45,000 acres across the planning area would likely have 

restoration thinning activities over the next 10 years and a proportion of those acres could be within 

100 feet of streams. Areas with restoration-thinning activities within 100 feet of streams would be 

susceptible to and at risk for the introduction and spread of invasive plants in riparian habitats. 

Relative to the other alternatives, the risk of introducing invasive plants into riparian habitats from 

restoration-thinning activities is highest under the No Action alternative. 

Over the next 10 years, just over 7,000 acres of outer zone Riparian Reserve restoration thinning 

activities would likely occur under Alternative C and almost 16,000 acres in under Alternative B. With 

respect to restoration thinning activities in the Riparian Reserve under the different alternatives, 

Alternative C would have a moderate level of risk and Alternative B would have the second highest level 

of risk for introducing invasive plants into riparian habitats. 

Under Alternative A, only the dry forest restoration-thinning activities would generate susceptibility 

for introducing invasive plants into riparian habitats. Under this alternative, approximately 1,000 acres 

of thinning in the outer zone of the Riparian Reserve would occur over the next 10 years across BLMadministered lands within the planning area. Compared to the other alternatives, Alternative A would 

have the second lowest level of risk for introducing invasive plants into riparian habitats from outer 

zone restoration thinning activities over the next 10 years. Although there would be a few acres of 

outer zone restoration thinning under Alternative D, all of the activities would be too far away from 

riparian habitats for there to be any risk of introducing invasive plants into them. Under Alternative D, 

there would be no risk. 

Invasive Plant Species Introduction Associated with New Road 

Construction 

See Table 3-77 for the risk comparison for the introduction of invasive plant species into HUC 10 

watersheds resulting from new road construction activities among the alternatives. 
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Table 3-77. Risk comparison for the introduction of invasive plant species associated with new road 

construction by HUC 10 watershed over the next 10 years. 

Risk Ranking 

No Action 

(# of 

Watersheds) 

Alt. A 

(# of 

Watersheds) 

Alt. B 

(# of 

Watersheds) 

Alt. C 

(# of 

Watersheds) 

Alt. D 

(# of 

Watersheds) 

Highest 41 10 34 33 7 

High 37 40 40 45 43 

Moderately High 18 13 17 13 11 

Moderate 22 51 32 25 50 

Moderately Low 25 31 34 29 35 

Low - - - - - 

Total at Risk 143 145 157 145 146 

Total Not at Risk 132 130 118 130 129 

Total Watersheds 275 275 275 275 275 

Under Alternative B, 157 HUC 10 watersheds would experience risk of introduction of invasive plant 

species associated with new roads in the next 10 years compared to the remaining alternatives that would 

have between 143 and 146 watersheds at risk of introduction of invasive plant species associated with 

new roads in the next 10 years. Under the No Action alternative and Alternative C, 78 HUC 10 

watersheds would have the High to Highest relative risk rankings making them the alternatives with the 

most intensive level of relative risk of having new road construction related invasive plants introductions 

in the next 10 years. Under both, Alternatives A and D, the lowest amount of HUC 10 watersheds would 

have risk rankings in the High to Highest risk categories. 

Overall, the greatest relative risk of invasive plant species introduction associated with new road 

construction activities would occur under Alternative B compared to the other alternatives, and the lowest 

risk would occur under the Alternative D. There would be some watersheds in the Highest risk category 

under all alternatives, but the fewest under Alternative D. 

Invasive Plant Species Introduction Associated with Off-Highway 

Vehicle Use 

The relative differences in susceptibility to invasive plant introductions based on OHV designations is 

minor over much of the analysis area, because the topography and vegetation make most of the landscape 

non-conducive to cross-country vehicle travel, even by OHV. Only under the No Action alternative would 

areas be designated open for OHV use.

The number and distribution of areas, such as Areas of Critical Environmental Concern with OHV use 

restrictions and areas managed to protect their wilderness characteristics, creates the variation across 

alternatives in the risk results. Areas with open OHV designations under the No Action alternative also 

create some of this the variation in the risk analysis. 

Figure 3-110 shows a relative risk comparison between the alternatives for the introduction of invasive 

plant species into HUC 10 watersheds associated with the OHV designations. 


Chapter 3 - AE&EC – Invasive Species

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would occur under the Alternative A, because it would have the smallest Harvest Land Base among the 

alternatives. 

The long-term risk of the spread of invasive plant species along riparian habitats would be higher under 

the No Action alternative and Alternatives B and C than under Alternatives A and D because more 

watersheds would be at risk of initial invasion from a combination of restoration thinning and Riparian 

Reserve-adjacent timber harvest activities. Shade reducing activities within 100 feet of streams increases 

the light in riparian habitats enough to invigorate plant growth. Soil disturbance in these areas reduces 

plant competition and prepares soil for seed germination. Invasive plants already present in or introduced 

to disturbed areas would have a good chance of thriving. Under all alternatives, the associated road 

construction and level of road use and maintenance expected to support the timber harvest activities 

would create risk for invasive plant introduction into riparian habitats over the long-term. 

Alternative C would have the highest long-term risk because it would have the most area within 100 feet 

of streams available for Riparian Reserve-adjacent timber harvest activities and for restoration thinning 

treatments. Under Alternative C, restoration thinning with commercial timber removal would occur as 

close as 60 feet on either side of fish-bearing streams and 50 feet on either side of non-fish-bearing 

streams. Timber harvest activities could also occur as close as 50 feet on either side of non-fish bearing 

streams. 

Alternative B would have the second highest long-term risk because the total Riparian Reserve width of 

50 feet along non-debris-flow prone, non-fish-bearing streams would permit Riparian Reserve-adjacent 

timber harvest activities within 100 feet of the streams. Alternative B would also permit restoration 

thinning within 100 feet of non-fish-bearing intermittent streams. 

The No Action alternative’s direction for restoration thinning within the Riparian Reserve is the least 

restrictive. The total Riparian Reserve widths are greater than 100 feet on either side of all streams under 

the No Action alternative. The long-term risk of introducing and spreading invasive plants in riparian 

habitats would be moderate under the No Action alternative. 

Under Alternative D, no effects to invasive species introduction into riparian habitats from timber harvest 

activities would occur because direction permits all timber harvest activities to occur more than 100 feet 

from all streams, too far from riparian habitats to have an impact on invasive plant introduction and 

spread. 

The No Action alternative would have a higher risk of invasive plant introductions and spread due to 

having area with open designations and fewer acres designated closed to OHV use. Of the action 

alternatives, the long-term risk of the spread of invasive plant species associated with OHV use would be 

highest under the Alternative A. The long-term risk of invasive plant species introduction and spread 

would be lowest under Alternative D because it has the fewest watersheds in the Moderately High to High 

risk categories for the introduction of invasive plants associated with OHV use. 

When the effects of all of the risk activities are considered, the overall potential for introduction and 

spread of invasive plants over the next ten years, and in the long term, would be lowest under Alternative 

D, intermediate under the No Action alternative and Alternative A, and highest under Alternatives B and 

C.

Table 3-79 shows a relative risk comparison between the alternatives, by analysis factor, for the 

introduction of invasive plant species over both the long- and short-term. 
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341 | Page

Table 3-79. Relative risk of long- and short-term introduction and spread of invasive plant species by 

analysis factor. 

Risk Analysis Factor No Action Alt. A Alt. B Alt. C Alt. D 

Number of highest and high risk HUC 

10 watersheds from timber harvest 

activities over the next 10 years 

Low Lowest High Highest Moderate 

Number of highest and high risk HUC 

10 watersheds for introduction into 

riparian habitats from timber harvest 

activities over the next 10 years 

None None None Highest None 

Relative risk of introducing invasive 

plants into riparian habitats associated 

with restoration thinning activities over 

the next 10 years 

Highest Low High Moderate None 

Number of HUC 10 watersheds 

assigned risk categories from new road 

construction associated with timber 

harvest activities over the next 10 years 

Low Moderate Highest Moderate Moderate 

Introduction into HUC 10 watersheds 

associated with OHV use (long- and 

short-term) 

Highest High High Moderate Low

Long-term introduction associated with 

timber harvest and associated activities High Lowest Moderately Low Highest Moderate 

Long-term introduction and spread 

along riparian habitats Moderate Low High Highest Lowest 

Overall Potential to Introduce and 

Spread Invasive Plant Species. 

Moderately 

Low Low High Highest Lowest 

Issue 2 

How would alternatives affect invasive aquatic species introduction and spread? 

Summary of Analytical Methods 

The BLM designed the analysis to compare the relative risk of introducing and spreading aquatic invasive 

species resulting from the relative differences in human activity levels in the different RMA designations 

and in timber harvest-related new road construction under the alternatives while taking into consideration 

the collective distribution of a representative set of aquatic invasive plant species. Variation of the effects 

between the alternatives results from the differences in RMA designations, the area available to livestock 

grazing, the levels of timber harvest associated new road construction over the next 10 years and over the 

long-term. The Planning Criteria provides detailed information on the invasive plant analysis and 

assumptions, which the BLM incorporates here by reference (USDI BLM 2014, pp. 90-98). 

Representative Species 

The following are the representative aquatic invasive species that the BLM selected to characterize the 

general condition of aquatic invasive species on BLM-administered lands within the planning area: 

x American bullfrog (Rana catesbeinana) 

x Asiatic clam (Corbicula fluminea) 

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Risk of Introduction 

The factors considered in the analysis of the relative levels of risk for the introduction of invasive aquatic 

species on the BLM-administered lands include: 

x Distribution and abundance of invasive aquatic species 

x Levels of timber harvest-associated new road construction over the next 10 years 

x Designations for RMAs 

x Proximity of RMA designations to streams and water bodies 

x Area available to livestock grazing 

The relative risk of introducing and spreading invasive aquatic species would vary by alternative. This 

analysis compares the effects road construction, recreation use and grazing on the introduction and spread 

of invasive aquatic species in terms of susceptibility and risk. The only part of the analysis focused solely 

on the short term is the new road construction assessment over the next 10 years. The BLM considered 

these risk factors in conjunction with the distribution of invasive aquatic species to assess relative risk of 

introducing invasive aquatic species between the alternatives. 

The analysis assumed that actions on other ownerships and actions, other than those listed above, would 

continue to contribute to aquatic invasive plant species introduction and spread at current levels. These 

other actions include BLM management of special forest products, right-of-way agreements, road 

maintenance, and fuels on BLM-administered lands. Any future changes in the contribution from these 

other activities to the risk of introduction and spread of invasive aquatic 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. 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. 

Assessing Risk of Invasive Aquatic Species Introduction 

Associated with New Road Construction 

Road construction and associated road management activities contribute to the introduction of new 

infestations and the spread of existing invasive aquatic species infestations. New infestations start when 

invasive aquatic species hitchhike on road construction equipment and materials from one contaminated 

aquatic system to another. In addition, disturbance and modification of riparian habitats by way of road 

construction creates better habitat conditions for some invasive aquatic species. Modification of stream 

crossings disturbs soil and opens up forest canopies. 

Over the long-term, the BLM assumed that the majority of the BLM’s new road construction would 

occur in the Harvest Land Base to facilitate timber harvest activities. Restoration thinning in Reserves 

and the need for new roads associated with these harvests, would taper off over time. In the Harvest 

Land Base, new roads would facilitate the timber harvest activities into the future without decline. 

This analysis used levels of new road construction associated with timber harvest activities over the 

next 10 years to compare the relative risk of invasive aquatic species introduction associated with 

road construction across the alternatives. 

The BLM determined the susceptibility of sub-basins (HUC 8) to invasive species introduction 

associated with timber harvest associated new road construction by analyzing the alternatives’ estimates 

of road construction from the Woodstock vegetation model and the coefficients developed for the 10-

year scenarios in the 2008 RMP/EIS (Appendix C). The geographic arrangement of timber harvests is a 
Chapter 3 - AE&EC – Invasive Species

344 | Page

modeling product and not a product of actual site-specific project planning. 

The BLM prorated the road construction estimates for the subbasins in the planning area for each 

alternative across. The BLM used levels of new road construction associated with timber harvest 

activities under each alternative 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 plant species introduction and spread. 

Both the susceptibility of a sub-basin to invasion due to timber harvest-associated road construction in 

the next 10 years and the presence of invasive aquatic species determine the risk of invasion. 

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 relatively more abundant and 

susceptibility would be relatively higher. Subbasins without a risk category meet at least one of the 

following conditions: no reported sites for the representative sample set of invasive aquatic species in 

the analysis and no BLM-administered lands in the sub-basin. 

Assessing Risk of Invasive Aquatic Species Introduction 

Associated with Recreation Management Area Designations 

Visitors to recreation areas could introduce invasive aquatic species to new locations in a number of 

different ways. Sometimes people deliberately release aquatic pets they no longer want in areas with easy 

access to water. Aquatic invasive species introductions occur when invasive organisms drop into in new 

aquatic environments after they have hitchhiked on recreational equipment from infested waters. 

The relative levels of human activity in the different Recreation Management Area (RMA) designations 

would create varying levels of opportunity for introducing invasive aquatic species into new locations. 

Visitor use and concentration would be higher and more concentrated in Special Recreation Management 

Areas (SRMAs) than in Extensive Recreation Management Areas (ERMAs) and the lowest in areas 

outside of designated RMAs. The analytical assumption is that, with increased visitor use and activity, 

there would be a corresponding increase in the chance of introducing infestations. As a result, this 

analysis assumed that SRMAs would be more susceptible to having new introductions of invasive aquatic 

species and infestation spread than ERMAs and both would be more susceptible than areas with no RMA 

designation. 

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. ERMAs, 

under the No Action alternative would include lands not managed for recreation use. The BLM would not 

put these lands under a RMA designation under the action alternatives. Because the RMA designation 

definitions differ between the No Action alternative and the action alternatives, the relative ranking 

analysis can only be used for the action alternatives. 

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. Susceptibility values for each sub-basin 

result from multiplying the acres of each type of RMA by the relative weight for each alternative. The 

BLM organized the susceptibility categories into relative susceptibility categories of High, Medium, and 

Low. 

The BLM determined the risk for invasive aquatic species introduction associated with RMA 

designations by considering both the susceptibility of a sub-basin to invasion from recreation in RMA 

designations and the presence of invasive aquatic species. Subbasins with a low distribution of 
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invasive aquatic species and low susceptibility would have the lowest risk of invasion. The greatest 

risk of invasion would be subbasins where both invasive aquatic species are relatively abundant and 

susceptibility would be high. Sub-basins without a risk category meet at least one of the following 

conditions: no reported sites for the representative sample set of invasive aquatic species in the 

analysis and no BLM-administered lands in the sub-basin. 

The BLM compared the number of sub-basins in the relative risk categories to determine the relative 

risk from each alternative of introducing and spreading invasive aquatic species into the planning area 

associated with RMA designations. 

Assessing Risk of Invasive Aquatic Species Introduction and 

Spread Associated with Livestock Grazing 

The BLM assessed the risk of invasive aquatic species introduction associated with livestock grazing by 

comparing the amount of land available for grazing in each alternative by BLM office. Livestock grazing 

creates opportunities for livestock and livestock management associated equipment to move through 

streams and other aquatic environments, which creates susceptibility for the introduction and spread of 

invasive plants. Areas within grazing allotments are available for issuance of grazing leases/permits and 

by extension are susceptible to the introduction and spread of invasive aquatic species associated with 

livestock grazing. 

The BLM assumed invasive aquatic species occur in the areas available for livestock grazing. In addition, 

livestock and livestock management equipment and supplies coming from other geographic areas could 

have invasive aquatic species hitchhikers. Therefore, the BLM assumed that areas susceptible for 

introduction and spread of invasive aquatic species associated with livestock grazing would be at risk. 

Comparing each offices’s acreage available for livestock grazing provides a relative assessment for the 

risk of introduction and spread of invasive aquatic species due to this activity across the alternatives. 

Background

Aquatic invasive 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 mud snails, ringed crayfish, bullfrogs, and bluegill. Other priority aquatic invasive 

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 looking at the following representative species, all of 

which occur within the planning area. 

American Bullfrog 

American bullfrogs (Lithobates catebeinus) 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 

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 at least two miles 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). 
Chapter 3 - AE&EC – Invasive Species

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American bullfrog occurs on Roseburg District BLM-administered land (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. Only one individual 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 does have some 

limits on its life history requirements that limit its ability to spread including intolerance to high 

temperatures, low pH and low calcium (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 restoration equipment, and through the 

transfer of infested water (Foster et al. 2014). 

Asiatic clam occurs and within the administrative boundaries of the Coos Bay, Eugene, Roseburg, and 

Salem Districts. 

New Zealand Mudsnail 

The New Zealand mudsnail (Potamopyrgus antipodarum), a clonal mollusk species, thrives in disturbed 

fresh and brackish waters in a broad spectrum of aquatic conditions. This habitat generalist spreads very 

easily, likes to burrow in sediment, and grows healthy 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 fast-moving streams. 

Sources for New Zealand mudsnail introductions into new locations include passage through fish 

digestive tracts; contaminated fishing, sporting, and in-stream restoration 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 be a biofouler of facilities drawing infested waters. New Zealand mudsnail 

populations can become very dense and out compete 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. 

Nutria 

Humans 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). Today nutria remains 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 to slow moving water bodies like marshes, wetlands, ponds, rivers. Dense 
Chapter 3 – AE&EC – Invasive Species

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populations of nutria modify riparian ecosystems by overgrazing riparian vegetation and building 

numerous burrows. The burrows also weaken fabricated structures like roadbeds and dikes. Intolerance to 

freezing temperatures is the primary factor limiting nutria spread in Oregon (ODFW 2014). 

Yellow Flag Iris 

Yellow flag iris (Iris pseudacorus) is a tall and showy invasive perennial wetland species introduced to 

North America for multiple purposes including: gardening, erosion control, and 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 but does not tolerate long periods of freezing 

temperatures (Ramey 2001). 

The popular water garden species escapes from gardens, erosion prevention plantings, and sewage 

treatment plants. Although yellow flag iris is a quarantined species in Oregon, avid water gardeners can 

easily obtain yellow flag iris in nurseries and from plant dealers over the internet. Gardeners often share 

yellow flag iris rhizomes in trades with other gardeners because it is beautiful and easy to grow. Similar 

to other invasive plants, yellow flag iris can be introduced to new locations when it hitches a ride on 

ground disturbing equipment. 

Once introduced, yellow flag iris expands 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 aggressive native plants like 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 

Because there is no requirement for county, private, or corporate landowners to report invasive aquatic 

species occurrences, an accurate accounting of the distribution of invasive species are still unavailable. 

Despite the limited reporting on invasive aquatic species occurrences, 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 (online at 

http://nas.er.usgs.gov/) and iMapInvasives (online at www.imapinvasives.org). Enough baseline 

occurrence data existing in iMapInvasives and the NAS – Nonindigenous Aquatic species database allow 

for an analysis of aquatic invasive species among alternatives using the HUC 8 watersheds as the basic 

analysis unit. 

The representative aquatic invasive generally have the following distribution in the planning area: 

x American bullfrog occurs in numerous widespread locations across western Oregon 

x Asiatic clam occurs within the administrative boundaries of the Coos Bay, Eugene, Roseburg, 

and Salem Districts 

x New Zealand mudsnail infestations are reported across the planning area 

x Nutria are well established throughout the planning area 

x Yellow flag iris has limited to widespread distribution in western Oregon and occupies BLMadministered lands in the Coos Bay, Eugene, and Medford Districts 


Chapter 3 - AE&EC – Invasive Species

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The No Action alternative has the greatest susceptibility because it has the most sub-basins in the highest 

susceptibility ranking and would have 35 sub-basins with some level of susceptibility that is associated 

with new road construction for timber harvest over the next 10 years. Alternative C would have the least 

susceptibility to the introduction and spread of aquatic invasive species, with 28 sub-basins having some 

level of susceptibility and all of those sub-basin susceptibility rankings would be Moderate to Low. 

Alternative B would be the second highest in susceptibility, Alternative A would be intermediate, and 

Alternative D second to the least susceptible. 

The four subbasins in the highest susceptibility category under the No Action alternative are located in the 

Coast Range and include lands administered by the Eugene, Roseburg, Coos Bay, and Medford Districts. 

The Umpqua sub-basin in the Roseburg and Coos Bay Districts would be the only sub-basin in the High 

susceptibility category under Alternative B. Under Alternatives, A, C and D there would be no subbasins 

in the High susceptibility category. 

See Table 3-80 for the risk comparison for the introduction and spread of invasive aquatic species into 

subbasins resulting from new road construction activities among the alternatives. 

Table 3-80. Risk comparison for the introduction and spread of invasive aquatic species associated with 

new road construction by subbasins over the next t10 years. 

Risk Category

No Action

(# of 

Watersheds)

Alt. A

(# of 

Watersheds)

Alt. B

(# of 

Watersheds)

Alt. C

(# of 

Watersheds)

Alt. D

(# of 

Watersheds)

High 1 0 0 0 0

Moderately High 7 1 6 6 2

Moderate 1 0 3 3 0

Moderately Low 13 16 14 13 13

Low 7 13 7 8 13

Total at Risk 29 30 30 30 28

The greatest relative risk of invasive aquatic species introduction and spread associated with new road 

construction activities over the next 10 years would occur under the No Action alternative compared to 

the other alternatives, and the lowest risk would occur under Alternative D. Only one sub-basin (Eugene 

District) would be in the High risk category under the No Action alternative and all sub-basins would be 

at or below the Moderately-High risk category for the other alternatives. 

Figure 3-114 displays the risk of invasive aquatic species introduction and spread by sub-basin, 

resulting from timber harvest associated new road construction over the next 10 years. The highest risk 

would occur under the No Action alternative, and the lowest risk would occur under Alternative D. 

Alternatives B and C would generate an intermediate level of risk compared to the other alternatives. 

The next lowest level of relative risk would occur under Alternative A. 




Chapter 3 – AE&EC – Invasive Species

355 | Page

aquatic species would be higher under alternatives with more area in the Harvest Land Base due to greater 

long-term road construction in that allocation. 

The least risk of invasive aquatic species introduction and spread associated with new road construction 

over the long term would occur under Alternative A and the great risk, under Alternative C. After 

restoration thinnings in the Reserves taper off, the BLM would require fewer new roads to support timber 

harvest activities in the relatively smaller Harvest Land Base under Alternative A, compared to the other 

alternatives. The most new roads would be required under Alternative C, because it has the most dispersed 

and largest Harvest Land Base of all of the alternatives. 

The BLM expects the 10-year impacts of RMAs to continue as described above over the long-term. The 

long-term risk of invasive aquatic species introduction and spread in the SRMAs and ERMAs would be 

consistently higher than in the surrounding areas because of the higher level of human activity. Among the 

action alternatives, Alternative D would have the highest long-term risk and Alternative A would have the 

least number of subbasins in the Moderate to High risk categories for the introduction and of invasive 

aquatic species associated with recreation use. 

The effects of grazing under the alternatives would continue as described above. Over the long-term, the 

amount of land available to livestock grazing would be greatest under the No Action alternative and so 

would the associated risk of introducing and spreading aquatic invasive species. Alternative D, with no 

acres available for livestock grazing, would have no risk of invasive aquatic species introductions and 

spread. 

The BLM assigned an overall risk ranking, by office, to each alternative based on the relative risks 

associated with all of the factors analyzed. For the Coos Bay and Medford Districts, and the Klamath Falls 

Field Office, the overall risk for the introduction and spread of invasive aquatic species would be highest 

under the No Action alternative and Alternative C, moderate under Alternatives A and B, and lowest 

under Alternative D. For the Eugene, Roseburg, and Salem Districts, the overall risk for the introduction 

and spread of invasive aquatic species would be highest under Alternative C, high under Alternative D, 

moderate under the No Action alternative and the lowest under Alternatives A and B. 

Table 3-82 shows a relative risk comparison between the alternatives, by analysis factor, for the 

introduction of invasive aquatic species over both the long and short term.

 
Chapter 3 - AE&EC – Invasive Species

356 | Page

Table 3-82. Relative risk of long and short-term introduction and spread of invasive aquatic species by 

analysis factor. 

Risk Analysis Factor No Action Alt. A Alt. B Alt. C Alt. D

Number of Moderately High and High Risk 

subbasins from timber harvest associated 

new road construction over the next 10

years

Highest Low Moderate Moderate Lowest

Number of subbasins assigned risk 

categories from new road construction 

associated with timber harvest activities 

over the next 10 years.

Moderate Most Most Most Fewest

Number of High and Moderately High risk 

subbasins from recreation use levels 

associated with recreation management area 

designations

Lowest Low High Highest

Area available for livestock grazing Highest Moderate Moderate Moderate None

Overall relative risk for the introduction and 

spread invasive aquatic species (Coos Bay,

Medford, Klamath Falls)

High Moderate Moderate High Low

Overall relative risk for the introduction and 

spread invasive aquatic species. (Eugene,

Roseburg, and Salem)

Moderate Lowest Lowest Highest High

All alternatives include management direction to “prevent, detect, and rapidly control new invasive 

aquatic species infestations.” This management direction is general, as is appropriate to the scope 

and scale of this action. Across alternatives, the BLM may 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 may include, but are not 

limited to, the following: 

x 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 

x Use sterile road building materials and weed-free straw and mulch 

x Use native plant species to promote competitive exclusion of invasive plant species 

x Retain native plant communities in and around riparian and aquatic habitats and minimize soil 

disturbance, consistent with project objectives 

Issue 3 

How would alternatives affect sudden oak death introduction and spread? 

Summary of Analytical Methods 

The BLM designed the analysis to project the rate of sudden oak death infestation expansion for the 

periods of 2013-2023 and 2023-2033 considering the different management strategies under the 

alternatives. The analysis shows the relative differences in the expected rate of sudden oak death 

infestation expansion resulting from the BLM not treating infestations, treating them only outside of the 

Riparian Reserve as defined under Alternative B, and treating all infested areas. The Planning Criteria 
Chapter 3 – AE&EC – Invasive Species

357 | Page

provides detailed information on the sudden oak death analysis and assumptions, which the BLM 

incorporates here by reference (USDI BLM 2014, pp. 101-104). 

This analysis examines different Phytophtora ramorum treatment strategies to compare how sudden oak 

death introduction and spread would result from the alternatives. 

The effects of where sudden oak death treatments would occur on BLM-administered lands is measured 

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. 

The factors that were considered in the analysis relative to the projected sudden oak death infestation 

levels and spread over the next 10-20 years include: 

x BLM’s Phytophtora ramorum treatment strategy by alternative: treat all infestations under the No 

Action alternative and Alternatives C and D; no treatments under Alternative A; and treat all 

infestations outside of the Riparian Reserve under Alternative B 

x Sudden oak death projected infestation zones for the next 10-20 years 

The natural 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. 

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. Under Alternative B, 

there would be no sudden oak death treatments within the Riparian Reserve. 

The technical experts added assumptions to facilitate the analysis after the Planning Criteria was 

developed. These include: 

x The acres treated on BLM-administered lands in the period 2001-2013 represent the infested area 

for the same period 

x The area treated expands at the same rate on BLM-administered land in the second and third 

decades as it did between 2001 and 2013 

x 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 

x All infestations on other ownerships would be treated 
Chapter 3 - AE&EC – Invasive Species

358 | Page

The analysis does not account for the following: 

x Regrowth of vegetation on sites that were treated and replanted or naturally re-vegetated 

x Variation in abundance of tanoak across the landscape 

x 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 industry. 

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. However, the European and North American mating types are not the same, 

which indicates 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 land. The original quarantine area covered 9 square miles (Goheen et 

al. 2006). By 2013, despite aggressive coordinated education, prevention, and early detection and 

treatment efforts the quarantine area expanded to 264 square miles from natural spread of the disease. 

Phytophthora ramorum travels long distances via nursery stock and infected wood of some host species. 

For that reason, the pathogen is subject to both State (ORS 603-052-1230) and Federal (7 CFR 301.92)

quarantine regulations that restricts 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, log, and lumber of 

identified host species. Many of these species are native trees and shrubs found in forests managed by the 

BLM, 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 ultimately penetrate and infect 

new hosts. The spores travel in water where some 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 other 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 
Chapter 3 – AE&EC – Invasive Species

359 | Page

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 when pathologists first became aware of its presence in Curry 

County. 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 uses an integrated pest management approach to control all detected Sudden Oak 

Death infestations. Treatments include cutting, piling, and applying herbicides to host species within 300 

feet of infected trees. Treatments often include broadcast or pile burning of cut material. Pathologists 

from the Oregon Department of Forestry and the U.S. Forest Service perform follow-up surveys until the 

area has been determined to be disease-free for 2 successive years. If the disease is still present, the area is 

retreated. The Coos Bay District plants treatment areas with Douglas-fir within 2 years of treatment. 

Affected Environment 

In 2001, Oregon had several infection centers in close proximity to one another on private residential, 

industrial forestland and on BLM-administered land. The original quarantine area covered 9 square miles 

(Goheen et al. 2006). By 2013, despite aggressive coordinated education, prevention, and early detection 

and treatment efforts the quarantine area expanded to 264 square miles from natural spread of the disease. 

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 with known sites. 

Sudden oak death infestation Zone 1 represents the broader infested area over the period of 2001 through 

2013 (Figure 3-117). 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. 

Chapter 3 – AE&EC – Invasive Species

361 | Page

amount of sudden oak death infestation intensification and increase in infested acres would occur under 

the No Action alternative, and Alternatives C and D, because the BLM would treat all detected 

infestations. The infestation would still increase under this aggressive treatment strategy as it has over the 

past 10 years. Spore loads would have less opportunity than under other alternatives to increase and 

spread to new hosts due to rapid response treatments by the Coos Bay District. By the end of the first 

decade, the infestation would have increased in both Zones 1 and 2 and would total over 2,700 acres. By 

the end of the second decade, the infestation would have entered Zone 3 and the cumulative total for all 

zones would exceed 5,200 acres or 22 percent of BLM-administered lands in Curry County (Table 3-83). 

Table 3-83. Sudden oak death infestations levels by infestation zone over the next 10 and 20 years across 

the alternatives. 

Infestation Zone (Time Frame) Alt. A Alt. B No Action, Alt. C and D 

Zone 1 (2014 – 2023) 10,013 4,440 1,858 

Zone 2 (2014 – 2023) 4,893 2,111 878 

Zone 3 (2014 – 2023) 305 39 - 

Zone 1 (2024 – 2033) 10,013 5,874 2,877 

Zone 2 (2024 – 2033) 8,143 3,978 1,755 

Zone 3 (2024 – 2033) 3,050 1,429 639 

A higher level of infestation intensification and increase in infested acres would occur under Alternative 

B. Under this alternative, no treatments would occur within the Riparian Reserve, but treatments would 

occur on all detected infestations outside of the Riparian Reserve. Sudden oak death would spread and 

intensify from the untreated areas in the Riparian Reserve. 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, and 

Alternatives C and D. By the end of the first decade, the infestation would have increased in Zone 1 and 

entered Zones 2 and 3. Cumulatively the infestation would cover almost 6,600 acres. By the end of the 

second decade, the infestation would have increased in all zones with a cumulative total infestation 

covering almost 11,300 acres or 47 percent of BLM-administered lands in the cumulative three-zone area. 

Under Alternative A, the Coos Bay District would not treat sudden oak death infestations, which would 

allow for the most intense and largest levels of infestations on BLM-administered lands. Left untreated, 

infected trees would produce and release spores over several years. No sudden oak death treatments 

would allow for rapid and uncontrolled infestation intensification on BLM administered lands. The 

highest levels of tanoak mortality would occur under Alternative A. 

Under Alternative A, 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 ownership within 

the quarantine area and a quarter of the remaining BLM ownership within Zone 2. Sudden oak death 

infestations would occupy 5 percent (more than 300 acres) of the BLM ownership in Zone 3 within the 

first 10 years. 

Sudden oak death would infest 87 percent (21,200 acres) of BLM-administered lands in the cumulative 

three-zone area by the end of the second decade under Alternative A. 

Decadal initial sudden oak death treatments under Alternative B would be almost two times higher than 

the expected treatment levels under the No Action and Alternatives C and D over the next 10 years and 

one and a half times greater in the second 10 years (Table 3-84). 
Chapter 3 - AE&EC – Invasive Species

362 | Page

Table 3-84. Initial sudden oak death treatment levels over the next 10 and 20 years. 

Sudden Oak Death Decadal Treatment Periods No Action, Alt. C and D

(Acres)

Alt A 

(Acres)

Alt B

(Acres)

Initial treatments for 2014 – 2023 1,777 - 3,292

Initial treatments for 2014 – 2023 2,536 - 3,854

Cumulative Treatments 4,313 - 7,146

Comparing the expected sudden oak death infestation increase within the Riparian Reserve and over all 

BLM-administered lands within the decadal infestation zones reveals the relative differences in effects 

across the different treatment strategies with respect to treatments in the Riparian Reserve. 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 Zone 3 by 2033 compared to 31 percent in Zone 2 and 34 percent 

in Zone 3 under the other alternatives. Under the No Action alternative and Alternatives C and D, the 

Riparian Reserve in Zone 3 would still be free of infestations by 2023. 

References 

Adams, M. J., C. A. Pearl, and R .B. Bury. 2003. Indirect facilitation of an anuran invasion by non-native fishes. Ecology Letters 

6(4): 343-351. 

Benson, A. J., R. M. Kipp, J. Larson, and A. Fusaro. 2014. Potamopyrgus antipodarum. USGS Nonindigenous Aquatic Species 

Database, Gainesville, FL. 

Crayon, J. J., U.S. Geological Survey, Western Ecological Research Center, Department of Biology, University of California, 

Riverside, CA, and IUCN/SSC Invasive Species Specialist Group (ISSG). 2009. 

http://issg.org/database/species/ecology.asp?si=80&fr=1&sts=sss&lang=EN. 

Foster, A. M., P. Fuller, A. Benson, S. Constant, D. Raikow, J. Larson, and A. Fusaro. 2014. Corbicula fluminea. USGS 

Nonindigenous Aquatic Species Database, Gainesville, FL. http://nas.er.usgs.gov/queries/FactSheet.aspx?speciesID=92. 

Frankel, S. J., and K. M. Palmieri. 2014. Sudden Oak Death, Phytophthora ramorum: a persistent threat to oaks and other tree 

species. International Oaks 25: 43-56. http://www.fs.fed.us/psw/publications/frankel/psw_2014_frankel001.pdf. 

Fuller, T. E., K. L. Pope, D. T. Ashton, and H. H. Welsh. 2011. Linking the distribution of an invasive amphibian (Rana 

catesbeiana) to habitat conditions in a managed river system in northern California. Restoration Ecology 19(201): 204-213. 

http://onlinelibrary.wiley.com/doi/10.1111/j.1526-100X.2010.00708.x/full. 

Goheen, E., E. Hansen, A. Kanaskie, N. Osterbauer, J. Parke, J. Pscheidt, and G. Chastagner. 2006. Sudden Oak Death and 

Phytophthora ramorum: a guide for forest managers, christmas tree growers, and forest tree nursery operators in Oregon and 

Washington. Oregon State University Extension Service, EM8877. 16 pp. 

Kramer-Wilt, E. 2008. Aquatic invasion ecology. Fall 2008. http://depts.washington.edu/oldenlab/wordpress/wpcontent/uploads/2013/02/Corbicula-fluminea_Kramer-Wilt.pdf. 

Oregon Biodiversity Information Center (OBIC). 2013. Cooperative data sharing agreement, iMapInvasives data, between the 

Oregon Biodiversity Information Center and USDI BLM, Oregon State Office. Portland State University. 4 pp. 

ODFW. 2006. Oregon Conservation Strategy. Salem, OR. 

---. 2014. Nutria. Living with wildlife (webpage). http://www.dfw.state.or.us/wildlife/living_with/nutria.asp. 

Oregon Sea Grant. 2010. New Zealand mudsnails: how to prevent the spread of New Zealand mudsnails through field gear. 

Brochure. 8 pp. http://seagrant.oregonstate.edu/sgpubs/onlinepubs/g10001.pdf. 

Ramey, V.. 2001. Center for Aquatic and Invasive Plants. University of Florida. http://plants.ifas.ufl.edu/node/205. 

USDA Animal and Plant Health Inspection Service (APHIS). 2013. APHIS expands Phytophthora ramorum quarantine area in 

Curry County, OR. DA-2013-36. 

---. 2014. Program Update. APHIS Phytophthora ramorum Program 2014, 2nd Quarter Summary. 

USDI BLM. 2008. Final Environmental Impact Statement for the Revision of the Resource Management Plans of the Western 

Oregon Bureau of Land Management Districts. Bureau of Land Management, Oregon State Office, Portland, OR. 

---. 2013. Resource Management Plans for Western Oregon: Analysis of the Management Situation. USDI BLM, 

Oregon/Washington State Office, Portland, OR. 

---. 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. 

Václavík, T., A. Kanaskie, E. M. Hansen, J. L. Ohmann, R. K. Meentemeyer. 2010. Predicting potential and actual distribution of

sudden oak death in Oregon: prioritizing landscape contexts for early detection and eradication of disease outbreaks. Forest 

Ecology and Management 260(6): 1026-1035. 

http://www.fs.fed.us/psw/publications/sod/vaclavik.2010.predictingDistributionSOD_Oregon.pdf. 

Washington Department of Fish and Wildlife. 2006. Living with wildlife: nutria. 7 pp. http://wdfw.wa.gov/living/nutria.pdf. 
Chapter 3 – AE&EC – Invasive Species

363 | Page

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. Oregon State University. 71 pp. 

 
Chapter 3 - AE&EC – Lands and Realty

364 | Page

Lands and Realty 

Key Points 

x Under all alternatives, BLM-administered lands are generally available for right-of-ways. Action 

Alternative D would most constrain the BLM’s ability to grant right-of-ways. 

Issue 1 

How would the alternatives affect land tenure in western Oregon? 

Summary of Analytical Methods 

The BLM identified how many acres in each alternative would be included in each land tenure zone and 

considered the probable impact of this on the BLM’s land holdings in western Oregon given recent trends 

in land acquisition, exchange, and disposal. 

Background 

Through RMP-level decisions, the BLM places all of the lands the BLM administers into one of 

following three land tenure zones: 

x Lands in Zone 1 are retained under BLM administration 

x Lands in Zone 2 are available for exchange to enhance public resource values, improve 

management capabilities, or reduce the potential for land use conflict 

x Lands in Zone 3 are available for disposal using appropriate disposal mechanisms 

Across the action alternatives, the BLM used the following criteria to determine land tenure zones 

(Appendix J):

x Zone 1 lands would include: 

o National Landscape Conservation System designated lands 

o Areas of Critical Environmental Concern 

o Lands acquired with Land and Water Conservation Funds 

x Zone 2 lands would include all BLM-administered lands not listed in the descriptions of both 

Zone 1 and Zone 3 lands. 

x 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 suitable 

for disposal 
Chapter 3 – AE&EC – Lands and Realty

365 | Page

Affected Environment 

Under the 1995 RMPs, the BLM has acquired 8,962 acres of lands by purchase, which encompasses 0.36 

percent of lands within the planning area. Ongoing land acquisition projects include the Sandy 

River/Oregon National Historical Trail (Salem District). 

The majority of BLM-administered lands within the planning area are currently within Zone 2 (suitable 

for exchange). Current land tenure acreages are presented with the alternatives in Table 3-85. Under the 

1995 RMPs, the BLM has made only limited use of land exchanges (acres acquired 22,390; acres 

disposed 7,367). Federal legislation, rather than discretionary agency action, directed most land 

exchanges and transfer activities within the planning area. 

There are 18,266 acres (approximately 0.7 percent of the total decision area acres) of BLM-administered 

land within the planning area designated as Zone 3 (suitable for disposal). Under the 1995 RMPs, the 

BLM has sold 3,798 acres of Zone 3 lands. 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 J. 

Environmental Effects 

Only the arrangement and acreage of Areas of Critical Environmental Concern cause the acreages in the 

land tenure zones to vary between alternatives. 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 are reflected in Zone 2). Zone 3 acreage does 

not adjust per alternative (Table 3-85). 

Table 3-85. Proposed land tenure zone acres by alternative. 

Land Tenure Zone No Action 

(Acres) 

Alt. A 

(Acres) 

Alt. B 

(Acres) 

Alt. C 

(Acres) 

Alt. D 

(Acres) 

Zone 1 – Lands Suitable for Retention 188,249 199,582 193,019 191,696 199,376 

Zone 2 – Lands Suitable for Exchange 2,287,140 2,275,807 2,282,370 2,283,693 2,276,013 

Zone 3 – Lands Suitable for Disposal 18,266 18,266 18,266 18,266 18,266 

The No Action alternative has the smallest acreage in Zone 1 (smallest acreage in ACECs) and the largest 

acreage in Zone 2. Alternative A has the largest acreage in Zone 1, with 11,333 more acres than the No 

Action alternative. This acreage difference accounts for approximately 0.45 percent of the total planning 

area. The minimal variation in acreage will have little effect on the BLM’s current ability to exchange 

lands. 

Issue 2 

How would the alternatives affect the availability of BLM-administered lands for right-of-ways in 

western Oregon? 

Summary of Analytical Methods

The BLM identified how many acres in each alternative would be designated as Right-Of-Way 

Avoidance and Exclusion Areas and considered how these designations would affect the availability of 

rights-of-way on BLM-administered lands in the western Oregon. 
Chapter 3 - AE&EC – Lands and Realty

366 | Page

Background 

Through RMP-level decisions, the BLM may identify certain BLM-administered lands as Right-of-Way 

Avoidance or Exclusion Areas. 

x Right-Of-Way Avoidance Areas – Areas with sensitive resource values where the BLM will 

strongly discourage right-of-ways and land use authorizations. The BLM will make 

authorizations in avoidance areas only when compatible with the purpose for which the area 

was designated and not be otherwise feasible outside the avoidance area. 

x Right-Of-Way Exclusion Areas – The BLM would not grant future right-of-ways except when 

mandated by law. 

Across the action alternatives, the BLM used the following criteria to identify BLM-administered lands 

that it would identify as Right-Of-Way Avoidance Areas: 

x Areas of Critical Environmental Concern 

x Recreation Management Areas 

x Wilderness Study Areas 

x Designated and Suitable Wild and Scenic Rivers classified as scenic and recreation rivers 

x Class II Visual Resource Management Areas 

Across the action alternatives, the BLM used the following criteria to identify BLM-administered lands 

that it would identify as Rights-Of-Way Exclusion Areas: 

x Lands designated as Wilderness 

x Lands managed for their wilderness characteristics 

x Designated and suitable Wild and Scenic Rivers classified as wild rivers 

x Class I Visual Resource Management areas 

The checkerboard land ownership pattern of the 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 Bureau receives an application. 

Currently, most right-of-ways the BLM grants over BLM-administered land in western Oregon are for 

access roads. In most cases, other linear right-of-ways (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 temporary use permits, 

including: 

x Apiary (beehive) sites 

x Agricultural cultivation of small areas 

x Residential encroachments or other structures pending their removal or long-term authorization 

x National Guard or military reserve training 

x Other miscellaneous short-term activities 

Chapter 3 - AE&EC – Lands and Realty

368 | Page

Pacific Connector Pipeline Project 

The Federal Energy Regulatory Commission released the Jordan Cove Energy and Pacific Connector 

Pipeline Project Draft EIS in November 2014 (Federal Energy Regulatory Commission 2014). 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 land in the Coos Bay, 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 Final Environmental Impact Statement is 

scheduled to be completed in 2015. 

Environmental Effects 

The analysis shows that Right-Of-Way Avoidance Area acres range from Alternative A with the least 

Avoidance Areas (179,436 acres) and Alternative D with the most Avoidance Acres (871,713 acres) 

(Table 3-86). While having fewer acres in Avoidance Areas than Alternative D, Alternative C would still 

have more than double the No Action alternative. Alternative A has fewer acres than the No Action 

alternative. The large acreage difference is primarily due to Recreation Management Areas where the 

range of acreage is from 8,217 acres to 666,862 acres. With this large acreage of Avoidance Areas, the 

BLM’s ability to grant right-of-ways under Alternative D, and to a slightly lesser degree under 

Alternative C, would be constrained relative to the current conditions. 

Table 3-86. Right-Of-Way Avoidance Areas by alternative. 

Avoidance Area Criteria No Action 

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

Areas of Critical Environmental Concern 94,657 105,990 99,427 98,104 105,784

Recreation Management Areas 8,217 18,543 164,141 416,616 666,862

Wilderness Study Areas 1,208 1,208 1,208 1,208 1,208

Designated and Suitable Wild and Scenic 

Rivers (Scenic and Recreation only) 20,414 20,414 27,557 27,557 64,083

Visual Resource Management Class II that is 

not Included in Right-Of-Way Exclusion 

Areas

123,756 48,185 48,958 48,999 58,309

Total Avoidance Acres* 243,928 179,436 326,510 575,444 871,713

* Right-of-way avoidance acreage is not a direct sum from 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 since Right-OfWay Exclusion is more restrictive than Right-Of-Way Avoidance. 

The No Action alternative would have the least acres in Right-Of-Way Exclusion Areas (42,382 acres) 

(Table 3-87). Alternative A would have the most acreage in Exclusion Areas (129,389). This acreage 

difference of 87,007 acres accounts for approximately 3.49 percent of the total planning area. The 

minimal variation in acreage for Right-Of-Way Exclusion Areas will have little effect on the BLM’s

ability to grant right-of-ways on BLM-administered land. 
Chapter 3 – AE&EC – Lands and Realty

369 | Page

Table 3-87. Right-Of-Way Exclusion Areas by alternative. 

Exclusion Area Criteria No Action 

(Acres) 

Alt. A 

(Acres) 

Alt. B 

(Acres) 

Alt. C 

(Acres) 

Alt. D 

(Acres) 

Lands Designated as Wilderness 14,309 14,309 14,309 14,309 14,309 

Lands Managed to Protect their Wilderness 

Characteristics - 88,029 50,706 50,706 - 

Designated and Suitable Wild and Scenic 

Rivers (Wild Only) 5,937 5,937 5,937 5,937 5,937 

Visual Resource Management Class I 22,136 21,114 21,114 21,114 21,114 

Totals 42,382 129,389 92,066 92,066 41,360 

 
Chapter 3 - AE&EC – Lands with Wilderness Characteristics

370 | Page

Lands with Wilderness Characteristics 

Key Points 

x Alternative A provides the greatest protection of identified Lands with Wilderness Characteristics 

within the decision area. 

x Alternatives B and C provides intermediate protection of Lands with Wilderness Characteristics

within the decision area. 

x Alternative D provides no protection of Lands with Wilderness Characteristics within the 

decision area. 

x Under all action alternatives, the BLM assumed that identified wilderness characteristics within 

the Harvest Land Base would degrade over time. 

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 

designated Wilderness Areas and existing Wilderness Study Areas (WSAs) within the planning area that 

could result under the alternatives. 

The BLM analyzed the extent to which each alternative 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 managed for wilderness 

characteristics under each alternative as well as considering the acres not managed for wilderness 

characteristics to which the BLM would apply management actions likely to degrade wilderness 

characteristics. 

The BLM assumed that where an alternative would manage an area for its wilderness characteristics these 

wilderness characteristics would persist for at least the duration of the RMP. The BLM also assumed that 

where an area was not managed for its wilderness characteristics, these wilderness characteristics would 

be lost over time. The BLM particularly considered instances where alternatives would prioritize another 

resource over wilderness characteristics. For example, in Alternatives B and D, the BLM does not manage 

for wilderness characteristics where doing so would be in conflict with proposed recreation or OHV 

designations. 

In this analysis, the BLM assumed that OHV users would operate vehicles consistent with BLM decisions 

about OHV use. Although the BLM has some site-specific and anecdotal information about illegal OHV 

use, the BLM does not have a basis for predicting the location or effects of any widespread or systematic 

illegal OHV use. In addition, much of the decision area has physical limitations to potential illegal OHV 

use, including dense vegetation, steep slopes, and locked gates. In most of the interior/south, the ability to 

track numerous different routes across the open spaces can lead to degradation and erosion in a greater 

proportion than most of the coastal/north. However, the BLM lacks a basis for characterizing current 

illegal OHV use or forecasting such potential illegal OHV use under any of the alternatives at this scale of 

analysis. 
Chapter 3 – AE&EC – Lands with Wilderness Characteristics

371 | Page

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). 

Analysis Assumptions 

x Where an alternative would manage an area for its wilderness characteristics these wilderness 

characteristics would persist for at least the duration of the RMP. 

x BLM-administered lands identified as having wilderness characteristics contain all wilderness 

characteristics (that is, all characteristics exist in the area: size, naturalness and outstanding 

opportunities for solitude or primitive and unconfined types of recreation). 

x Effects to any of the wilderness characteristics in an area would affect the overall area’s status as 

having wilderness characteristics. 

x Adverse effects to wilderness characteristics would result from any management action that 

allows surface-disturbing activities that degrade naturalness. 

x Where a portion of an area identified as having wilderness characteristics overlaps with the 

Harvest Land Base under a particular alternative, the effected sub-unit would have all inventoried 

acres eliminated from protection unless the remaining acreage is over 5,000 acres. 

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 Federal Land Policy and 

Management Act (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 Bureau updated its Lands With Wilderness 

Characteristics inventories for western Oregon in 2013. This update included BLM-administered lands 

contained in citizen’s wilderness proposals. The impetus for this update was the need for accurate 

information for the ongoing revision of the RMPs for western Oregon. In conducting these inventories, 

the six BLM offices 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. 

As inventory maintenance, the BLM used the same criteria from Section 2(c) of the Wilderness Act to 

determine the presence or absence of wilderness characteristics. Following this guidance, the BLM 

inventoried areas for the requisite wilderness characteristics: sufficient size of a roadless area, naturalness, 

and outstanding opportunities for solitude or primitive and unconfined recreation. The BLM wilderness 

inventory did not find wilderness characteristics to be present within any portion of the citizen-proposed 

areas. 

In Alternative A, the BLM would protect all lands with identified wilderness characteristics that are not 

within the Harvest Land Base. In Alternatives B and C, the BLM would protect all lands with identified 

wilderness characteristics that are outside of the Harvest Land Base and are compatible with existing and 

potentially non-compatible recreation opportunities (motorized and mechanized uses). In Alternative D, 

the BLM would not protect any identified lands with wilderness characteristics. 
Chapter 3 - AE&EC – Lands with Wilderness Characteristics

372 | Page

Affected Environment 

Through inventories, the BLM identified 90,199 acres of Lands with Wilderness Characteristics in the 

Coos Bay, Medford, and Salem Districts. 

The Coos Bay District inventory found one area that possesses wilderness characteristics totaling 3,048 

acres. The Coos Bay District re-validated their 2006 inventory updates. The interdisciplinary review 

resulted in the conclusion that the Wasson Creek unit remains sufficient in terms of relevance and 

supporting rationale. The Medford District inventory found seven areas that possess wilderness 

characteristics totaling 85,254 acres. The Salem District inventory found four areas, including nine 

subunits that possess wilderness characteristics, resulting in a total of 2,624 acres. All areas in the Salem 

District rely on adjacent BLM wilderness or other Federal Lands with Wilderness Characteristics to meet 

the size criterion. Table 3-88 lists the areas found by the BLM to possess wilderness characteristics. 

Table 3-88. Lands with Wilderness Characteristics within the decision area. 

District/Field Office Sub-Unit Totals (Acres)

Coos Bay

Wasson Creek - 3,408

Eugene

No lands were identified with wilderness characteristics

Klamath Falls

No lands were identified with wilderness characteristics

Medford

Berry Creek - 6,459

Burton Nine Mile - 6,103

Dakubetede - 5,099

Round Top Mountain - 5,295

Wellington - 5,711

Whiskey Creek - 6,187

Wild Rogue - 51,249

Roseburg

No lands were identified with wilderness characteristics

Salem

Bull of the Woods/Opal Creek Additions Nasty Rock 1,196

Bull of the Woods/Opal Creek Additions Evans Mountain 278

Table Rock Wilderness Additions Table Rock 95

Salmon Huckleberry Additions Boulder Creek 506

Salmon Huckleberry Additions Eagle River 14

Salmon Huckleberry Additions Salmon River 120

Clackamas Wilderness/South Fork Clackamas River Memaloose Creek 195

Clackamas Wilderness/South Fork Clackamas River South Fork Clackamas #1 178

Clackamas Wilderness/South Fork Clackamas River South Fork Clackamas #2 42

Chapter 3 - AE&EC – Lands with Wilderness Characteristics

374 | Page

Environmental Effects 

This analysis considers the effects to inventoried Lands with Wilderness Characteristics both through 

management for wilderness characteristics under various alternatives and through management that would 

degrade wilderness characteristics where alternatives do not manage for them. 

Effects Common to All Alternatives 

x While the alternatives vary in the acreage of areas they manage for their wilderness characteristics, 

under all alternatives the BLM would not manage Lands with Wilderness Characteristics that 

overlap with the Harvest Land Base for their wilderness characteristics. Management actions for 

other resources would likely degrade these characteristics over time. 

x The BLM would successfully protect areas with identified wilderness characteristics that exist 

outside of the Harvest Land Base, and where the BLM chooses to protect these wilderness 

characteristics. 

x Where wildland fire threatens safety of property, suppression could degrade wilderness 

characteristics even in areas managed for their wilderness characteristics. 

Effects of Managing Lands for their Wilderness Characteristics 

The alternatives vary in the extent that they would allocate lands to be managed for their wilderness 

characteristics. Table 3-89 and Figure 3-119 show the amount of Lands with Wilderness Characteristics 

that the BLM would maintain by alternative. Under Alternative A, the BLM would manage all Lands with 

Wilderness Characteristics not in the Harvest Land Base for their wilderness characteristics. Under 

Alternatives B and C, the BLM would manage all Lands with Wilderness Characteristics not in the 

Harvest Land Base, and not over lapping with conflicting recreation designations, for their wilderness 

characteristics. Under both the No Action alternative and Alternative D, the BLM would not manage 

Lands with Wilderness Characteristics for their wilderness characteristics. 
Chapter 3 – AE&EC – Lands with Wilderness Characteristics

375 | Page

Table 3-89. BLM-administered Lands with Wilderness Characteristics maintained by alternative. 

District Unit Name Totals 

(Acres) 

No Action 

(Acres) 

Alt. A 

(Acres) 

Alt. B 

(Acres) 

Alt. C 

(Acres) 

Alt. D 

(Acres) 

Coos Bay Wasson Creek 2,467 - 2,467 - - - 

Medford 

Berry Creek 6,241 - 6,045 - - - 

Burton Nine Mile 5,933 - 5,778 - - - 

Dakubetede 5,092 - 4,870 - - - 

Round Top Mountain 5,291 - 5,291 - - - 

Wellington 5,697 - 4,272 - - - 

Whiskey Creek 6,187 - 6,187 - - - 

Wild Rogue 50,670 - 50,636 50,670 50,670 - 

Salem 

Bull of the Woods/Opal 

Creek Additions-Nasty Rock 1,191 - 1,183 - - - 

Bull of the Woods/Opal 

Creek Additions-Evans 

Mountain 

277 - 247 - - - 

Table Rock Wilderness 

Additions 96 - 96 58 58 - 

Salmon Huckleberry 

Additions-Boulder Creek 506 - 506 - - - 

Salmon Huckleberry 

Additions-Eagle River 14 - 6 - - - 

Salmon Huckleberry 

Additions-Salmon River 117 - 117 - - - 

Clackamas Wilderness 

Additions-Memaloose Creek 199 - 168 - - - 

Clackamas Wilderness 

Additions-South Fork 

Clackamas #1 

178 - 158 - - - 

Clackamas Wilderness 

Additions-South Fork 

Clackamas #2 

43 - 43 - - - 

Totals 90,199 - 88,070 50,728 50,728 - 
Chapter 3 - AE&EC – Lands with Wilderness Characteristics

376 | Page

Figure 3-119. Acres of BLM-administered Lands with Wilderness Characteristics maintained by 

alternative. 

Where the BLM would manage an area for wilderness characteristics, the BLM would apply a suite of 

protective management direction to achieve this objective. This management direction includes closing 

the area to motorized travel, making the area a Right-Of-Way Exclusion Area, managing for VRM Class I 

or II, closing the area to salable minerals, requiring stipulations on leasable minerals, and recommending 

to withdraw the area from locatable minerals. Table 3-90 lists the acres protected by any of these 

management protections by alternative. 

Table 3-90. Acres of management protections for Lands with Wilderness Characteristics managed for 

their wilderness characteristics. 

No Action

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

Applied Management Protections - 88,070 50,728 50,728 -

No Action Alternative 

The 1995 RMPs do not identify Lands with Wilderness Characteristics outside of designated Wilderness 

Areas and Wilderness Study Areas. Thus, the No Action alternative would not manage any Lands with 

Wilderness Characteristics for their wilderness characteristics. While management for other resources 

may provide some level of protection for these qualities, without specific management protections, these 

wilderness characteristics are likely to degrade. 

Alternative A 

Alternative A includes management for wilderness characteristics in all areas identified during wilderness 

inventories that are outside of the Harvest Land Base. Management actions to protect other resources and 

special areas would offer some protection of wilderness characteristics, although surface-disturbing 

activities and casual use (e.g., recreation) would have the potential to alter the natural setting as well as 

reduce opportunities for solitude or primitive recreation for all Lands with Wilderness Characteristics 

units that are not managed for their wilderness characteristics. 

90,199 88,070

50,728 50,728

0

0

20,000

40,000

60,000

80,000

100,000

No Action Alt. A Alt. B Alt. C Alt. D

BLM-administered Lands with 

Wilderness Characteristics (Acres)
Chapter 3 – AE&EC – Lands with Wilderness Characteristics

377 | Page

Of the 90,199 acres of Lands with Wilderness Characteristics, the BLM would manage 88,070 acres (97.6 

percent) for their wilderness characteristics. The other 2,129 would be in the Harvest Land Base and 

would likely be lost over time. 

Alternatives B and C 

Alternatives B and C manage Lands with Wilderness Characteristics for their wilderness characteristics 

when they are outside of the Harvest Land Base and are compatible with existing and potential recreation 

opportunities and activities. Under Alternatives B and C, the BLM would manage two units totaling 

50,728 acres for their wilderness characteristics. The 39,471 acres not managed for their wilderness 

characteristics would be either be in the Harvest Land Base or would be managed by the BLM under 

incompatible recreation and OHV management; their wilderness characteristics would likely be lost over 

time. 

Alternative D 

Alternative D does not manage any lands with wilderness characteristics for their wilderness 

characteristics. While some management for other resource might provide some level of protection for 

wilderness characteristics, the 90,199 acres of wilderness characteristics are likely to degrade over time, 

particularly where they overlap with the Harvest Land Base or incompatible recreation and OHV 

designations. 

Effects from Forest Management to Lands With Wilderness 

Characteristics 

Because of the inherent incompatibility between managing for wilderness characteristics and sustainedyield timber harvest, the BLM is not considering managing for wilderness characteristics any lands in the 

Harvest Land Base under a given alternative. Wilderness characteristics are likely to degrade where the 

BLM does not specifically manage for them, therefore, wilderness characteristics in the Harvest Land 

Base would almost certainly be lost over time. While retention levels vary among alternatives, all lands 

within the Harvest Land Base would eventually be subject to sustained-yield timber harvest, which is 

incompatible with preserving wilderness characteristics, at least over the life of the plan. Table 3-91

shows the acres of lands with wilderness characteristics that would be in the Harvest Land Base by 

alternative. 

 
Chapter 3 - AE&EC – Lands with Wilderness Characteristics

378 | Page

Table 3-91. BLM-administered lands with wilderness characteristics in the Harvest Land Base by 

alternative. 

District Unit Name Totals

(Acres)

No Action

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

Coos Bay Wasson Creek 2,467 - - - 1 146

Medford

Berry Creek 6,241 2,574 196 1,094 786 613

Burton Nine Mile 5,933 5,052 155 - - 2,522

Dakubetede 5,092 4,322 222 734 769 634

Round top mountain 5,291 - - - - 25

Wellington 5,697 4,533 1425 1,837 1,923 1,520

Whiskey Creek 6,187 2,586 - - - 350

Wild Rogue 50,670 3,706 34 - - 2,835

Salem

Bull of the Woods/Opal Creek 

Additions-Nasty Rock 1,191 - 8 11 112 125

Bull of the Woods/Opal Creek 

Additions-Evans Mountain 277 - 30 47 138 11

Table Rock Wilderness Additions 96 - - 38 38 42

Salmon Huckleberry AdditionsBoulder Creek 506 - - - 94 -

Salmon Huckleberry AdditionsEagle River 14 7 8 7 8 8

Salmon Huckleberry AdditionsSalmon River 117 - - - - -

Clackamas Wilderness AdditionsMemaloose Creek 199 42 31 29 37 22

Clackamas Wilderness AdditionsSouth Fork Clackamas #1 178 73 20 20 20 20

Clackamas Wilderness AdditionsSouth Fork Clackamas #2 43 20 - - - -

Totals 90,199 22,915 2,129 3,817 3,926 8,873

The No Action alternative would have the largest acreage of lands with wilderness characteristics in the 

Harvest Land Base, followed by Alternative D. Alternative A would have the least. 

Effects from Recreation and Visitor Services Management 

Wilderness characteristics would diminish within Recreation Management Areas where the BLM would 

manage for non-compatible motorized and mechanized recreation use. In Alternative A, the BLM 

prioritizes the management of wilderness characteristics over incompatible recreation and OHV 

designations. Under Alternatives B and C, the BLM would not manage for wilderness characteristics 

where incompatible recreation management area and OHV designations are proposed. Under Alternatives 

B and C, the BLM would not manage 39,433 acres of lands with wilderness characteristics for their 

wilderness characteristics in order to manage them for incompatible Recreation Management Area and 

OHV designations. Under Alternative D, the BLM would not manage lands with wilderness 

characteristics for their wilderness characteristics; all 90,199 acres of lands with wilderness characteristics 

would be available to either mechanized use or motorized use with either an open or limited to existing

OHV designation. Wilderness characteristics would diminish in Alternative D from incompatible 

recreation use. 
Chapter 3 – AE&EC – Livestock Grazing

379 | Page

Livestock Grazing 

Key Points x Under Alternatives A, B, and C, BLM-administered land available for livestock grazing would 

decrease from 495,190 acres (20 percent of the decision area) to 359,049 acres (14 percent of the 

decision area). This change would occur through the BLM making currently vacant lots 

unavailable for grazing. 

x Under Alternative D, the BLM would no longer authorize livestock grazing within the decision 

area, a change that would affect 495,190 acres (20 percent of the decision area) for the life of the 

plan.

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 grazing on both BLM-administered lands within a 

grazing district (through Section 3 permits) and those outside a 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 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, and, where it takes place, Section 15 of the Taylor Grazing Act permits 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 those BLM-administered 

lands. The BLM permits most leases for 10 years, though that is not required. 

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 acres of BLM lands allocated for livestock grazing? 

Summary of Analytical Methods 

The BLM compared the number of allotments and acres that would be available for livestock grazing on 

BLM-administered lands under each alternative. The BLM did not include small exclosures within an 

allotment that exclude livestock grazing for the purpose of this analysis. 

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). 
Chapter 3 - AE&EC – Livestock Grazing

380 | Page

Affected Environment 

The Coos Bay District, Klamath Falls Field Office, and Medford District administer livestock grazing on 

495,190 acres of BLM-administered lands, representing 21 percent of the decision area (Table 3-92).

Table 3-92. Livestock grazing statistics by district or field office. 

District/

Field Office

Number of 

Allotmentsa

Total BLM Acres 

within Allotments

Number of Active 

AUMs

Number of 

Permittees

Coos Bay 4 543 23 4

Klamath Falls 95 209,852 12,947 63

Medford 87 (11b) 284,795 10,255 43

Totals 197 495,190 23,225 110 a

 Allotments include vacant without current permit/lease, and closed. These do not include unallotted lands. 

b

 These 11 allotments have been removed from the reporting system since no grazing has occurred since before the 

1995 RMP. This RMP proposes these allotments as unavailable for grazing, so it is important to account for them 

here. 

There are six allotments within the planning area containing acreage in the Cascade Siskiyou National 

Monument, which is outside the decision area. Table 3-93 displays the acres of each allotment in the 

planning area and in the monument. The Klamath Falls Field Office administers the Dixie and Buck 

Mountain Allotments and the Medford District administers the Deadwood Allotment. The Soda Mountain 

Allotment, Siskiyou Allotment, and Keene Creek Allotment have no livestock grazing authorized. 

Table 3-93. BLM-administered livestock grazing allotments with acres within the Cascade Siskiyou 

National Monument (CSNM) and allotments within the decision area. 

Allotment Name

Allotment 

Number

Acres in 

CSNM

Acres in

Decision 

Area

Total 

AUMs Decision

Buck Mountain 00103 739 7,416 204 Current permit to graze

Deadwood 20106 37 7,967 788 Current permit to graze

Dixie 00107 1283 4,436 320 Current permit to graze

Keene Creek 10115 10,600 13,019 - CSNM-grazing was removed 

by PL111-011

Siskiyou 10118 2,163 260 - CSNM-grazing was removed 

by PL111-011

Soda Mountain 10110 35,619 413 - CSNM-grazing was removed 

by PL111-011

Table 3-94 displays the change in the number of active allotments from levels identified in the 1995 

RMPs to current levels. The number of vacant allotments and leases has increased from 17 (all in the 

Medford District) in 1995 to 56 (42 in the Medford District and 14 in the Klamath Falls Field Office). 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: 

x Relinquishment by operators 

x Cancellation due to nonuse or noncompliance 

x Lack of interest 

x Difficulties to graze within an allotment because of intermingled private land 

x Conflicts with other users of public land 

x Lack of fencing to control livestock on public land 

x Change of boundary fencing that excludes BLM-administered lands 
Chapter 3 – AE&EC – Livestock Grazing

381 | Page

Table 3-94. Current grazing levels compared to 1995 RMP levels. 

District/ 

Field Officea

1995 RMP Levels 2014 Levels 

Available 

AUMs 

Active 

Allotments 

Vacant 

Allotments 

Available 

AUMs 

Active 

Allotments 

Vacant 

Allotments 

Coos Bay 270 7 - 120 4 - 

Klamath Falls 13,662 95 - 12,947 83 12 

Medford 17,458 99 18 10,255 50b 46 

Totals 31,390 201 18 23,322 137 58 a For reporting purposes all allotments and AUMs the districts administer are counted, including vacant allotments and their 

associated AUMs. Some of these allotments and associated AUMs do not occur within the planning area.

Existing grazing leases/permits within the BLM-administered lands in the decision area authorize 23,322 

active Animal Unit Months (AUMs) of active use. Current levels of available grazing are 8,068 AUMs 

less than permitted levels in 1995. These AUMs are all available for grazing, but some allotments are 

vacant and not being used. Actual levels of livestock use on active allotments can vary due to annual 

fluctuations of individual livestock operations or environmental conditions such as drought, 

relinquishment by operators, transfers, or changes in 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 grazing associated with the Cascade Siskiyou National Monument, combining 

multiple allotments into one, splitting of allotments into more than one, and reductions in grazing for 

resource protection.

Environmental Consequences 

Under all alternatives, all components of livestock grazing authorizations (acres for grazing, number of 

allotments, AUMs, permittees/lessees) would either remain the same or decrease, as shown in Table 3-95. 

Alternatives A, B, and C would retain all active allotments but would make vacant allotments unavailable 

for grazing. Therefore, the number of AUMs billed would remain at current levels in all alternatives 

except Alternative D. Under Alternative D, the BLM would cease to authorize any livestock grazing 

within the decision area and receive no payments for AUMs for the life of the plan. 

 
Chapter 3 - AE&EC – Livestock Grazing

382 | Page

Table 3-95. Livestock grazing authorizations for each alternative for the Coos Bay District, Klamath Falls 

Field Office, and Medford District. 

District/

Field Office Alternative Allotments1

Public 

Land2

(Acres)

Permitted 

Use 

AUMs

Active/Available 

AUMs Permittees

Coos Bay

No Action 4 543 - 120 -

Alt. A, B, C - - - - -

Alt. D - - - - -

Klamath Falls

No Action 95 209,852 12,762 12,947 63

Alt. A, B, C 94 205,627 12,762 12,927 63

Alt. D - - - - -

Medford

No Action 96 284,795 10,255 12,553 43

Alt. A, B, C 59 161,760 10,255 10,255 43

Alt. D - - - - -

Total

No Action 196 495,190 23,017 25,500 106

Alt. A, B, C 155 359,049 23,017 23,182 106

Alt. D - - - - - 1

Number of allotments available to grazing by alternative. 

2

Public land acres available for livestock grazing by alternative. 

Under Alternatives A, B, and C, the amount of BLM-administered land available for livestock grazing 

through the issuance of grazing leases/permits would decrease from 495,190 acres (20 percent of the 

decision area) to 359,049 acres (14 percent of the decision area) (Table3-95). In Alternative D, the BLM 

would eliminate authorized use and the acres would become unavailable for livestock grazing for the life 

of the plan. 

Figure 3-120 shows the acres available for livestock grazing by alternative. 

Figure 3-120. Change in acres available for livestock grazing by alternative. 

543

209,852

284,795

0

197,289

161,760

000

0

50,000

100,000

150,000

200,000

250,000

300,000

Coos Bay Klamath Falls Medford

Grazing Available (Acres)

District/Field Office

No Action Alt. A, B, C Alt. D
Chapter 3 – AE&EC – Livestock Grazing

383 | Page

On the Medford District, Alternatives A, B, and C would decrease the number of available allotments as 

compared to the No Action alternative; the decrease would occur on allotments that have been vacant for 

five years or more. The number of allotments available to graze would decrease by 40. The BLMadministered lands available for livestock grazing would decrease by 135,612 acres and approximately 

2,298 AUMs. This decrease would not reduce the number of allotments or permittees that have an active 

permit or lease (Figure 3-121). 

Figure 3-121. Change in the number of allotments available to graze by alternative. 

For the Klamath Falls Field Office, Alternatives A, B, and C would decrease the number of acres 

available to grazing in two allotments, as compared to the No Action alternative. A portion of the Edge 

Creek Allotment (4,065 acres) is fenced off from livestock grazing and included in the Klamath River 

Area of Critical Environmental Concern (ACEC). The BLM would make this area unavailable to grazing 

in Alternatives A, B, and C. No AUMs are currently associated with these ACEC acres and no livestock 

grazing is currently occurring in this area. The remainder of the Edge Creek Allotment would continue to 

be available for livestock grazing. The BLM would also make the Plum Hills Allotment unavailable to 

livestock grazing. Plum Hills is a vacant allotment with 160 acres and 20 available AUMs. 

Figure 3-122 shows the locations of the areas available, unavailable, and unallotted within the Coos Bay 

and Medford Districts and the Klamath Falls Field Office. 

4 

96 98 

0 

96 

59 

0 0 0 

0

20

40

60

80

100

120

Coos Bay Klamath Falls Medford

Grazing Allotments 

District/Field Office 

No Action Alt. A, B, C Alt. D

Chapter 3 – AE&EC – Livestock Grazing

385 | Page

alternative and 23,017 AUMs in Alternatives A, B, and C. The BLM would no longer collect fees on 

these AUMs. The BLM discusses economic losses to permittees more under Socioeconomics. Alternative 

D would have the greatest effect to livestock grazing for the Medford District and the Klamath Falls Field 

Office when compared to the other alternatives. 

Issue 2 

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? 

Background 

Current 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 in consultation with 

Resource Advisory Councils, Provincial Advisory Committees, Tribes, and others. The standards are the 

basis for assessing and monitoring rangeland conditions and trend (USDI BLM 1997). 

The 43 CFR part 4180.2 (c)(1) provides: 

“If a standards assessment indicates to the authorized officer that the rangeland is failing to achieve 

standards or that management practices do not conform to the guidelines, then the authorized officer will 

use monitoring data to identify the significant factors that contribute to failing to achieve the standards or 

to conform with the guidelines. If the authorized officer determines through standards assessment and 

monitoring that existing grazing management practices or levels of grazing use on public lands are 

significant factors in failing to achieve the standards and conform with the guidelines that are made 

effective under this section, the authorized officer will, in compliance with applicable laws and with the 

consultation requirements of this part, formulate, propose, and analyze appropriate action to address the 

failure to meet standards or to conform to the guidelines.”

(i) Parties will execute a documented agreement and/or the authorized officer will issue a 

final decision on the appropriate action under §4160.3 as soon as practicable, but no later 

than 24 months after a determination. 

(ii) BLM may extend the deadline for meeting the requirement established in paragraph (c) 

(1)(i) of this section when legally required processes that are the responsibility of another 

agency prevent completion of all legal obligations within the 24-month time frame. BLM 

will make a decision as soon as practicable after the legal requirements are met. 

Prior to the 2015 changes, the regulations required: 

“(c) The authorized officer shall take appropriate action as soon as practicable but not later than the start 

of the next grazing year upon determining that existing grazing management practices or levels of grazing 

use on public lands are significant factors in failing to achieve the standards and conform with the 

guidelines that are made effective under this section. 

Appendix K includes the complete “Standards for Livestock Grazing Management for Public Lands in 

Oregon and Washington.”

Summary of Analytical Methods 

For this analysis, the BLM considered why certain allotments are not meeting rangeland health standards 

in a general manner and what affect the alternatives would have on meeting those standards. 
Chapter 3 - AE&EC – Livestock Grazing

386 | Page

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 BLM has assessed 94 percent of livestock grazing allotments and leases within the decision 

area to determine whether they are meeting rangeland health standards. As shown in Table 3-96,

the BLM found livestock grazing to be a contributing factor in not meeting rangeland health 

standards in 12 allotments (5 in Medford and 7 in Klamath Falls). In those allotments, the BLM 

adjusted livestock grazing management to ensure significant progress toward meeting the standards 

and to eliminate livestock grazing as the causal factor for not meeting the health standard. In this 

situation, adjusting livestock grazing management would usually require changes in livestock 

numbers, season of use, or animal unit months (AUMs), construction of range improvements, or 

implementation of intensive grazing systems. On 6 percent of allotments within the decision area, a

Rangeland Health Assessment has not yet been completed. Some of those allotments are currently 

not grazed and are proposed to be made unavailable for livestock grazing in Alternatives A, B, C, 

and D. Those allotments lacking a Rangeland Health Assessment have a schedule to complete the 

assessment based on district priorities. 

Table 3-96. 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 52 107,929 23 124,584

Rangelands Not Meeting All 

Standards with Appropriate 

Action Taken to Ensure 

Significant Progress Toward 

Meeting the Standard 

(Livestock was a contributing 

factor)

- - 7 25,988 5 7,784

Rangelands Not Meeting All 

Standards or Making 

Significant Progress Toward 

Meeting the Standard Due to 

Causes Other Than Livestock 

Grazing

- - 11 46,745 19 21,260

Allotments Assessed and 

closed to grazing with a 

previous decision

- - - - 3 13,692

Total Assessed 4 543 70 180,662 50 153,628

Allotments Not Assessed - - 25 15,254 44 120,154

Total 4 543 95 195,196 94 284,795
Chapter 3 – AE&EC – Livestock Grazing

387 | Page

Opportunities to achieve desired rangeland health conditions may be limited in some areas due to past 

management activities. An example of this would be historic vegetative treatments that converted an area 

from a perennial grass/forb understory to an invasive plant understory (like Medusahead, dogtail, or 

bulbous bluegrass). Therefore, the upland Rangeland Health Standard 1 may not be met from even 

Alternative D where removal of livestock is proposed unless intensive reseeding combined with intensive 

weed treatments are additionally implemented. Completed Rangeland Health Assessments by allotment 

are available on the BLM web sites for each district located at: 

http://www.blm.gov/or/districts/medford/plans/medfordrmp.php and 

http://www.blm.gov/or/districts/lakeview/plans/inventas.php. 

Environmental Consequences 

The BLM assumed that for the 12 grazing allotments in Table 3-96 where grazing was a casual factor 

within one year of the Rangeland Health Assessment, the BLM would make, or has made, a change in 

livestock grazing that will result in significant progress toward fulfillment of the standards. 

Therefore, in all alternatives, including the No Action alternative, either those allotments would make 

significant progress toward meeting the standard or that livestock grazing is no longer a contributing 

factor. Only Alternative D would make these 12 allotments unavailable to livestock grazing. In 

Alternative D, some allotments not meeting rangeland health standards would recover at a faster rate with 

fewer disturbances when compared to other alternatives. 

Issue 3 

How would each of the alternatives affect BLM’s ability to provide forage on those lands allocated for 

livestock grazing? 

Summary of Analytical Methods 

For the purposes of this analysis, the BLM assumed that regeneration harvest generally improves forage 

production due to the decreased competition between understory and overstory vegetation. Given this 

assumption, the BLM compared the size of the Harvest Land Base by alternative to determine how the 

alternatives would affect the BLM’s ability to provide forage. 

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 forage conditions within individual allotments are variable based on historic livestock grazing levels, 

past management actions, and current grazing management. Past timber harvest activities within 

allotments created canopy openings that provide increased forage for livestock. 

On the Coos Bay District, a mix of native grass species, noxious weeds, and non-native pasture vegetation 

characterizes the vegetation on BLM-administered lands within the four livestock grazing leases. The 

non-native pasture vegetation is typically dominant. A mix of grassland, chaparral, mixed conifers, and 

hardwoods, characterizes the Medford District vegetation on BLM-administered lands. The eastern side 

of the Klamath Falls Field Office is characterized by non-forested uplands comprised of sagebrush and 

juniper communities. The western portion of the field office is comprised of mixed conifers and 

hardwoods. 
Chapter 3 - AE&EC – Livestock Grazing

388 | Page

Environmental Consequences 

Under Alternatives A, B, and C, timber harvest activities occurring within allotments may create 

temporary reductions in available livestock grazing. The BLM may need to rest harvest areas from 

livestock grazing the first year after disturbance activities to allow understory vegetation to recover and to 

protect seedlings. Long-term effects (occurring after 5-10 years) of timber harvest activities could result in 

small increases in understory vegetation. The forage differences between alternatives may vary slightly 

with the largest forage likely to be available in Alternative C coinciding with the largest Harvest Land 

Base acreage. 

Forage availability increases from Alternative A to Alternative B to Alternative C, which has the largest 

Harvest Land Base. This increased forage availability by alternative may affect livestock distribution 

within allotments; however, no increases in stocking rate would occur due to increased forage available. 

Increased forage could cause small increases in weight gain of livestock (Walburger et al. 2007). These 

alternatives would provide adequate livestock forage for livestock grazing levels. 

Alternative D would eliminate livestock grazing, thus the impacts of an increase or decrease in forage for 

livestock is irrelevant. 

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. 19 pp. 

---. 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. 
Chapter 3 – AE&EC – Minerals

389 | Page

Minerals 

Key Points 

x Under all of the action alternatives, the acres of land recommended for withdrawal from locatable 

mineral entry would increase by 6-8 percent of the decision area. The BLM ranks 38-65 percent 

of these lands as high for mineral occurrence and development. Recommending the withdrawal of 

these 80,000-110,000 acres (depending on alternative) of high-ranked lands could have negative 

effects to the development of known and undiscovered mineral resources. 

x Approximately 90 percent of the decision area remains open to locatable and salable mineral 

entry under all action alternatives. 

x Unless closed by legislation, under all action alternatives, the decision area is open to leasable 

mineral development. 

Background 

The BLM administers the mineral estate on nearly 40 million acres of BLM, U.S. Forest Service, 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 68,600 acres of 

Federal minerals with private surface ownership. Table 3-97 lists the acres by office. 

Table 3-97. Acres of surface and mineral estate. 

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 

* 2008 data from the Western Oregon Plan Revision EIS and district-specific information. 

Physiography 

The planning area contains five geologic physiographic regions.63 They are the Coast Range, Willamette 

Valley, Cascade Mountains (High and Western), Klamath Mountains, and the Basin and Range (Figure 

3-123). Each region’s unique geology influences the mineral occurrences. 

 

63 These are different from the terrestrial physiographic regions described in FEMAT and illustrated in Figure 3-2. 
Chapter 3 - AE&EC – Minerals

390 | Page

Figure 3-123. Physiographic Regions in the decision area (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 for aggregate 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. This MILO database shows 300 occurrences for other mineral 

commodities such as clay, limestone, pumice, and silica sand scattered thorough the planning area. There 

are 150 occurrences for coal with most sites in coastal areas concentrated in the Coos Bay area. In 

addition, there are 3,300 metal occurrences (gold, silver, copper, nickel, chromite, and other minerals) 

with nearly all being located in southwest Oregon.

Coast Range Mineral Resources 

Coal seams occur throughout the Coast Range, with the majority in Coos County. On the Coos Bay 

District, there is a coalbed natural gas Area of Mutual Interest. The Coast Range has oil and gas potential 

and development; the State’s first commercial gas field was located in 1979 near Mist in Columbia 

County; this field has 18 wells and has produced 65 billion cubic feet of gas. Other economically valuable 

minerals include beach placers containing gold and platinum from Cape Blanco to Cape Arago. 

Willamette Valley Mineral Resources 

Deeply-weathered basalts that have resulted in 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. 

Cascade Mountains Mineral Resources 

Gold and silver has 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. 
Chapter 3 – AE&EC – Minerals

391 | Page

A series of hot springs in an irregular, roughly 12-mile-wide, north-south belt marks a thermal boundary 

existing between the High Cascades and Western Cascades. Temperatures of the waters can range 

between 90-190 degrees Fahrenheit in certain areas. The thermal gradients of the region may represent a 

large potential source of renewable geothermal energy. 

Klamath Mountains Mineral Resources 

The Klamath province has substantial mineral resources due to its geologic diversity. Mineralization is 

primarily attributed to tectonic plate evolution and secondarily to later plutonic intrusion. This province 

has historically produced gold, silver, copper, nickel, chromite, and 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 province has come from placers deposits. 

Copper was historically mined from the Josephine ophiolite near Grants Pass, nickel from weathered 

ophiolites near Riddle, and chromite from ophiolites throughout the Klamath Mountains. Chromite rich 

beach sands derived from the Klamath Mountains occur on the southern Oregon coast. 

Basin and Range Mineral Resources 

There was historic uranium, mercury, and borax production in this province and diatomite occurs near the 

Sprague River. This region has a thin crust, numerous faults, and high heat flow, which creates an 

increased possibility for geothermal resources. 

Issue 1 

How would the alternatives affect salable mineral development or existing BLM rock quarries? 

Summary of Analytical Methods 

The BLM evaluated how the acreage proposed for closure to salable mineral materials under each 

alternative would affect the possible future development of this resource. Under each alternative, the 

BLM would close lands managed for their wilderness characteristics, eligible Wild and Scenic River 

segments, some Areas of Critical Environmental Concern (ACECs), and Recreation Management Areas 

(RMAs), to salable mineral development. The BLM evaluated data from LR2000,64 data supplied by each 

office, and data from the Oregon Department of Geology and Mineral Industries to determine the location 

of mineral material sites (primarily rock quarries) in the decision area. It was determined that this data 

could not be utilized to predict the location for future mineral material sites. The BLM will not complete a 

formal mineral potential report for salable minerals for this RMP revision. Information regarding mineral 

potential reports, and when they are required, can be found in BLM Manual 3031. 

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which the BLM incorporates here by reference (USDI 

BLM 2014, p.104). 

 

64 This is a BLM database containing information about minerals. 
Chapter 3 - AE&EC – Minerals

392 | Page

Background 

Salable minerals are mineral materials and include common variety quarry rock used in construction and 

road surfacing, and sand and gravel, clay, and volcanic pumice and cinders. The regulations found in 43 

CFR 3600 guide the exploration, development, and disposal of mineral material resources and the 

protection of resources and the environment. The disposal of mineral materials includes sale at fair market 

value to the public and through free use permits to government entities or non-profit organizations. 

Disposal of mineral materials is discretionary on the part of BLM.

Within the decision area, the BLM’s primary salable mineral material is quarry rock. The BLM, timber 

companies, and local governments crush the majority of this quarry rock to create aggregate for road 

surfacing. Other uses of quarry rock include rip-rap for fish enhancement projects, jetty and boat ramps, 

and reclamation projects. The BLM also disposes of sand and gravel, soil or fill, clay, volcanic pumice 

and cinders, and specialty stone through sales or free use permits. 

Affected Environment 

The use of mineral materials is dependent on the demand by the BLM, private companies, local 

governments, and the public. Figures 3-124 and 3-125 display mineral material production by cubic 

yard and the number of sales across the decision area for the years 2007-2013 (LR2000).

Figure 3-124. Number of sales or permits for mineral material by year in the decision area. 

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
Chapter 3 – AE&EC – Minerals

393 | Page

Figure 3-125. Cubic yards of mineral material produced by year in the decision area. 

Mineral material sales data from 2007-2013 show that sales and permits (BLM use is tracked by permits) 

in the decision area are both numerous and of low volume, with nearly 500 disposals during this period 

averaging about 400 cubic yards each. 

There are just over 600 developed quarry sites in the decision area. The majority of these quarries are 

used for in-place quarry rock, although a few sites are for pumice, sand, gravel, or dimension stone. Many 

of these sites were developed before the 1990s and have been in use for decades. The footprint, or area of 

disturbance, of quarry sites is variable and ranges from about 0.01-5 acres. A typical quarry is about 0.5 

acre in size. The BLM estimates that that approximately 25-33 percent of these rock quarries are near 

depletion with just a few thousand cubic yards of rock remaining. At some sites, continued removal could 

require expansion of the existing footprint. The BLM does not have an 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 the required 

specifications. However, access, proximity to area of use, and environmental considerations are also 

important factors in determining where to develop a quarry. Figure 3-126 shows the spatial distribution 

of quarry sites in the decision area. 

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 

Chapter 3 – AE&EC – Minerals

395 | Page

Table 3-98. 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 18 

Totals 602 

The majority of these quarries are used for in-place quarry rock, although a few sites are for pumice, sand 

and gravel, or dimension stone. The BLM does not have a complete inventory of potential rock quarry 

sites in the decision area, but as Figures 3-125 and 3-126 show, there is ongoing interest in BLM 

quarries, with 40 to 90 sales a year. 

All of the salable activity described above takes place on BLM-administered lands that are open to salable 

mineral entry. Table 3-99 provides a breakdown by office of the acres of BLM-administered lands that 

are currently closed to salable mineral development. Closed nondiscretionary lands, which total 31,530 

acres, remain closed under all alternatives. As Table 3-99 shows, the Salem District has the majority of 

lands closed to salable mineral entry. 

Table 3-99. Acres of lands currently closed to salable mineral development (No Action alternative). 

District/Field Office Salable 

(Acres)* 

Closed Nondiscretionary+

(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 

* 2008 data from The Western Oregon Plan Revision EIS. 

+ Legal mandates establish non-discretionary closures while a discretionary closure is the result of an agency management 

decision. 

There are over 5,500 quarry sites for stone/aggregate and an estimated 300 sites for other types of saleable 

minerals other than quarry rock or aggregate in the planning area (DOGAMI MILO). They include 

commodities such as clay, limestone, pumice, silica, and others (Table 3-100). 

Table 3-100. Estimated number of mineral material sites in the planning area. 

Commodity Number of Sites 

Cement Materials 108 

Clay 84 

Other Minerals* 89 

Pumice 4 

Quarry Stone and Aggregate 5,500 

Silica Sand 19 

* Talc, soapstone, certain gemstone, refractory graphite, serpentine, quartz crystal, optical calcite 
Chapter 3 - AE&EC – Minerals

396 | Page

Trends in salable mineral material developments for rock quarries and development guidance can be 

found in Appendix L.

Environmental Effects 

Figure 3-127 and Table 3-101 show acres that the BLM would close to salable mineral development by 

alternative and land use category. 

Figure 3-127. Acres closed to salable development by land category and alternative. 

Table 3-101. Acres closed to salable mineral entry. 

Land Category No Action 

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

ACEC - 94,740 88,177 86,854 94,534

RMA - 18,068 48,810 70,350 83,743

Lands Managed for Wilderness 

Characteristics - 88,029 50,728 50,706 0

Eligible Wild Scenic Rivers - 0 7,143 7,143 29,378

Closed Nondiscretionary+ 31,530 31,530 31,530 31,530 31,530

Closed Discretionary+ under the 1995 RMPs 287,900 0 0 0 0

Totals 319,430 232,367 226,388 246,583 239,185

+ Legal mandates establish non-discretionary closures while a discretionary closure is the result of an agency management 

decision. 

All the action alternatives open more land to salable mineral entry than the No Action alternative (the 

allocations driving these closures are in Table 3-101). Under the No Action alternative, 13 percent of the 

319,430

31,530 31,530 31,530 31,530

94,740 88,177 86,854 94,534

18,068 48,810 70,350

7,143 83,743

7,143

29,378

88,070 50,728

50,728

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

Land Closed to Salable Development (Acres)

Existing Closed ACEC RMA Suitable Wild Scenic Rivers Wilderness Characteristics
Chapter 3 – AE&EC – Minerals

397 | Page

decision area is closed to salable mineral entry, the majority in the Salem District. Under the action 

alternatives, the BLM would reduce the total acres closed to saleable minerals to 9 to 10 percent of the 

decision area. Data is not readily available to spatially display the areas closed to salable mineral entry 

under the No Action alternative, therefore a comparison map is not included in this analysis. Appendix L

lists each ACEC, RMA, lands managed for wilderness characteristics, and eligible WSRs closed to 

salable entry through this RMP revision. The overall percentage of closed acreage for each action 

alternative is similar, though the allocations driving the closures change across alternatives (Table 3-102). 

Compared to the No Action alternative, mineral materials would be slightly more available under the 

action alternatives, with Alternative B having the most acreage available. 

Table 3-102. Percentage of lands closed to salable mineral entry in the decision area. 

Land Category No Action 

(Percent) 

Alt. A 

(Percent) 

Alt. B 

(Percent) 

Alt. C 

(Percent) 

Alt. D 

(Percent) 

ACEC, RMA, Land managed for 

Wilderness Characteristics, Eligible 

WSRs 

- 8% 8% 9% 9%

Nondiscretionary Closure 1% 1% 1% 1% 1% 

Discretionary Closure under 1995 RMPs 12% - - - - 

Totals 13% 9% 9% 10% 10% 

Depending on the alternative, there are up to 19 developed rock quarries in allocations that the BLM 

would close to mineral development. Table 3-103 shows the number or quarry sites that are located in 

each land use category by alternative. 

Table 3-103. Number of rock quarries located in each land use category by alternative that would be 

closed to mineral development. 

Land Category No Action 

(Quarries) 

Alt. A 

(Quarries) 

Alt. B 

(Quarries) 

Alt. C 

(Quarries) 

Alt. D 

(Quarries) 

ACEC 8 6 6 6 6 

RMA - - 3 4 4 

Lands Managed for Wilderness 

Characteristics - 10 6 6 - 

Eligible Wild and Scenic Rivers - - - - 9 

Total Quarries 8 16 15 16 19 

Closing existing rock quarries prevents future use by the BLM, local governments, and the public, which 

may necessitate the development of new quarries elsewhere to offset the loss. Closing 15 to 19 quarries, 

depending on the alternative, could require the development of new sites, which could increase the cost 

and environmental footprint of quarry development or necessitate a long haul of rock material. In addition 

to this, there would be an effective loss of resources available for future use for each quarry closed. 

Appendix L contains the developed rock quarries by district and name within each ACEC, RMA, lands 

managed for wilderness characteristics and eligible WSRs closed to salable mineral development under 

the alternatives. 

Issue 2 

How would the alternatives affect the acres of land recommended for withdrawal from locatable mineral 

entry? 
Chapter 3 - AE&EC – Minerals

398 | Page

Summary of Analytical Methods 

The BLM identified by alternative the acres of land recommended for withdrawal from locatable mineral 

entry. The BLM assumed that areas recommended for withdrawal from locatable mineral entry under 

each alternative to be withdrawn for the purposes of this analysis. The BLM then ranked each ACEC, 

RMA, lands managed for wilderness characteristics and eligible WSRs that is recommend for withdrawal 

as high, medium or low. The ranking is based on geology, mining claim density, historic mines, 

prospects, and occurrences. This ranking can be used to determine the potential impacts to mineral 

development for each recommended withdrawal. Withdrawing areas ranked as high would 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. 

The BLM will not complete a formal mineral potential report for locatable minerals for this RMP 

Revision. Prior to actual withdrawal, the BLM must prepare a mineral potential report for each 

recommended withdrawal proposal. 

The BLM estimated the historic mineral occurrence and/or development for each ACEC, RMA, lands 

managed for Wilderness Characteristics and eligible WSRs that the BLM would recommend for 

withdrawal from locatable mineral entry under each alternative. For this evaluation, the BLM relied on 

the Mineral Resource Map of Oregon (1984) for geology, mineral deposits, and mining history and on 

LR2000 for the number of claims per quarter section of closed and active mining claims. The rankings are 

from high to low. 

High historic mineral occurrence or development areas are—

x Regions with historic major gold mining; 

x Areas with laterites and beach placers that contain more than ten active or closed mining 

claims; 

x Areas with favorable geology for mineral production and/or potential and containing more than 

ten active or closed mining claims; and 

x Areas with more than thirty active or closed mining claims. 

Medium historic mineral occurrence or development areas are—

x Areas with favorable geology for mineral production or potential;l 

x Areas with laterites, beach placers, and no mining claims; and 

x Areas with one to thirty active or closed mining claims. 

Low historic mineral occurrence or development areas are areas with no mining claims and that do not 

fall into the High or Medium categories. 

The Planning Criteria provides more detailed information on analytical assumptions, methods and 

techniques, and geographic and temporal scales, which the BLM incorporates here by reference (USDI 

BLM 2014, p.104). 

Background 

Locatable minerals include the metals gold, silver, copper, lead, zinc, nickel, and chromite and certain 

nonmetallic minerals determined to be uncommon, such as fluorspar and certain varieties of limestone. 
Chapter 3 – AE&EC – Minerals

399 | Page

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 at 43 CFR 3700 and 3800 establish procedures 

for locating mining claims, preventing unnecessary or undue degradation, compliance with Federal and 

State laws related to environmental protection, and performance standards. Surface Management 

Regulations from 43 CFR 3809 include that a Plan of Operations must be submitted for any operations 

causing surface disturbance greater that casual use in designated ACECs, areas in the National Wild and 

Scenic Rivers System, and areas designated as closed to OHV use (as defined in 43 CFR 8340.0-5). A 

Plan of Operations is subject to NEPA. 

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. These 

requirements include that after the date on which the lands are withdrawn, the BLM will not approve a 

Plan of Operations or allow notice-level operations to proceed until the BLM has prepared a mineral 

examination report to determine mining claim validity. Cost recovery applies to this process. Congress 

can designate withdrawals, or the BLM can undertake a withdrawal process ending with a decision signed 

by the Secretary of Interior. This RMP revision does not withdraw lands from locatable mineral entry. 

Affected Environment 

The planning area contains over 3,300 occurrences of locatable mineral resources and has a long history 

of mineral development (DOGAMI MILO). Mining claim records show that about 39,500 claims have 

been located on public lands in the planning area since BLM recording requirements began with the 

passage of FLPMA. The 1,045 active mining claims in the decision area attest to the ongoing interest in 

locatable minerals. 

Table 3-104 shows the number of active mining claims, Notices, and Pending or authorized Plan of 

Operation in the decision area by office. Figure 3-128 shows the general locations of active mining 

claims in the decision area. 

Table 3-104. 2013 Active mining claims, Notices, and pending or authorized Plans of Operation in the 

decision area. 

District/Field 

Office Active Mining Claims Notices Plans of OperationPending or Authorized 

Coos Bay 38 1 - 

Eugene 36 1 - 

Klamath Falls 1 - - 

Medford 840 24 10 

Roseburg 123 - 1 

Salem 7 1 - 

Totals 1,045 27 11 

Chapter 3 – AE&EC – Minerals

401 | Page

Table 3-105. Acres of lands previously withdrawn from locatable minerals. 

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 

Totals 98,400 

*2008 data from the Western Oregon Plan Revision EIS. 

Trends in locatable mineral developments and regulations are described in Appendix L. 

Environmental Effects 

Figure 3-129 and Table 3-106 show the acres that the BLM would recommend for withdrawal from 

locatable mineral entry by alternative for each ACEC, RMA, lands managed for wilderness 

characteristics, and eligible WSRs. The BLM did not rank existing withdrawals in this discussion, but 

included the existing acres. 

Figure 3-129. Acres that the BLM would recommend for withdrawal from locatable mineral entry by 

alternative and land category and previously withdrawn acres. 

 

98,400 98,400 98,400 98,400 98,400 

88,070 50,728 50,728 

17,714 

51,580 56,155 114,541 

64,838 58,621 57,558 64,556 

7,143 7,143 29,378 

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

Acres 

Eligible Wild and Scenic Rivers ACEC

RMA Lands Managed for Wilderness Characteristics

Existing Withdrawn
Chapter 3 - AE&EC – Minerals

402 | Page

Table 3-106. Acres the BLM would recommend for withdrawal from locatable mineral entry by 

alternative and previously withdrawn acres. 

Land Category No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

ACEC 64,838 58,621 57,558 64,556

RMA - 17,714 51,580 56,155 114,541

Lands managed for 

Wilderness Characteristics - 88,070 50,728 50,728 -

Eligible Wild Scenic Rivers - - 7,143 7,143 29,378

Totals 98,400 170,622 168,072 171,584 208,475

Under all action alternatives, the BLM would recommend increasing the lands withdrawn from locatable 

mineral entry; this increase would range from 168,050 acres under Alternative B to 208,475 acres under 

Alternative D (Table 3-106). About 4 percent of the 2.5 million acre decision area is currently withdrawn 

from locatable mineral entry (Table 3-107). The BLM would retain the previously withdrawn acres under 

all alternatives. Alternatives A, B, and C would increase the percentage of lands withdrawn by 6 percent, 

and Alternative D would increase the percentage of lands withdrawn by 8 percent. Withdrawing an 

additional 6-8 percent of the decision area could affect the development of locatable mineral resources. 

Table 3-107. Percentage of lands recommended for withdrawal to locatable mineral entry by alternative 

and land category including and percentage of previously withdrawn lands in the decision area. 

Land Category No Action

(Percent)

Alt. A 

(Percent)

Alt. B 

(Percent)

Alt. C 

(Percent)

Alt. D 

(Percent)

ACEC, RMA, LWC,

SWSR - 6% 6% 6% 8%

Previously Withdrawn 4% 4% 4% 4% 4%

Totals 4% 10% 10% 10% 12%

To understand better the effects of the recommended withdrawals, the BLM ranked the estimated historic 

mineral occurrence or development for the acres of land for each ACEC, RMA, lands managed for 

wilderness characteristics, and eligible WSRs that the BLM would recommend for withdrawal under each 

alternative. Figure 3-130 shows this ranking by alternative and the proportion of acres that fall into each 

mineral ranking category (High, Medium, Low). Existing withdrawals are not analyzed or ranked, but the 

acres are included in Figure 3-130. 
Chapter 3 – AE&EC – Minerals

403 | Page

Figure 3-130. Acres that would be recommended for withdrawal with mineral ranking of estimated 

prospective mineral occurrence or development for each land category by alternative (includes previously 

withdrawn acres). 

Figure 3-130 shows that the BLM ranks a substantial portion (38-65 percent) of the lands recommended 

for withdrawal as High for prospective mineral occurrence or development. Alternative A would 

recommend for withdrawal the greatest acreage of lands that ranked High (110,300) and Alternative D 

would recommend for withdrawal the least acreage of lands that ranked High (79,384). Removal of 

approximately 80,000-110,000 acres of these High ranked lands from locatable mineral exploration and 

development could have negative effect to development of known and undiscovered mineral resources. 

Appendix L for the estimated ranking of each ACEC, RMA, lands managed for wilderness 

characteristics, and eligible WSRs recommended for withdrawal from locatable mineral entry. 

An additional effect that would occur in association with withdrawing additional lands from locatable 

mineral entry is the reduction of revenue collected from public lands through mining claim fees to the 

government. To illustrate how withdrawal might affect fees, LR2000 records show there have been about 

3,500 mining claims located in the areas that the BLM would recommend for withdrawal from locatable 

mineral entry under the action alternatives. Using the current fee structure for mining claim location this 

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 affect 

existing claims, the public cannot file new claims in lands that are withdrawn from locatable mineral 

entry, resulting in no new fees collected. However, holders of existing claims would still pay maintenance 

fees if applicable. 

Issues considered but not analyzed in detail 

How would the alternatives affect the acres of land with fluid leasable mineral restrictions: no surface 

occupancy, conditional surface use, and timing limitations? 

98,400 98,400 98,400 98,400 98,400 

41,023 60,117 61,815 75,197 19,097 

23,317 25,442 

54,330 110,300 84,638 83,550 

79,384 

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

Acres Recommended for Withdrawal 

Existing Withdrawn Low Medium High
Chapter 3 - AE&EC – Minerals

404 | Page

The alternatives would impose proposed fluid mineral stipulations on each ACEC, RMA, lands managed 

for wilderness characteristics, and eligible WSRs. Table 3-108 shows the acres for which the BLM would 

propose stipulations across the alternatives. As show the no action alternative contains the most acreage 

with stipulations and alternative A the least. The differences in the action alternatives are due to the 

differing arrangements in each alternative of ACECs, RMAs, lands managed for 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 

Alternative acreages include all proposed stipulations which include specific stipulations, such as no 

surface occupancy or conditional surface uses based on resource protection needs. 

Table 3-108. Acres that would have leasable stipulations across alternatives in ACECs, RMAs, lands 

managed for wilderness characteristics, and eligible WSRs 

No Action 

(Acres)

Alt. A 

(Acres)

Alt. B 

(Acres)

Alt. C 

(Acres)

Alt. D 

(Acres)

Leasable stipulations 692,100* 190,389 211,638 318,915 498,525

* This includes only acres that are no surface occupancy 

Acreage not included in table above for the action alternatives are site-specific stipulations as needed to 

protect Federally-listed threatened and endangered species and their critical habitats 

The BLM will not complete a formal mineral potential report for leasable minerals for this RMP revision. 

Information regarding mineral potential reports and when they are required can be found in BLM manual 

3031. 

Site-specific stipulations, such as no surface occupancy, conditional surface uses, or timing restrictions, 

can be imposed on each lease as needed to protect other resource values, as identified in this RMP. The 

BLM is identifying such stipulations for certain areas, but since they do not prevent the development of 

some leasable minerals and only somewhat hinder development, there will be no foreseeable effects of the 

alternatives regarding mineral leasing of oil, gas, or Coalbed Natural Gas resources. The stipulation of no 

surface occupancy could impact geothermal resources; this resource is a part of the sustainability energy 

section of this document. 

Reasonably foreseeable mineral material developments and development guidance can be found in 

Appendix L.

References 

DOGAMI, MLRR. Online Oil & Gas Well Log Viewer. http://www.oregongeology.org/mlrr/oilgas-logs.htm#./oilgaslogs.htm?&_suid=140173381705803887908546260215.

Ferns, M. L., and D. F. Huber. 1984. Mineral Resources Map of Oregon, DOGAMI Geological Map 36, , scale 1:500,000.

Oregon Department of Geology and Mineral Industries (DOGAMI). 1982. Geothermal Resources of Oregon, 1 sheet, scale 

1:500,000.

Oregon Department of Geology and Mineral Industries (DOGAMI). 2010. Mineral Information Layer for Oregon (MILO, release 

2), geospatial database.

USDI BLM. Well Information System. https://www.blm.gov/wispermits/wis/SP.

---. 2008. Record of Decision and Resource Management Plan Amendments for Geothermal Leasing in the Western United 

States. FES-08-44.

---. 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.

---. 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. 
Chapter 3 – AE&EC – National Trails System

405 | Page

National Trails System 

Key Points 

x Regardless of the National Trail Corridor width, the BLM does not administer enough lands 

within the viewshed to protect the Pacific Crest National Scenic Trail resources and setting 

characteristics adequately. 

x Alternative D provides the largest National Trail Corridor and protects the greatest number of 

acres within the viewshed. However, these acres only account for 9 percent of all viewable acres. 

Issue 1 

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 trail corridors by alternative 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 BLM-administered lands to determine the percent of 

BLM-administered land within the trail’s viewshed. 

For the purposes of this analysis, the BLM assumed that its 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. Within the corridors, the BLM would: 

x Designate a Special Recreation Management Area 

x Manage for Visual Resource Management Class II 

x Designate as closed to off-highway vehicles 

x Close to recreational target shooting 

x Allow timber harvest activity only to protect or maintain recreation setting characteristics or to 

achieve recreation objectives 

x Apply a controlled surface use stipulation on surface occupancy and surface disturbing activities 

x Recommend for withdrawal from locatable mineral entry 

x Close to salable mineral development 

x Apply stipulations for leasables including no surface occupancy, controlled surface use, and 

timing limitations 

Pacific Crest National Scenic Trail Viewshed Analysis 

The Pacific Crest National Scenic Trail (PCT) viewshed is defined as the area within 5 miles of any point 

of the portion of the PCT that runs through BLM-administered lands (Figure 3-131). This definition is 

based on the assumption that the average traveler along the PCT has the ability to see 5 miles from any 

point along the trail. It should be noted that this 5 miles is a fixed distance and so the viewshed actually 

includes areas that are not visible from the trail. Thus, in addition to determining the acres of BLMadministered lands within the 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 Table 3-109. 

Chapter 3 – AE&EC – National Trails System

407 | Page

three trail classification types, as well as of the allocation through which agencies manage them and the 

specific trails that pass through the BLM-administered lands within the planning area. 

National Recreation Trail 

The Secretary of the Interior can designate National Recreation Trails within parks, forests, recreation 

areas, or where lands administered by the Department of the Interior are involved. These would be subject 

to the consent of the Federal agency, State, political subdivision, or other appropriate administering 

agency having jurisdiction over the lands involved. 

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. 

National Historic Trail 

Only Congress can establish National Historic Trails, which are extended trails which follow as closely as 

possible and practicable the original trails or routes of travel of national historic significance. Their 

purpose is to identify and protect historic routes and their historic remnants and artifacts for public use 

and enjoyment. 

National Trail Management Corridor 

A National Trail Management Corridor is a land use plan allocation which is based on Section 7(a)(2) of 

the National Trails System Act “rights-of-way.” The National Trail Management Corridor includes all 

public land area of sufficient width within which to encompass National Trail resources, qualities, values, 

and associated settings and the primary use or uses that are present or that the managing agency is to 

restore. For the purposes of this planning effort, National Trail Management Corridors include all BLMadministered lands containing resources, values, and associated settings that support the nature and 

purposes of a given National Trail. 

Other Federal lands, State trust lands, private land, or other interests in lands, including split estate, that 

contain National Trail resources, qualities, values, and associate settings and the primary use or uses are 

included in the National Trail Management Corridor. 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 or other instrument with the BLM. 

Pacific Crest National Scenic Trail 

The Pacific Crest National Scenic Trail (PCT) 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; its corridor through the U.S. 

travels through the states of California, Oregon, and Washington. The PCT 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. 
Chapter 3 - AE&EC – National Trails System

408 | Page

The PCT enters BLM-administered lands within the planning area from California along the crest of the 

Siskiyou Mountains east of Mt. Ashland and proceeds east towards Soda Mountain and then proceeds 

northeasterly along the western Cascades to the Rogue Siskiyou National Forest boundary. Hikers can 

access the PCT by numerous Federal, State, and county roads. Although the trail is easily accessible from 

numerous roads, the trail itself is closed to motorized and mechanized use. 

Table 3-110. Pacific Crest National Scenic Trail mileage by ownership within the decision area. 

Landowner Approximate Mileage

BLM 17.0

Private Lands 3.6

Private Timber Companies 7.1

State of Oregon 0.9

Totals 28.6

The main use of the BLM-administered segment of the PCT is for day hikes, primarily by residents of the 

Rogue Valley. The main recreational activity within the PCT on BLM-administered lands is hiking, 

followed by equestrian use. In addition to these activities, sightseeing, wildlife observation, photography, 

camping, and hunting occur. In the winter months, cross-country skiing occurs along the trail. The BLM 

estimates that day use along the BLM-administered segment of the PCT is approximately 25,000 visitors 

annually. 

The nature and purpose of the PCT 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 PCT is designed and managed to provide the most primitive recreational experience 

possible as identified through the BLM’s Recreation Opportunity Spectrum. The trail includes a 

permanently protected corridor that provides for the nature and purpose of the trail, including side and 

connecting trails as well as PCT-dependent facilities such as campsites, water sources, and viewpoints. 

Public lands within the trail corridor, including lands acquired and managed for the PCT, 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 PCT experience is managed 

cooperatively and seamlessly across unit and agency boundaries and with significant involvement of 

citizen stewards. 

California National Historic Trial-Applegate Trail Route 

The National Park Service is preparing a feasibility study to evaluate 41 routes for possible addition to the 

California National Historic Trail. The feasibility study evaluates eligibility of the study routes for 

potential inclusion into the National Trails System. Congress authorized this study under the Omnibus 

Public Land Management Act of 2009. Approximately 10.9 miles of the evaluated Applegate trail route 

are located on BLM administered lands within the planning area. Table 3-111 shows a mileage 

breakdown by ownership, within the planning area boundaries. 

Table 3-111. California National Scenic Trail mileage breakdown by ownership within the planning area. 

Landowner Approximate Mileage

Bureau of Land Management 10.9

Private Lands 405.0

Private Timber Companies 5.6

State of Oregon 5.0

Totals 426.5
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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 2,000 miles in length spanning across the western half of North 

America. The first half of the California 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 route just north of the Oregon and California border. 

The purposes of the California National Historic Trail are to enable all people to envision and experience 

the heritage and impacts 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, including those drawn as part of the California gold rush. 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. 

Figure 132 {omitted}

Affected Environment 

Pacific Crest National Scenic Trail 

The BLM’s Medford district currently manages the approximately 30 miles of the Pacific Crest National 

Scenic Trail that passes through as a Special Recreation Management Area (SRMA) The current SRMA 

plan established a 100-foot wide (50 feet off center-line) trail 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 protective trail corridor for the portion of the 

PCT that passes through the Klamath Falls Field Office. 


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setting, and primary uses because protective management direction does not exist and would not be 

applied to areas of the trail that pass through BLM-administered lands within the planning area. 

In all alternatives, the BLM would apply a 100-foot wide trail corridor (50-feet off centerline) along all 

portions of the California National Historic trail that cross BLM-administered lands within the planning 

area. This would result in adequate protection of National Trail resources, values, setting characteristics 

and primary uses for which the California National Historic trail is currently being studied. 

Pacific Crest National Scenic Trail 

The BLM would establish a National Trail Corridor on the 17 miles of the Pacific Crest National Scenic 

Trail (PCT) that crosses BLM-administered lands within the planning area. This corridor width would 

vary across alternatives. In this analysis, the BLM considers the effects of these widths on PCT resources, 

values, recreation setting, and primary uses. 

Table 3-112 shows the percentage of visible acres present in the PCT corridor by alternative. This table 

also shows the total acres of BLM-administered lands visible from the BLM portion of the PCT within 

the planning area by alternative. 

Table 3-112. Percent of total and visible acres of BLM-administered lands within Pacific Crest Trail 

corridor by alternative. 

Areas No Action Alt. A Alt. B Alt. C Alt. D

Trail corridor width 100 feet 500 feet 0.25 mile 1 mile 2 miles

BLM lands within the corridor (Acres) 411 526 737 1,355 2,453

BLM lands within the corridor (% of all 

lands) 97.1% 81.2% 56.1% 30.4% 30.9%

BLM lands within the 5-mile viewshed and

within the corridor (% of all lands) 0.4% 0.9% 0.7% 3.6% 8.0%

BLM lands visible within 5 miles of the 

corridor (% of all visible lands) 1.5% 1.9% 1.3% 4.9% 8.8%

Regardless of the National Trail Corridor width, the BLM does not administer enough lands within the 

viewshed to protect PCT resources and setting characteristics adequately. Under the most protective 

Alternative (Alternative D), the BLM would administer only 8.8 percent of the total visible acres within 

the viewshed. Management activities that result in visual impacts could take place on the 90 percent of the 

viewshed that the BLM does not administer resulting in impacts to the setting characteristics that are 

beyond the BLM’s control. 

No Action Alternative 

Under the No Action alternative, the BLM would continue to provide a 100-foot trail management 

corridor off centerline (50 feet on each side) on the Pacific Crest Trail (PCT). This would result in the 

protection of 411 acres of BLM administered lands along the 17-mile segment of the PCT included in this 

analysis. Compared to the acres of visible lands from the PCT (6,464 acres), the No Action alternative 

would preserve 7 percent of the visible BLM-administered lands from the PCT 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 PCT’s resources when 

compared with all action alternatives. 
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Alternative A 

Under Alternative A, the BLM would establish a 500-foot trail management corridor off the centerline 

(250 feet on each side) on the PCT. This would result in the protection of 526 acres of visible BLMadministered lands along the 17-mile segment of the PCT included in this analysis. Alternative A would 

protect 8 percent of the 6,464 acres of BLM-administered lands that are visible from the PCT using the 

protective management direction described in the methods section. 

Alternative A provides greater protection to the PCT’s resources when compared with the No Action 

alternative and less protection when compared to Alternatives B, C, and D. 

Alternative B 

In Alternative B, the BLM would establish a 1/4 -mile trail management corridor off the centerline on the 

PCT. This would result in the protection of 737 acres of BLM-administered lands along the 17-mile 

segment of the PCT included in this analysis. Alternative B would protect 11 percent of the 6,464 acres of 

BLM-administered lands that are visible from the PCT using the protective management direction 

described in the methods section. 

Alternative B provides greater protection than the No Action alternative and Alternative A, and less than 

Alternatives C and D. 

Alternative C 

In Alternative C, the BLM would establish a 1-mile trail management corridor off the centerline (1/2 mile 

on each side) on the PCT. This would result in the protection of 1,355 acres of visible BLM-administered 

lands along the 17-mile segment of the PCT included in this analysis. Alternative C would protect 21 

percent of the 6,464 acres of BLM-administered lands that are visible from the PCT using the protective 

management direction described in the methods section. 

Alternative C provides greater protection than the No Action alternative and Alternatives A and B and 

less than Alternative D. 

Alternative D 

In Alternative D, the BLM would establish a 2-mile trail management corridor off the centerline (1 mile 

on each side) on the Pacific Crest Trail (PCT). This would result in the protection of 2,453 acres of BLMadministered lands along the 17-mile segment of the PCT included in this analysis. Alternative D would 

protect 38 percent of the 6,464 acres of BLM-administered lands that are visible from the PCT using the 

protective management direction described in the methods section. 

Alternative D provides the greatest level of protection to the PCT’s resources compared to the other 

alternatives. Alternative D provides five times the level of protection as the No Action alternative. 

 
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Rare Plants and Fungi 

Key Points 

x Only two Federally-listed plant species potentially occur within the Harvest Land Base under all 

alternatives: Kincaid’s lupine and Gentner’s fritillary. Under all alternatives, the BLM would 

conduct pre-disturbance surveys and apply conservation measures for these two species. 

x The six Federally-listed plant species and one Federal candidate plant species within the decision 

area are shade-intolerant. 

x The BLM would manage Bureau Sensitive plant and fungi species under the BLM’s Special 

Status Species program under all alternatives. However, under Alternative D, the BLM would 

manage these species on O&C lands only in such a way that would not conflict with sustainedyield timber production. 

x None of the action alternatives would include the Survey & Manage standards and guidelines. 

Under all action alternatives, species that are currently Survey & Manage and not included on the 

Bureau Sensitive species list would receive no specific protections. 

x All action alternatives allocate more acres to Late-Successional Reserve than the No Action 

alternative, which would benefit rare plants and fungi associated with mature and structurallycomplex forest. 

Background 

There are 269 special status plant and fungi species within the planning area: 179 vascular plants, 41 

bryophytes (mosses and liverworts), 22 lichens, and 27 fungi. Included on the Special Status Species list 

are Federally-listed, proposed, and candidate species, and Bureau Sensitive species. 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 State Directors also can designate species known or 

suspected to occur on BLM-administered land that botanists know little about as Bureau Strategic, a

tracking or “watch list” category that is not part of the Special Status Species program. 

Of the 269 plant and fungi Special Status Species within the planning area, there are 178 documented 

species on BLM-administered land. The remaining 91 speciesare suspected or likely to occur on BLMadministered lands. These suspected species are included on the Special Status Species list because 

known sites occur nearby, their range coincides with the planning area, or suitable habitat exists on BLMadministered land. 

Separate from the Special Status Species program, little known species thought to be associated with latesuccessional or old-growth forests currently receive special management attention under the Survey & 

Manage measures (USDA FS and USDI BLM 1994). Some, but not all, of the Survey & Manage species 

qualify for inclusion on the Bureau Sensitive species list. Of the 241 Survey & Manage species within the 

planning area, 47 are also on the Bureau Sensitive list and an additional 65 are on the Bureau Strategic 

list. 
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Distribution, Habitat, and Biology 

The planning area is vegetatively diverse due to the physical geography of the area and it falls within five 

of the Level III ecoregions65 mapped by the Environmental Protection Agency: Willamette Valley, Coast 

Range, Cascades, Klamath Mountains, and Eastern Cascades Slopes and Foothills (Omernik and Griffith 

2012). 

Within the State of 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 (e.g., crinite mariposa lily (Calochortus coxii)) are strictly associated with serpentine soils that 

occur in the planning area within the Klamath Mountains ecoregion (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 

construction of roads). 

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 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 M). The figure in Appendix M 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 Special Status Species sites 

based upon current data. Both Table 3-113 and 3-114 indicate that the greatest abundance and density of 

Special Status plant species within the planning area is within the Medford District. This is because the 

Medford District lies primarily within the Klamath Province that 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 3-113. Plant and fungi sites by status and taxonomic group. 

District/

Field Office 

Bureau Sensitive (# of Sites) Bureau Strategic (# of Sites) 

Totals Bryophytes Lichens Vascular 

Plants Fungi Bryophytes Lichens Vascular Plants Fungi 

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 

 

65 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 3-10 or Figure 3-123. 
Chapter 3 - AE&EC – Rare Plants and Fungi

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Table 3-114. Special Status, Strategic, and Survey & Manage sites documented between January 2009 

and July 2013. 

District/Field Office Special Status

(# of Sites)

Strategic

(# of Sites)

Survey & Manage

(# 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. From January 2009 to July 2013, the BLM 

surveyed approximately 121,297 acres within the decision area and found a total of 226 new Special 

Status Species sites, 88 new Strategic Species sites, and 180 new Survey & Manage species sites. On 

average, this works out to be one new Special Status, Strategic, or Survey & Manage site for every 246 

acres surveyed. However, BLM found the majority of the new sites within the Medford District with 92 

percent of the Special Status sites, 84 percent of the Strategic sites, and 52 percent of the Survey & 

Manage sites. The detection rate for the Medford District was one new site for every 128 acres surveyed, 

while the detection rate for the Eugene District was much less with one new site found for every 1,248 

acres surveyed. During this period, surveyors did not document any new sites within the Klamath Falls 

Field Office. 

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 produce sporocarps everywhere that they may occur, and the 

sporocarps are usually present for a short time. Most of the Special Status and Survey & 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). Visual observation cannot determine the size of a genetic individual 

or a population of a fungal species. The plant community composition gives an indication of the fungal 

community under the surface. The plant community influences the development of mycorrhizal 

populations (i.e., when the aboveground vegetation changes, the fungal community changes with it). 

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 Table 3-114 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, 

noxious weed treatments). 
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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, 

including aquatic, riparian, rock, and terrestrial. Generally, botanists understand the habitats associated 

with rare vascular plants. Bryophytes and lichens are associated with a variety of habitats including 

conifer trees, rock, soils, and riparian areas, although primarily in conifer and hardwood communities. 

Many of these species are closely associated with a particular substrate, habitat condition, and 

environment. Fungi occur in a number of forms. Most are mycorrhizal and usually associated with host 

species in conifer and hardwood forest communities. The habitat characteristics for many rare lichen and 

bryophyte species are less certain and more conceptual than those for vascular plants. Fungi have even 

less certain habitat characteristics than the lichens and bryophytes. The habitat groups discussed later in 

this section organize BLM Special Status Species into broad habitat types based on current understanding. 

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. When the vascular plant community changes, the 

mycorrhizal fungi also change. 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 

fungal species richness, (i.e., the larger the clearcut, the greater the impact to the mycorrhizal fungal 

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 (Kranabetter and Kroeger 2001, Luoma and Eberhart 

2005, Miller et al. 1998, Wiensczyk et al. 2002). 

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 

and cause 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. These include the following: 

x Type, extent, duration, and intensity of the disturbance 

x Frequency and season of the disturbance 

x Habitat and life-cycle requirements of a species 
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x Adaptability of a species to a changed environment 

Some rare plant species (e.g., Bradshaw’s desert-parsley) are adapted to frequent, low-intensity fires and 

respond positively in most cases (Kaye et al. 2001). Species such as Gentner’s fritillaria 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 wildfire. 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 juncus and sedge species associated with streams 

and wetlands are adapted to periodic floods by prolific seed production. 

Federally-Listed Species 

There are twelve Federally-listed and one candidate plant species that occur or have occurred historically 

within the planning area. The BLM has documented seven of these species within the decision area:

Gentner’s fritillary, western lily, Cook’s lomatium, rough popcorn flower, Kincaid’s lupine, Nelson’s

checker-mallow, and Siskiyou mariposa lily. The U.S. Fish and Wildlife Service has designated critical 

habitat for four of the Federally-listed plants: Willamette Valley daisy, large-flowered wooly meadowfoam, Cook’s lomatium, and Kincaid’s lupine. The U.S. Fish and Wildlife has completed recovery plans 

for all of the Federally-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, thus making positive identification of newly discovered sites difficult. 

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 one new Gentner’s fritillary site 

for every 4,400 acres surveyed in suitable habitat. Most sites are very small – 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 on BLM-administered lands within the decision area. 

There are an additional 36 sites within the Cascade Siskiyou National Monument, which is outside of the 

decision area. Gentner’s fritillary occurs within nine livestock grazing allotments. The Medford District 

has surveyed all suitable habitats within grazing allotments, and populations generally occur on steeper 

slopes outside of riparian areas where cattle use is light. Botanists monitor the effects of grazing on 

Gentner’s fritillary and there is little evidence of direct grazing or trampling by cattle (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 
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habitats: freshwater wetlands, coastal prairie and scrub, and the edges of Sitka spruce forest. The single 

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 has yet to flower as of 2014 (Guerrant 2006, as cited in 

USDI FWS 2009). 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 

BLM populations are in and adjacent to the French Flat Area of Critical Environmental Concern. Rural 

development, illegal refuse dumping, and recreational use threaten Cook’s lomatium habitat in the Illinois 

Valley. Illegal uses such as OHV trespass and refuse dumping occasionally damage sites on BLM, 

although the use of barricades and law enforcement efforts have successfully reduced effects in recent 

years (R. Showalter, BLM, personal communication, 2014). BLM does not authorize livestock grazing of 

any habitats containing Cook’s lomatium, eliminating effects from livestock grazing. 

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 within the Roseburg 

District. There are no naturally occurring populations of rough popcorn flower on BLM-administered 

land. 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 

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 planning 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 10 

Kincaid’s lupine sites known to occur in the decision area. In addition, there are five sites on BLMadministered land within the West Eugene Wetlands, which is outside of the planning area. Within the 

decision area, there is designated critical habitat on BLM lands only within the West Eugene Wetlands. 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. 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 

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 planning 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, 
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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 land, 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 is another 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 BLM site consists of one to five 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 

on BLM-administered lands: Applegate’s milk-vetch, Willamette Valley daisy, large-flowered wooly 

meadow-foam, 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 land in the planning area, and the species is unlikely to occur on BLM-administered land 

within the Klamath Falls Field Office (R. Currin, USFWS, personal communication, 2014, and J. 

Blanchard, personal communication, 2014). 

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 land 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, 
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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 

The BLM designed the Special Status Species program to conserve rare species and their habitats, 

promote their conservation, and reduce the likelihood and need for species to be listed under the 

Endangered Species Act. BLM Manual 6840 (Special Status Species Management; USDI BLM 2008) 

provides policy guidance and includes specific implementation actions such as surveying BLMadministered land for Special Status Species, monitoring Special Status Species populations and habitats, 

and developing conservation strategies to meet these program objectives. 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” (USDI 

BLM 2008). The Special Status Species policy directs each BLM State Director to establish Special 

Status Species lists. 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 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 two 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 Special 

Status Species. The Affected Environment section below summarizes results of these surveys. 

Survey & Manage 

The Northwest Forest Plan and the 1995 RMPs include the Survey & 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 & Manage, Protection Buffer, and other 

Mitigation Measures Standards and Guidelines and the 2004 Final Supplemental EIS to Remove of 

Modify the Survey & Manage Mitigation Measure Standards and Guidelines discussed the origin and 

implementation of the Survey & 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 & 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 & 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 & Manage measures. 
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There are six categories of Survey & Manage species that are found in the planning area (Table 3-115).

The categories consider species relative rarity, their level of association with late-successional/old-growth 

forests, and if pre-disturbance surveys are practical (Table 3-116). Strategic surveys are landscape-scale 

surveys designed to collect information about a species, including its presence and habitat, and are 

required for all Survey & Manage species. For Category A and C species, pre-disturbance surveys are 

required. The Survey & 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 & 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). 

“Equivalent effort” surveys are required for two lichens, four bryophytes, 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, multispecies 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 & 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 and USDI 2011). 

Table 3-115. Number of Survey & Manage species by taxonomic group and category found within the 

planning area (2003 list). 

Taxa Group Survey & Manage Categories Totals A C B D E F

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

Table 3-116. Survey & 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

Oak Woodland 

Oak woodlands represent a special habitat within the decision area. While oak species in Oregon are not 

special status, their habitat is rare and vulnerable to destruction from development, conversion to conifer 

forest, and high-intensity fire. 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 ranges (Quercus kelloggii) 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 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, natural fire and frequent, low intensity burning by Native 
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Americans limited the extent of coniferous forests and sustained fire-tolerant oak savannah and 

woodlands (Devine and Harrington 2006, Gould et al. 2011, Klamath Bird Observatory and Lomakatsi 

Restoration Project 2014, Tveten and Fonda 1999). Lack of fire in oak communities has resulted in the 

invasion 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 (Fire and 

Fuels). 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 

significant during the first five years after release. 

Issue 1 

How would management activities (such as timber harvest, livestock grazing, and mineral development) 

affect Special Status plant and fungi species, current Survey & Manage species, and special habitats? 

Summary of Analytical Methods 

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 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. These 

compounding uncertainties complicate the analysis of effects on rare plant and fungi species at this scale 

of planning. 

The BLM used species occurrence data where it was available to evaluate the effects of management 

activities. Botanists have surveyed only a portion of BLM-administered lands within 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. 

Because there is generally little existing information available 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. As discussed in the background section, fungi are especially difficult to detect even 

with repeat visits. The BLM assumed that the surveys for rare fungi will be opportunistic in nature. 

Targeted, repeat surveys for fungi would only occur under the No Action alternative where equivalenteffort fungi surveys are required. 

Under Alternative D within the Harvest Land Base, the BLM would rely on existing information and 

habitat evaluations to assess the site-specific effects of timber management activities on Bureau Sensitive 

species. 

Timber Harvest and other Vegetation Management 

In this analysis, 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 
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possible to identify differences in effects among the alternatives at this scale of analysis with the data 

available. 

Timber harvest methods (clearcuts, regeneration harvest with retention, uneven-aged management, 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, the BLM in this analysis evaluated the relative magnitude of 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 

relative difference in management activity levels among alternatives. The BLM evaluated the overall 

acreage of all timber harvest methods by alternative. The BLM assumed that clearcut harvest would have 

a greater magnitude of effect 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. 

The BLM assumed in this analysis that mature, multi-layered canopy and structurally-complex forest 

provides habitat for rare fungi. The BLM specifically evaluated effects on rare fungi based on the acreage 

of mature, multi-layered canopy and structurally-complex forest within the Harvest Land Base under each 

alternative. 

The BLM evaluated how the Harvest Land Base overlaps with rare plant and fungi habitat and known 

sites under each alternative. The BLM assumed that timber activities would not affect Survey & Manage 

plant and fungi sites directly in the No Action alternative because of pre-disturbance surveys and site 

protection. The BLM assumed that sensitive plant and fungi sites would not be directly affected by timber 

activities under any alternative except Alternative D, because of pre-disturbance surveys for plant species 

and site protection for all sensitive species. Under Alternative D, some sites within the Harvest Land Base 

would be directly affected by timber harvest, because the BLM would protect known sites on O&C lands 

only where protection would not conflict with sustained-yield timber production. The BLM assumed that 

under Alternative D, there would be no additional pre-disturbance surveys for timber harvest. For the 

purposes of this analysis, the BLM assumed that sites within the Harvest Land Base of Survey & Manage 

species that are not Bureau Sensitive would eventually be lost because of timber harvest under the action 

alternatives. The BLM assumed that changes to their habitat from timber harvest under all alternatives 

could indirectly affect rare plant and fungi species, such as through the introduction or spread of invasive 

species. 

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 over 50 years. 

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 (Berch et al. 2006, Ryden et al. 1997). 

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
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Wildland Urban Interface (Fire and Fuels and Forest Management). These treatments would affect 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 species depends. However, prescribed 

burning rarely would consume soil duff, large logs, or snags. An indirect effect of prescribed burning is 

the potential increase in non-native species due to 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, Giles-Johnson et al. 

2010, USDI FWS 2006 and 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. 

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 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). 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 cattle do not stray far from water. Heavy trampling 

disturbance occurs around holding pens, water sources, salt blocks, and trails between favored 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 

grazing in each alternative. Additionally, the BLM considered the presence of Federally-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. 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. 
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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. 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 directly removes all 

vegetation in the construction zone, increases water runoff on the compacted or hardened surface 

resulting in increased soil erosion adjacent to the road, fragments habitat, creates a conduit for the 

introduction of noxious and non-native invasive plants, and increases the potential for off-highway 

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 Soil Resources). 

Off-highway Vehicle Use 

In this analysis, the BLM assumed that areas allocated as open for off-highway vehicle (OHV) use would 

experience habitat removal and disturbance for rare plants and fungi. Where cross-country travel occurs, 

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 allow for the introduction and dispersal of noxious and non-native weed species. 

In this analysis, the BLM assumed that OHV users would operate vehicles consistent with BLM decisions 

about OHV use. Although the BLM has some site-specific and anecdotal information about illegal OHV 

use, the BLM does not have a basis for predicting the location or effects of any widespread or systematic 

illegal OHV use. In addition, much of the decision area has physical limitations to potential illegal OHV 

use, including dense vegetation, steep slopes, and locked gates. In most of the interior/south, the ability to 

track numerous different routes across the open spaces can lead to degradation and erosion in a greater 

proportion than most of the coastal/north. However, the BLM lacks a basis for characterizing current 

illegal OHV use or forecasting such potential illegal OHV use in the future under any of the alternatives 

at this scale of analysis. 

Areas designated as closed would not experience habitat disturbance for rare plants and fungi, because the 

BLM would not permit OHV use. Areas designated as limited would not experience measurable 

additional habitat disturbance for rare plants and fungi, because the BLM would limit off-highway 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 planning, the BLM cannot identify which routes any alternative would design. 

Therefore, the BLM cannot quantify more site-specific effects in this analysis, and implementation level 

decisions would address these effects. 

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. 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 

assumed in this analysis that the mileage of new road construction would be indicative of the amount of 

quarry activities, including the expansion of existing sites and the development of some number of new 

sites. In addition, the BLM also considered the effects of quarry activities on rare plants and fungi based 

on the acreage closed to salable mineral development under each alternative. 

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. 
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The BLM assumed that locatable mineral development 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. 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 development. 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 allow for consideration of Federally-listed or proposed species, but not 

for other BLM Special Status Species; therefore, some Special Status Species sites would likely be 

extirpated and occupied habitat would be destroyed as a result of equipment operations and ground 

disturbance. 

Affected Environment 

There are 213 known sites of Federally-listed plants on BLM-administered lands within the planning area 

(Table 3-117). Most occupied sites of the Federally-listed species are very small: approximately 74 

percent of all sites occupy 1/10th of an 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. 

 
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Table 3-117. Federally-listed plants within the BLM-administered lands in the planning 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 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 planning 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 checker-mallow Sidalcea nelsoniana 1 Salem Within the Walker Flat ACEC

Candidate

Siskiyou mariposa lily Calochortus 

persistens 1 Medford Species mostly known from northern California

Total 213

There are 4,564 known sites of Bureau Sensitive and Strategic plant and fungi species on BLMadministered lands in the planning area (Table 3-113). Sites range in size from just one or a few 

individuals that occupy much less than 1/10th 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 one acre. 

The BLM has conducted Survey & 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. These surveys found 619 sites 

during this period, an average of one new site for every 9.8 acres surveyed within potential habitat. The 

Salem District conducted equivalent-effort fungi surveys on two acres and did not find any fungi. 

There are currently 862,408 acres of mature, multi-layered canopy or structurally-complex forest, which 

provides potential habitat for rare plants and fungi that are associated with late-successional and old 

growth habitat. 
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Oak woodland and savanna are limited within the planning area. Within the decision area, Oregon white 

oak woodland and savannah occur primarily in the Roseburg and Medford Districts and the Klamath Falls 

Field Office; however, oaks occur in all of the officeswithin the decision area. 

Environmental Effects 

Under all alternatives, the BLM would—

x Manage Federally-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; 

x Conduct surveys for Federally-listed and candidate plant and fungi species on BLMadministered land with suitable habitat; 

x Maintain or restore natural processes, native species composition, and vegetation structure in 

natural communities outside of the Harvest Land Base through prescribed fire, thinning, 

removal of encroaching vegetation, retention of legacy components (e.g., large trees, snags, 

and down logs), and planting or seeding native species; 

x Use only species native to the plant community when re-vegetating degraded or disturbed 

areas; and 

x Retain or reconnect the hydrologic flows to wetlands. 

The alternatives vary in the approach to pre-disturbance surveys for and management of known sites of 

Bureau Sensitive and Survey & 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 would 

conserve known sites 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 pre-disturbance surveys for Survey & Manage species where appropriate 

and would manage known Survey & Manage sites through implementation of the Survey & Manage 

standards and guidelines. None of the action alternatives would require pre-disturbance surveys or site 

management for Survey & Manage species that are not included on the Bureau Sensitive species list. 

Under Alternatives A and C, the BLM would take actions to contribute toward the recovery of Federallylisted 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 Federally-listed species 

and to increase the overall resiliency of other Special Status Species to reduce the risk of extirpation. 

Under Alternative B, the BLM would manage mixed hardwood and 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 and conifer communities, they are likely 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. 

The two Federally-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. More sites of 

these species occur within the Harvest Land Base under all of the action alternatives than under the No 

Action alternative. However, the BLM would conduct pre-disturbance survey and apply the same 

conservation measures for these Federally-listed species under all alternatives, regardless of land use 
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allocation. Therefore, the species-specific protections for these species would avoid adverse effects from 

timber harvest similarly under all alternatives. 

In the No Action alternative and Alternatives A, B, and C, 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 currently known Special Status and Strategic plant and fungi sites that would occur within 

the Harvest Land Base under each alternative are listed in Table 3-118. 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. However, there is no basis 

for predicting a difference in effects between the No Action alternative and Alternatives A, B, and C. 

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. Also, 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. 

Table 3-118. Special Status and Strategic plant and fungi sites within the Harvest Land Base. 

Alternative Taxa Group Federal 

Endangered

Federal 

Threatened Sensitive Strategic Totals

No Action

Bryophytes - - 10 22 32

Lichens - - 110 300 410

Vascular 15 1 1,287 9 1,312

Fungi - - 99 219 318

Totals No Action 15 1 1,506 550 2,072

Alt. A

Bryophytes - - 8 6 14

Lichens - - 95 80 175

Vascular 25 7 490 6 528

Fungi - - 92 44 136

Totals Alt. A 25 7 687 136 853

Alt. B

Bryophytes - - 4 16 20

Lichens - - 75 184 259

Vascular 54 7 904 6 971

Fungi - - 112 166 278

Totals Alt. B 54 7 1,095 372 1,528

Alt. C

Bryophytes - - 8 20 28

Lichens - - 115 201 316

Vascular 57 8 893 8 966

Fungi - - 117 172 289

Totals Alt. C 57 8 1,133 401 1,599

Alt. D

Bryophytes - - 10 25 35

Lichens - - 122 224 346

Vascular 46 8 1,066 7 1,127

Fungi - - 101 102 203

Totals Alt. D 46 8 1,299 358 1,711
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There are 2,719 currently known Sensitive, Strategic, and Survey & Manage fungi sites within the 

decision area. Under all alternatives, the majority of known sites of rare fungi would be within Reserve 

land use allocations. Table 3-119 shows the number of known fungi sites within the Harvest Land Base 

under each alternative 

Table 3-119. Number of Special Status and Survey & Manage fungi sites within Harvest Land Base by 

alternative. 

Alternative Sensitive 

(# of Sites) 

Strategic 

(# of Sites) 

Current Survey & Manage 

Species (# of Sites) (Percent of 

Known Sites in Decision Area)* 

All Species (# of Sites) 

(Percent of Known 

Sites in Decision Area) 

No Action 99 219 1,045 (38%) 1,363 (50%) 

Alt. A 92 44 482 (18%) 618 (23%) 

Alt. B 112 166 721 (27%) 999 (37%) 

Alt. C 117 172 900 (33%) 1,189 (44%) 

Alt. D 101 102 765 (28%) 968 (36%) 

* Sites of Survey & Manage species that are not also Sensitive or Strategic 

Under the No Action alternative, the BLM would continue to implement Survey & Manage measures to 

conduct pre-disturbance surveys and protect known sites for the Survey & Manage species. Most Survey 

& 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 & Manage plant and fungi species would increase under the No Action 

alternative in the decision area. 

Under all action alternatives, species that are currently Survey & Manage and not included on the Bureau 

Sensitive species list would receive no specific protections under the action alternatives. The number of 

unprotected sites would vary by alternative: Alternative A would have the fewest sites within the Harvest 

Land Base, and Alternative C would have the largest (Table 3-120). Unless these sites co-occur with 

Sensitive species, timber harvest would affect these sites. 

 
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Table 3-120. Current Survey & Manage species sites within the Harvest Land Base. 

Alternative Taxa Group

Current Survey & Manage Species

that are not also Sensitive or Strategic

(# of Sites)

No Action

Bryophytes 379

Lichens 428

Vascular Plants 278

Fungi 1,045

No Action Totals 2,130

Alt. A

Bryophytes 97

Lichens 172

Vascular Plants 58

Fungi 482

Alt. A Totals 809

Alt. B

Bryophytes 205

Lichens 341

Vascular Plants 222

Fungi 721

Alt. B Totals 1,489

Alt. C

Bryophytes 221

Lichens 435

Vascular Plants 193

Fungi 900

Alt. C Totals 1,749

Alt. D

Bryophytes 235

Lichens 378

Vascular Plants 202

Fungi 765

Alt. D Totals 1,580

There is incomplete and unavailable information relevant to the effects of the action alternatives on 

Survey & Manage species. With complete and species-specific survey information on the location of 

habitat and species sites for all Survey &Manage species, the BLM would be able to analyze the effects of 

all alternatives on Survey & Manage species and compare the effects under each action alternative to the 

No Action alternative, which would continue to implement the Survey & Manage measure. However, the 

BLM lacks complete and species-specific survey information for most Survey &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 & 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 on Survey & Manage species. The 

2004 Final SEIS to Remove or Modify the Survey & 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 & Manage 

measures for known site management and pre-disturbance surveys, and that analysis is incorporated here 

by reference. However, 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 

EIS was insufficient to support the conclusion that the Survey & Manage measure was no longer 

necessary to meet the goals of the Northwest Forest Plan. Nevertheless, the information in the 2004 SEIS 

and 2007 SEIS does present analysis based on the incomplete survey information available that concludes 
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that most Survey & Manage species would have sufficient habitat to support stable populations under the 

No Action alternative without the Survey & Manage measure. 

Even in the absence of the Survey & Manage measure, habitat and sites of species that fall within the 

reserve system would receive protection. Compared to the No Action alternative, all action alternatives 

allocate more acres to the Late-Successional Reserve, which the Northwest Forest Plan expected to meet 

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 & Manage measure 

would provide sufficient habitat for Survey & Manage species, as analyzed in the 2004 SEIS, the action 

alternatives would provide additional habitat within the Late-Successional Reserve. 

The Survey & Manage species are species associated with “late-successional and old-growth forests”

(USDA FS and USDI BLM 2000, p. 8). To the extent that older and more structurally-complex multilayered conifer forests as defined in the action alternatives encompass the “late-successional and oldgrowth forests” that provide habitat for Survey & Manage species, all action alternatives reserve such 

forests from timber harvest within the Late-Successional Reserve. Under all action alternatives, there 

would be no timber harvest of older and more structurally-complex multi-layered conifer forests, although 

each alternative uses a different definition to identify older and more structurally-complex multi-layered 

conifer forests. Therefore, all of the action alternatives, in contrast to the No Action alternative, would 

protect from timber harvest the forest conditions with which the Survey &Manage species are 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 than older and more 

structurally-complex multi-layered conifer forests) in the decision area would increase under all 

alternatives. Therefore, the amount of habitat for Survey & Manage plant and fungi species would 

increase under all alternatives. 

In summary, all action alternatives would remove the Survey & Manage measure that requires predisturbance surveys and protection of known sites. There is incomplete and unavailable information 

relevant to the effects of the action alternatives on Survey & Manage species. The 2004 Final SEIS 

provides an incomplete analysis, but supports the conclusion that most Survey & Manage species would 

have sufficient habitat to support stable populations under the No Action alternative without the Survey & 

Manage measure. All action alternatives allocate more acres to the Late-Successional Reserve than the No 

Action alternative, protect older and more structurally-complex multi-layered conifer forests, and would 

result in an increase in mature and structurally-complex forest. As a result, and in light of the incomplete 

information available to the BLM, all action alternatives would protect most existing habitat for Survey & 

Manage species and would result in an increase in the amount of habitat for Survey & Manage species. 

A sub-group of more than 25 lichen, bryophyte, and fungi species (including Special Status Species and 

current Survey & Manage species that are not Special Status Species) is associated with habitat conditions 

and forest biological legacy (green trees, coarse wood, and snags) of mature and structurally-complex 

forests. Important habitat components include coarse wood, snags, and specific host species. 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 greatest under Alternative C, with 

176,696 acres of total timber harvest, and only slightly lower under Alternative B, with 162,764 acres of 

timber harvest (Table 3-121). Alternative D and the No Action alternative would have substantially lower 

acreage of total timber harvest, with 139,151 acres and 111,260 acres, respectively. Alternative A would 

have the lowest acreage of total timber harvest, with 91,782 acres in the first decade. Included in that total 
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for Alternative A is 13,425 acres of restoration thinning without timber extraction, 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. 

Table 3-121. Total acres of timber harvest in the first decade (2013-2023) by alternative. 

Harvest Type No Action

(Acres)

Alt. A

(Acres)

Alt. B

(Acres)

Alt. C

(Acres)

Alt. D

(Acres)

Clearcuts - 47,644 - 93,935 -

Salvage 3,493 1,086 2,954 4,160 1,973

Selection - 26,179 67,516 44,464 104,569

Thinning 107,767 3,448 54,362 34,137 7,030

Thinning without Timber Extraction - 13,425 - - -

Two-Age - - 37,932 - 25,579

Total Timber Harvest 107,767 91,782 37,932 176,696 25,579

Under Alternatives A and C, forest management would include clearcuts (i.e., regeneration harvest with 

no retention) in the High Intensity Timber Area, which comprises 12 percent and 22 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, 93,935 acres and 47,644 acres, respectively (Table 3-121). Early-successional 

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 earlysuccessional species on each harvest unit. 

The impacts from salvage harvest would generally 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 lost, making the effects of salvage 

similar among all alternatives. 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, salvage would take place in the Harvest Land Base after a high or moderate severity fire 

event. In all alternatives except for Alternative C, 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 Late-Successional Reserves 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 occur on a relatively small acreage under all alternatives, approximately 1 to 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 forests in the first decade, increasing the likelihood of 

reducing habitat quality for rare plants and fungi associated with mature and structurally-complex forest. 

Alternatives A, B, and D would not include any fertilization and thus would not reduce habitat quality for 

rare plants and fungi because of fertilization. 
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Under all alternatives, a majority of the BLM-administered lands would be allocated to reserves, where 

mature and structurally-complex forest habitat would be retained and additional habitat would develop. 

All action alternatives allocate more acres to Late-Successional Reserve than the No Action alternative, 

which would benefit rare plants and fungi associated with mature and structurally-complex forest. The 

acreage of structurally-complex forest would increase under all alternatives, as would the acreage of 

stands older than 120 years. Within the Harvest Land Base, the abundance of structurally-complex forest 

would increase substantially under the No Action alternative and Alternatives B and D, 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 forest 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 by alternative (Table 3-122). 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 No Action alternative would have the greatest acreage of potential fungi habitat 

within the Harvest Land Base; however, most of this habitat would be subject to the Survey & 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 current Survey & Manage species. Of the 

action alternatives, Alternative C would have the largest number of potential fungi habitat acres within the 

Harvest Land Base, followed by Alternatives B and D. The BLM would conduct pre-disturbance surveys 

under Alternatives A, B, and C for Special Status Species, and the BLM would provide conservation 

measures for new sites found. The BLM would not survey under Alternative D, and undetected sites 

would be affected by timber harvest. 

Table 3-122. Special Status fungi potential habitat within the Harvest Land Base by alternative. 

Alternative Fungi Habitat Acres 

within the Harvest Land Base 

No Action 207,586 

Alt. A 48,601 

Alt. B 133,763 

Alt. C 172,015 

Alt. D 125,001 

Although vegetative communities where oak species currently predominate are generally outside of the 

Harvest Land Base in all alternatives, oak species do occur within the Harvest Land Base. Oaks represent 

an immeasurable small percentage of the basal area of the forests 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 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) 

across all alternatives would decrease by 3 to 4 percent in 50 years. It is likely that the vegetation 

modeling overestimates any a decline in hardwood abundance in general and oaks in specific, 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, oaks 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. 

Within the Harvest Land Base, the different harvest methods would have varying effects on oak species. 

Alternatives A and C would both include clear cuts with no retention, and all oaks present within the 
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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 alternatives would mitigate effects of timber harvest on oaks. 

Management direction common to all alternatives 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, the BLM would apply vegetation management to 

increase species diversity and allow for hardwood persistence. 

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 Districts. However, 140,380 acres of this total 

are currently vacant, and these areas have not been subject to grazing for several years. The vacant 

allotments would remain available for grazing under the No Action alternative, and grazing could occur in 

these areas in the future. 

Alternatives A, B, and C would close the vacant allotments to grazing, but keep all active allotments open 

to grazing. Since livestock do not currently graze these areas, there would be no immediate difference in 

effects from the No Action alternative. However, closing the vacant allotments would preclude potential 

future grazing impacts to Special Status plants and fungi. 

Under all alternatives other than Alternative D, grazing would continue in active grazing allotments. 

There are 571 Special Status plant and fungi species sites that occur within active grazing allotments; 98 

percent are vascular plants and include Gentner’s fritillary. 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 and Alternatives A, B, and C, there would be no direct 

negative impacts to this species from grazing under those alternatives: there has been no evidence that 

cattle eat Gentner’s fritillary or cause measurable trampling impacts (M. Wineteer, BLM, personal 

communication, 2014). Cattle tend to concentrate in areas with water, while Gentner’s fritillary generally 

occurs on steeper slopes outside of riparian areas. 

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 special status plant and fungi 

species that occur within active grazing allotments. Elimination of grazing would reduce direct 

consumption of these species and trampling. However, elimination of grazing would also result in 

increased competition and accumulation of fuels, increasing the risk of wildfire. The specific effects of 

the elimination of 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 cattle do 

not directly affect Gentner’s fritillary, removing cattle may improve adjacent habitat for the species and 

allow for expansion. 
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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. There are approximately 650 known sites of special status plants and 

fungi within these areas, and 284 sites of current survey and manage species, in addition to representative 

examples of many types of diverse vegetation. Alternatives A and D would designate more acres of 

ACECs than other alternatives: 105,990 and 105,784 acres, respectively. Alternatives B and C would 

designate fewer acres: 99,427 and 98,104 acres, respectively (see the ACEC section in this chapter for 

more detailed information on ACEC designation). 

As a result, Alternatives A and D would have similar effects and provide the most benefit to rare plant 

and fungi species through ACEC designation. Even though the No Action alternative would designate the 

fewest acres of ACECs, it would provide only slightly less benefit to rare plant and fungi species because 

of the protection provided by interim management of potential ACECs. Alternatives B and C would have 

similar effects and provide the least benefit to rare plant and fungi species through ACEC designation. 

Road Construction 

The No Action alternative would result in the greatest mileage of new road construction in the first 

decade (Table 3-123). This mileage of new road construction would result in the removal or disturbance 

of 5,167 acres of habitat. Alternative D would result in the least mileage of new road construction in the 

first decade and 1,288 acres of habitat removed or disturbed. Although it is not possible at this scale of 

analysis with the data available to determine whether these acres represent potential or occupied habitat 

for rare plants and fungi, the acreage affected by road construction provides a relative evaluation of the 

effects of road construction on rare plants and fungi. 

Table 3-123. Road construction miles for the first 10 years of implementation. 

Alternative Total New Road 

Construction (Miles) 

Habitat Removed 

or Disturbed (Acres) 

No Action 947.3 5,167 

Alt. A 310.2 1,692 

Alt. B 687.2 3,748 

Alt. C 800.6 4,367 

Alt. D 254.5 1,388 

Off-highway Vehicle Use 

Under the No Action alternative, approximately 85,000 acres (3.3 percent) of the decision area would 

remain closed to OHV use, and approximately 330,400 acres (12.8 percent) would remain open to OHV 

use. On the remaining 83.9 percent, OHV use would continue to be limited to existing or designated 

roads and trails. On some portion of the 330,400 acres open to OHV use, habitat removal and disturbance 

has been occurring and will continue to occur in the future. 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 open to OHV use is actually 

experiencing habitat removal or disturbance or will in the future. However, within areas open to OHV 

use, such effects could occur throughout the open area without future analysis or decision-making by the 

BLM. 
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Under all action alternatives, no areas would be open to OHV use. The BLM would designate the entirety 

of the decision area as either closed to OHV use or limited to existing roads and trails. As such, there 

would be no additional habitat removal or disturbance from OHV use measurable at this scale of analysis 

with the data available under any of the action alternatives. 

Mineral Development 

The No Action alternative would maintain the closure of the largest acreage to salable mineral 

development, at 319,430 acres closed. The action alternatives would close from 226,367 acres under 

Alternative A to 246,584 acres under Alternative C. 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 development under the alternatives. 

Under the No Action alternative, 98,400 acres would continue to be withdrawn from locatable mineral 

entry. All of the action alternatives would recommend for withdrawal more than double the acreage of the 

existing withdrawals, totaling from 266,473 acres under Alternative B to 307,308 acres under Alternative 

D. As described in the Minerals section in this chapter, much of this acreage would have low prospective 

mineral occurrence or development. 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. 

There are currently approximately 1,045 mining claims of active record in the decision area, the majority 

of which occur within the Medford District, which has a disproportionate percentage of rare plant and 

fungi sites. Mining claims, notices, and plans currently exist on areas where there are known rare plant 

sites such as French Flat (Medford District) and Hunter Creek Bog (Coos Bay District), which are also 

Areas of Critical Environmental Concern. 

Issues considered but not analyzed in detail 

How would recreation management affect special status plant and fungi species, current Survey & 

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 as a result of trampling, collection of firewood, introduction 

and spread of noxious and non-native species, and soil disturbance. Recreation sites would not differ 

among the alternatives. Changes to recreation sites in the decision area under any of the alternatives, such 

are 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. 

While recreation use outside of recreation sites 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. 

How would invasive plant introduction and spread affect special status plant and fungi species, current 

Survey & Manage species, and special habitats? 
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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 

plant introduction and spread associated with management actions under each alternative. 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, current Survey & Manage 

species, and special habitats? 

Wildfire response activities, such as bulldozing for fire line access and construction, safety zone 

construction, and staging centers, can cause direct effects to rare plant and fungi sites and 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. However, the full range of wildfire 

response tactics would be available under all alternatives, and maintenance of fire suppression-related 

infrastructure would not change among alternatives (the Fire and Fuels section contains more 

information). Because these factors would not differ among the alternatives, there is no reasonable basis 

on which to identify a difference among the alternatives in the effects of wildfire response on rare plants 

and fungi. 

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